May 25, 2018 Objection Reviewing Officer USDA- Forest Service Intermountain Region 324 25th Street, Ogden, Ut 84401

Project Name: Alta Ski Lifts Master Development Plan Improvement Projects Board of Directors Responsible Official: David C. Whittekiend, Forest Supervisor Mimi Levitt; UT, President Emeritus Peter Corroon; UT, President Project District: Uinta-Wasatch-Cache National Forest Chris Mikell; UT, Vice President RE: Friends of Alta objection letter to the Draft Decision Notice, Finding of No Richard Thomas; UT, Treasurer Becky Johnson; UT, Secretary Significant Impact for Alta Ski Lifts Master Development Plan Improvement Nicholas C Besobrasov; CA, UT Projects Dan Bishop; UT Cassie Dippo; UT Dear Objection Reviewing Officer, Jim Ehleringer; UT Patrick de Freitas; UT As Alta’s local land trust and a public charity, Friends of Alta’s (FOA) mission is to work John Holland; VT on behalf of a diverse public to protect the environment of Alta, including watershed Lucy Jenkins; UT and wildlife habitat areas, and to preserve Alta’s unique character and heritage. Over Peg Kramer; PA, UT the years, FOA has worked collaboratively with the Uinta-Wasatch-Cache National Counsel Forest (UWCNF) and the Alta Ski Lifts (ASL) to accomplish common recreation and Patrick A Shea conservation goals. It is important to FOA and Alta’s far reaching community that ASL Advisory Committee remains a sustainable business and is able to provide a reliable and quality ski David Arnold III: MA experience that so many hold near and dear to their hearts. We appreciate the Brad Barber; UT Jayne Belnap, PhD; UT opportunities we have had to submit comments during this NEPA process. Gene Bliss, MD; UT Skip Branch; UT Standing Laura McIndoe Briefer; UT On both May 25, 2016 and October 20, 2017, Friends of Alta via Jennifer Clancy Margot & Fred Churchill; MA submitted public scoping comments electronically on ASL’s Master Development Plan Michael Goldstein, MD; CA (MDP). These comments enable us to object to the Draft Decision Notice and Finding Shannon Gordon; WA Jack Hoag; MA of No Significant Impact (FONSI) in which the Forest Supervisor unilaterally authorized Barbara Hoffman; NY all 10 of the projects proposed by Alta Ski Lifts. The Forest Supervisor’s decision was Austin Hoyt; MA based on the April 2018 Environmental Assessment (EA) prepared by ASL’s consultant. Felicity Forbes Hoyt; MA We are taking this opportunity to object to the draft decision notice issued by the Loren Kroenke; UT Fay Michener; NY Forest Supervisor. Our overarching goal with this letter is to provide helpful Jeff Niermeyer; UT information and specific areas where we feel the EA and the FONSI could be improved Felix G Rohatyn; NY upon or edited in order for the UWCNF to make informed decisions that will have a Dick Schatten; CT Elfriede Shane; UT fundamental impact on Alta’s future. Skip Silloway; UT Overview UWCNF’s Salt Lake Ranger District has some of the highest recreation visits in the Friends of Alta nation. We understand this puts a huge burden on staff and would like to urge the PO Box 8126 Alta, UT 84092 Forest Supervisor and District Ranger to only approve projects that can be properly reviewed and monitored for compliance, especially in environmentally sensitive areas. Jen Clancy It may be possible for the UWCNF to work closer with partnering agencies that have Executive Director staff with the applicable expertise to help monitor projects and reduce the burden on (801) 742-9719 [email protected] UWCNF staff while gaining better regulatory compliance. The timeline and approval process during the 2017 Categorical Exclusion granted to ASL for the Supreme Lift re- www.friendsofalta.org route is a fresh and painful reminder why proper planning and oversight is necessary to avoid unintended impacts such as wetland destruction.

The mission of Friends of Alta is to The EA’s purpose and need statement (pg 3) states “The Forest Service follows laws, protect the environment of Alta, regulations, and guidance specific to ski areas, while preventing unnecessary or undue including watershed and wildlife degradation of public land.” We are concerned the FONSI decision was based on a habitat areas; to preserve Alta’s unique character and heritage; and biased EA that didn’t properly analyze reasonable alternatives and was falsely to encourage stewardship and characterized on page 2 of the FONSI as “a thorough review of relevant information, sustainability of Alta’s consideration of divergent views, and acknowledgement of any incomplete or environment and community. unavailable information.”

FOA Objections to FONSI decision and EA analysis 5/25/2018 Page 1 of 5 In drafting the EA ASL’s consultant took liberty in using subjective comments to underplay the environmental impacts instead of using neutral reporting statements. Examples of this can be found on page 10 “Mt Baldy tram would have very low capacity” instead of stating what the capacity is; on page 24 in the first paragraph “Some vegetation would be cleared” and “Minor vegetation clearing” as opposed to a more neutral statement about the approximate area that would be cleared; on page 23 “Rapidly building avalanche hazard due to wind often cause Alta to close the East Baldy Traverse” instead of simply providing a number; and on page 33 “The proposed action would have a very slight detrimental impact” as opposed to stating what the impact is. While ASL has a good reputation for following Best Management Practices (BMP) and has taken the added step of creating and staffing an environmental center to manage stewardship of ASL’s Special Use Permit area it appears that their track record has recently been taken for granted instead of trusted but verified. For example, the photo to the right was taken on 7/21/2017 by Jen Clancy during the Supreme Lift re-route project on the flat at the base of the old Supreme Lift. The straw log in this photo was placed for purposes of being compliant with Storm Water Pollution Protection Plan, yet the small rocks placed on top of the straw logs are unlikely to keep sediment from the dirt pile (top left) from washing into nearby streams. In addition to the rocks not properly securing the straw logs they are also placed infrequently and in the event of a storm, debris would easily be swept under the straw logs. This example is intended to show the value and need for project monitoring to ensure compliance with applicable permits and regulations and protect Alta’s environment. Objection to decision and analysis for removal of wetlands by proposed action, most pointedly regarding the Flora Lift The FONSI and EA propose and approve the Flora Lift’s base and terminal to be sited in a wetland and destroy at least 0.23 acres of wetland. We object to the Forest Supervisor’s decision in the FONSI to approve any wetland removal including the Flora Lift and in its proposed location because 1) it would violate Salt Lake Valley Health Department (SLVHD) Regulation 14 (SLVHD and have joint authority) which prohibits the filling of a wetland/riparian area and 2) the analysis of the proposed projects is incomprehensive. Regulation 14, section 4.2 Prohibited Acts states: 4.2.14 To move dirt into a water source or disturb vegetation in a manner which causes or promotes erosion and contamination of a water source. Section 1.7.2 Other Planning Guidance (pg 5) of the EA states: “CEQ guidance stipulates that the Forest Service should inquire of other agencies whether there are any potential conflict that could arise from the proposed action. If so, this EA must acknowledge and describe the extent of those conflicts. It is Forest Service policy to work with local governments and make every effort to comply with local land use plans and regulations, even though the agency may not be legally required to do so.” This statement is in the spirit of long standing partnerships between the USFS, Salt Lake City (SLC), and the SLVHD to protect and manage the Central Wasatch Mountains to ensure clean, reliable water for the residents of the Salt Lake Valley. The Scoping Report: Alta Ski Lifts Improvements NEPA review dated May 11, 2017 (pg 10) includes the following statement about complying with SLC, Sandy, and Salt Lake County Health Department regulations regarding watershed health: “Compliance with applicable local laws and regulations is Forest Service policy, and these regulations will be considered in this analysis.” Again, the EA includes recognition of Regulation 14 in the section 1.7.2 OTHER PLANNING GUIDANCE (pg 6) and 1.9 REQUIRED PERMITS AND AUTHORIZATIONS Table 1-1 Other permits, approvals, and consultations that may be required for implementation of the proposed action or an action alternative (pg 12) under Salt Lake County but then omits including Regulation 14 under the listing for SLC Public Utilities. The FONSI and EA don’t address compliance with Regulation 14 for the proposed action and there is zero discussion regarding compliance with Regulation 14. The closest the EA comes to addressing this issue is in section 3.4.1.5 Mitigations (pg 58) where it states: “WAT-2: Obtain appropriate COE, Division of Water Rights, Salt Lake County Health Department, and Salt Lake City Department of Public Utilities permits and authorizations prior to disturbing wetlands or altering stream channels.”

FOA Objections to FONSI decision and EA analysis 5/25/2018 Page 2 of 5 While we recognize the USFS has a policy is no net loss of wetlands, wetland destruction is also referred to multiple times as we have pointed out above and there should be an effort to comply with other land use plans and regulations. Furthermore, in regards to mitigation, it’s valuable to point out “once disturbed, wetlands either recover very slowly or move towards alternative states that differ from reference conditions. Thus, current restoration practice and wetland mitigation policies will maintain and likely accelerate the global loss of wetland ecosystem functions” according to David Moreno-Mateos, a University of California, Berkeley, postdoctoral fellow’s advice based on his study that stated restored wetlands rarely equal condition of original wetlands (Moreno-Mateos 2012). It is concerning how the EA jumps to recommending mitigation measures at a 5:1 ratio (pg 56) in section 3.4.1.3 Direct and Indirect Effects of the draft EA prior to all regulatory approvals. This mitigation directive likely stems from an email Rebecca Hotze (District Ranger) sent to Charlie Condrat (Soil and Water Program Manager) on 10/17/2017 that said “I told them they need to avoid the wetlands or do a 5-1 mitigation ratio since that is what they just did…” It appears premature to provide mitigation instructions to the applicant prior to final site wetland delineation and approval of Alta’s MDP. Part of our reasoning to say the EA is incomprehensive is due to the wetland delineation for this project being done on 10/17/17 while is clearly outside the growing season at 10,000 feet, with snow on the ground, and against the best practices of the Army Core of Engineers. In the event this project moves forward in a manner that will impact any wetlands in the local area, the USFS should require a certified wetland delineation during the growing season to document the full extent of actual wetland destruction. As we witnessed with the Supreme lift reroute, at this phase of review and planning the information used to determine the location and area to be impacted is likely to be modified as the project is developed further, calling for an updated wetland delineation and assessment of wetland impacts at the proper time of year. Due to the date of delineation and planning stage at this point, we are also concerned that this analysis doesn’t adequately address the full impact area or footprint of the base terminal. All other lifts at Alta have staging areas around their bases that are mostly comprised of flat dirt areas for lift maintenance and it is unclear if this area and type of use was planned for and/or included in this analysis which could possibly be a notable omission. The Project Rationale in section 2.4.4.1 Flora Lift construction from the Bottom of Sugarbowl to the Top of Collins Lift (pg 23) states the rationale as in part “Maintaining the East Baldy Traverse between the top of Sugarloaf lift and the tops of Collins lift is a drain on snowcat and avalanche control resources” without any explanation or data to support the statement. Additionally, the statement “Even when the East Baldy Traverse is open, the experience for skiers is, more often than not, unpleasant because of wind and blowing snow.” Yet there are no numbers to base this statement on, it appears to be more of a general observation that has been stretched to support the desired outcome. There are times when due to certain wind directions, that the East Badly Traverse is difficult to use but wouldn’t those same winds make the lift ride on a fixed-grip lift equally an unpleasant experience? Section 2.6.2 of the EA (pg 30) refers to the Flora lift siting as: “complex and, in some cases, conflicting design considerations.” There is one alternative location described about 200 feet west of the proposed site with a verbal rational that the site was “seriously” considered yet there are no graphics presented to further document the statements made in the alternatives analysis. While there is a verbal summary of the alternatives, it seems reasonable to assume that planning such a lift would include a combination of site visits and mapping exercises to develop the preferred site location, point to alternatives for consideration, and exclude locations that don’t meet the stated objectives. Thorough disclosure includes providing a map or other graphic to demonstrate statements made. It is unclear if there was ever any meaningful consideration of other sites. To be transparent, thorough, and address this concern, we recommend that the EA be edited to include map or other documentation displaying the review process. Without further documentation we feel this alternatives analysis falls short in meeting NEPA requirement to consider less- disruptive alternatives. In addition to the timing of the delineations, there seem to be conflicting statements in section 3.4.1.2 Affected Environment (pg 56) as to how results of the delineations on 10/17/17 are applied to different areas. While “wetland hydrology” wasn’t present at the Flora Lift it appears to be sufficient to say it’s been observed but not by who. Couldn’t this same rationale for lack of wetland hydrology on the date of the delineation be applied to the Albion Parking lot and Sunnyside lift? “The extent of NWI-identified wetlands within the project footprints differs from the extent identified during the site investigation. Although the NWI shows wetlands in the footprint of the Sunnyside lift replacement, Supreme summer trail work, Alf’s Restaurant addition, and the equipment storage facility projects, no wetlands were observed in those locations during the site investigation. Potential wetland areas were identified from aerial and color infrared imagery in the footprints of the Albion parking lot expansion, a different area of the Sunnyside lift

FOA Objections to FONSI decision and EA analysis 5/25/2018 Page 3 of 5 replacement, and Flora lift projects. However, the potential wetlands in the Albion parking lot and Sunnyside lift alignment lacked hydric soil conditions or wetland hydrology, and therefore are not wetlands. The potential wetlands visible in the aerial and color infrared imagery at the lower Flora lift terminal are dominated by hydrophytic vegetation and have hydric soils. Although wetland hydrology was not present during the site investigation, it has been observed during the growing season. Construction of the Flora lift would impact 0.23 acres of palustrine emergent and shrub/scrub wetlands. The lower terminal accounts for 0.18 acres of those impacts. The remaining 0.05 acres are located in the lift alignment and may or may not be impacted by lift towers, depending on tower placement.” It is our intent these observations help the UWCNF in making a well informed decisions in projects that have potential impacts to wetlands in Alta. Objection to decision and analysis of proposed Baldy Tram We value the work and lives of Alta’s snow safety department and understand the desire to phase out military artillery, but we feel the decision on the Baldy Tram is premature. We can appreciate Alta’s desire for a backup plan if the artillery program ends, but there is no imminent threat stated in the EA forcing this decision to happen today. There are low impact feasible options such as using the Snowbird Tram that we don’t feel were given adequate consideration. If artillery is suddenly lost without warning the use of the Snowbird Tram to access the top of Baldy places patrol in the same situation as the Badly Tram in that they work their way down with hand charges over an area that hasn’t already been controlled. Currently, Alta’s snow safety personnel use the Snowbird Tram to first access Alta’s portion of Baldy after artillery has been shot from the Peruvian Ridge. Later the boot-pack (hike) up from the Sugarloaf Pass is put in for the public’s access. Section 2.6.1 Badly Tram Alternatives (pg 30) states: “Completing avalanche work on Mt. Baldy from the Snowbird side of the mountain, but this option would not eliminate the need for an extended hike through avalanche- prone terrain for ski patrollers to access the starting zones.” According to snow safety personnel the hike from the Snowbird Tram to the top of Baldy is safe and no control work occurs on that route prior to access, we feel this is a mischaracterization of safety of the route and encourage the UWCNF to fact check the rationale behind omitting this alternative for that reason. The EA states in Section 1.8.2 ISSUES CONSIDERED BUT NOT ANALYZED IN DEPTH (pg 10) that the “Mt. Baldy tram would have a very low capacity and primarily serve to transport ski patrol personnel.” We are later informed that it will be a 150-pph tram. What constitutes “a very low” capacity lift in this situation? Is this statement based on the average skier density of the area or industry standard ratings for lift capacity? The lack of information documenting why the lift capacity is considered very low isn’t thorough or transparent in the EA. In Section 3.4.2.2. Affected Environment (pg 65) the EA states that, “an estimated 200 people hike from Alta and Snowbird to the summit on days when Mt. Baldy is open.” With the proposed lift having the ability to transport 150 pph, Mt. Baldy has the potential to reach its current average amount of daily skiers in under just a few hours. We feel that this is will greatly add to the number of skiers that frequent this area and should be reflected more accurately in the EA. In our comment letter on October 20, 2017, FOA stated concerns about the proposed Baldy Tram being using in the summer months and being a stepping stone for further development on the peak. In a meeting Skip Silloway (at the time Board Member of FOA) and I attended with ASL General Manager Mike Maughan, District Ranger Bekee Hotze, and Carl Fisher of Save Our Canyons at ASL on October 31, 2017 Mike expressed a desire to keep the door open to future use of the Badly Tram in the summer. This statement alongside, public comments raising the issue of summer use, and most importantly the recent changes to ASL’s special use permit to manage the summer program should have triggered the evaluation of summer use in this EA and is a significant omission in the analysis. In the document RESPONSE TO COMMENTS ON PROPOSED ACTION: ALTA SKI LIFTS MASTER DEVELOPMENT PLAN IMPROVEMENT PROJECTS dated March 2, 2018 (pg 26) it states “Summer use of the lift has not been proposed or addresses in this EA and would require separate proposal and analysis if ASL wished to pursue it” without any explanation why summer use of the Baldy Tram was not being considered. Additionally, that same response goes on to say “See preceding response regarding additional future development.” The previous response states “The Responsible Official will consider the potential for future development supported by the tram in formulating a decision” yet we don’t see that that consideration documented anywhere in the EA. In an email acquired from a Save Our Canyons FOIA request, District Ranger Bekee Hotze provides comment via email on 1/12/18 at 5:54pm to the UWCNF ID Team on the draft of the Responses To Comments on Proposed Actions document. She responds “Something to consider, we have to consider reasonable foreseeable actions” in response to the statement “The Responsible Official will consider the potential for future development supported by the tram in formulating a decision” (pg 26). Her comment furthers our point that there should have been documented consideration of such use documented in the EA. Without documented reasoning we are left questioning if this omission FOA Objections to FONSI decision and EA analysis 5/25/2018 Page 4 of 5 was a strategy in acquiring approval via smaller incremental requests? While the FONSI (pg 6) states “summer use of the tram is not approved in my decision” this statement is only included in the OTHER ALTERNATIVES CONSIDERED section (pg 6) and not highlighted as part of the project approval criteria which may weaken the intent and means for future enforcement. We object to the decision in the FONSI to approve the proposed Baldy Tram based on inadequate consideration of future uses. We hope these objections and observations help guide the USFS in producing a well vetted and accurate EA that adequately considers all reasonable alternatives and regulations. Thank you,

Jen Clancy Executive Director, Friends of Alta PO Box 8126, Alta, UT 84092 801-742-9719

References/ Attached Documents Referenced text has been highlighted for convenience. Environmental Assessment: Alta Ski Lifts Master Development Plan Improvement Projects. US Department of Agriculture – Forest Service, Uinta-Wasatch-Cache National Forest, Salt Lake Ranger District, Salt Lake City, Utah. Prepared with the assistance of Cirrus Ecological Solutions, LC, Logan Utah. April 2018. Draft Decision Notice and Finding of No Significant Impact, Alta Ski Lifts Master Development Plan Improvement Projects. USDA – Forest Service, Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest, Salt Lake City, Utah RESPONSE TO COMMENTS ON PROPOSED ACTION: ALTA SKI LIFTS MASTER DEVELOPMENT PLAN IMPROVEMENT PROJECTS dated March 2, 2018 Moreno-Mateos D, Power ME, Comín FA, Yockteng R (2012) Structural and Functional Loss in Restored Wetland Ecosystems. PLoS Biol10(1): e1001247. https://doi.org/10.1371/journal.pbio.1001247 Copy of the Email from District Ranger Hotze to Charlie Condrat dated 10/17/2017 at 5:42pm

FOA Objections to FONSI decision and EA analysis 5/25/2018 Page 5 of 5

Environmental Assessment: Alta Ski Lifts Master Development Plan Improvement Projects

US Department of Agriculture – Forest Service Uinta-Wasatch-Cache National Forest Salt Lake Ranger District Salt Lake City, Utah

Prepared with the assistance of: Cirrus Ecological Solutions, LC Logan, Utah

April 2018

The United States Department of Agriculture (USDA) prohibits discrimination in its programs on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, and marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotapes, etc.) should contact the USDA Office of Communications at (202) 720-2791. To file a complaint, write the Secretary of Agriculture, US Department of Agriculture, Washington, D.C. 20250 or call 1-800-245-6340 (voice) or (202) 720-1127 (TDD). USDA is an equal opportunity employer.

Environmental Assessment: Alta Master Development Plan Improvement Projects

CONTENTS List of Tables ...... ii List of Figures ...... iii Chapter 1: Purpose and Need ...... 1 1.1 Introduction ...... 1 1.2 Organization of the Document ...... 1 1.3 Project Area ...... 2 1.4 Proposed Action ...... 2 1.5 Purpose and Need ...... 3 1.6 Decision to be Made ...... 4 1.7 Planning Guidance ...... 4 1.7.1 Forest Plan ...... 4 1.7.2 Other Planning Guidance ...... 5 1.8 Scoping and Identification of Issues ...... 7 1.8.1 Issues Subject to In-Depth Analysis ...... 8 1.8.2 Issues Considered but Not Analyzed in Depth ...... 10 1.9 Required Permits and Authorizations ...... 10 Chapter 2: Proposed Action ...... 13 2.1 Introduction ...... 13 2.2 Alternative Formulation ...... 13 2.3 Alternative 1 – No-Action ...... 13 2.4 Alternative 2 – Proposed Action ...... 14 2.4.1 Parking ...... 14 2.4.2 Avalanche Control ...... 16 2.4.3 Replacement of Lifts ...... 20 2.4.4 New Lift ...... 22 2.4.5 Ski Run Work ...... 23 2.4.6 Buildings ...... 24 2.5 Design Criteria ...... 27 2.6 Alternatives Considered but Not Carried into In-Depth Analysis ...... 29 2.6.1 Baldy Tram Alternatives ...... 29 2.6.2 Flora Lift Alternatives ...... 30 2.6.3 Gazex Installation Alternatives ...... 31 2.7 Summary and Comparison of Environmental Effects ...... 31 Chapter 3: Affected Environment and Environmental Consequences ...... 36

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Environmental Assessment: Alta Master Development Plan Improvement Projects

3.1 Introduction ...... 36 3.2 Disturbance Types and Areas ...... 36 3.3 Cumulative Actions ...... 38 3.4 Physical and Biological Environment ...... 40 3.4.1 Soil, Water, and Watershed Resources ...... 40 3.4.2 Vegetation ...... 59 3.4.3 Wildlife ...... 73 3.5 Human Environment ...... 90 3.5.1 Cultural Resources ...... 90 3.5.2 Scenic Resources ...... 95 3.5.3 Recreation ...... 100 3.5.4 Safety ...... 104 Chapter 4: Consultation and Coordination ...... 107 4.1 Introduction ...... 107 4.2 Public Scoping and Notice and Comment on the Proposed Action ...... 107 4.3 Other Consultation ...... 108 Chapter 5: List of Preparers ...... 109 Chapter 6: References ...... 110 Appendix A – Mitigaton Measures ...... A-1

LIST OF TABLES Table 1-1. Other permits, approvals, and consultations that may be required for implementation of the proposed action or an action alternative...... 11 Table 2-1. Summary and comparison of environmental effects...... 31 Table 3-1. Typical disturbance dimensions1 by project type...... 37 Table 3-2. Disturbance types and acres disturbed under the proposed action...... 37 Table 3-3. Cumulative actions considered in this analysis...... 39 Table 3-4. Soil units in the project area...... 43 Table 3-5. Wetland resources in the project area...... 47 Table 3-6. CDA analysis of the Proposed Action...... 51 Table 3-7. RHCA and Wetland Table...... 55 Table 3-8. Sensitive and watch-list plant species occurring or suspected to occur on the Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest and their level of analysis for this project...... 60 Table 3-9. Threatened, endangered, and candidate species identified by FWS that may occur in the project area and/or may be affected by the project...... 74 Table 3-10. Special-status species occurring or suspected to occur on the Uinta-Wasatch-Cache National Forest and their level of analysis for this project...... 75 Table 3-11. Partners in Flight Priority species for Utah, FWS Birds of Conservation Concern of Region 16, and species listed on the FWS IPAC website with potential to occur in the vicinity...... 79 Table 3-12. Special-status wildlife cumulative effects...... 86

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Table 5-1 List of preparers associated with this document...... 109 Table A-1. Best Management Practices that would be followed under the proposed action...... A-1

LIST OF FIGURES Figure 2-1. Overview of the proposed action...... 15 Figure 2-2. Proposed redesign plan area for Albion base parking lot...... 16 Figure 2-3. Proposed new tram from Germania Pass to the top of Mt. Baldy...... 17 Figure 2-4. East Devil’s Castle and Sugarloaf Mountain with proposed Gazex locations...... 19 Figure 2-5. Patsey Marley with proposed Gazex locations...... 19 Figure 2-6. Existing Albion and Sunnyside lifts with proposed replacement of Sunnyside lift...... 20 Figure 2-7. Existing Wildcat lift with proposed lift replacement...... 22 Figure 2-8. Proposed new Flora Lift from the bottom of Sugarbowl on Sugarloaf to the top of Collins lift...... 23 Figure 2-9. Proposed Supreme summer run work...... 24 Figure 2-10. Existing Alf’s restaurant building with proposed addition...... 25 Figure 2-11. Existing Watson Shelter building with proposed addition area...... 26 Figure 2-12. Proposed equipment storage facility building...... 27 Figure 3-1. Watershed resources map including soils, wetland, and RHCAs...... 44 Figure 3-2. Alta ski area...... 97

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Environmental Assessment: Alta Master Development Plan Improvement Projects

CHAPTER 1: PURPOSE AND NEED 1.1 INTRODUCTION On December 5, 2015, the Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest (UWCNF) received a proposal from Alta Ski Lifts (Alta) to authorize a number of improvement projects that the ski area proposes to complete over the next several years. As the projects are included in Alta’s accepted master development plan (MDP), are within the ski area’s special use permit (SUP) area, and are consistent with UWCNF screening criteria, the Forest Service agreed to review Alta’s proposal. MDPs are a requirement of USDA-Forest Service (Forest Service) ski area special use permits (SUPs) and serve as a conceptual planning tool to outline the operators’ vision as to how ski areas will evolve over a 10-to-15-year planning horizon. They are intended to be dynamic documents, amended or revised periodically to reflect changes in operational opportunities and constraints, skier market demands, or agency administrative requirements. Acceptance of an MDP does not authorize implementation of the plan. Decisions regarding authorization are based on review required by the National Environmental Policy Act (NEPA) addressing projects that are ripe for decision and capital investment, generally within the next 5 years. The proposed projects may affect the human environment, so the Forest Service must analyze and disclose potential impacts in accordance with NEPA. The UWCNF has decided that the appropriate level of review for this proposal is an environmental assessment (EA). The UWCNF has prepared this EA in compliance with NEPA and Forest Service regulations regarding its implementation (36 CFR 220). This EA discloses the direct, indirect, and cumulative environmental impacts that would result from implementing the proposed action and required no-action alternative, in support of an agency decision regarding Alta’s requested authorization. The ski area operates under a Special Use Permit (SUP) issued by the Forest Service. The current SUP was issued in 2002 and is administered by the UWCNF. It has a term of 40 years. All proposed projects fall within the current SUP boundary. 1.2 ORGANIZATION OF THE DOCUMENT This EA is organized as follows:

 Chapter 1 – Purpose and Need: Includes background information on this EA process, outlines the organization of the document, describes the project area, summarizes the proposed action and the purpose and need it addresses, defines the decision to be made on the basis of this EA, identifies relevant higher level Forest Service plans, describes how the UWCNF informed the public of the proposed action and how the public responded, then lists other permits and authorizations that may be necessary to implement the proposed action.  Chapter 2 – Proposed Action and Alternatives: Provides a detailed description of the proposed action, the alternative formulation process, and the no-action alternative. Concludes with a comparative summary of the anticipated environmental effects of the proposed action and no- action alternative.  Chapter 3 – Affected Environment and Environmental Consequences: Describes the existing resource conditions and the direct, indirect, and cumulative environmental effects of implementing the proposed action and no-action alternative. Discussion is organized by resource and addresses the specific issues associated with each resource identified through public scoping and internal, interdisciplinary review.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

 Chapter 4 – Consultation and Coordination: Identifies the agencies and other entities consulted during the preparation of this EA.  Chapter 5 – List of Preparers: Identifies the UWCNF and contractor personnel involved in preparation of this EA.  Chapter 6 – References: Lists the references cited in the text of this EA.  Appendices: Provide more detailed information supporting the analyses presented in this EA. Documentation of this EA process is available in the project record located at the Salt Lake Ranger District, 6944 South 3000 East, Salt Lake City, UT 84121. 1.3 PROJECT AREA The project area is defined as Alta’s approximately 1,800-acre SUP area. It is generally bounded by State Route 210 (SR 210) on the north, the ridgeline separating Big and Little Cottonwood canyons on the east, the Salt Lake County/Utah County line on the south, and Snowbird Ski and Summer Resort on the west. Access is from the Salt Lake Valley, about 13 miles up SR 210. Elevations range from 8,530 feet to 11,051 feet, and exposures are generally north. The project area is in the UWCNF’s Central Wasatch Management Area. 1.4 PROPOSED ACTION A description of the proposed action was provided to individuals, groups, and organizations during the agency-designated scoping period starting in April 2016. Public scoping was used to gain feedback on preliminary issues, identify new issues, and possibly identify alternatives to consider. Scoping and public involvement are discussed in Section 1.8 and the proposed action is described in detail in Chapter 2. Scoping of this proposed action included three projects that were subsequently dropped from this analysis. The Supreme lift replacement and associated Cecret lift removal were analyzed separately and authorized in February 2017. On the basis of scoping comments, the decision was made to remove the restoration of Lake Flora, at the top Glory Hole, from this analysis and investigate water-storage alternatives, including the potential for expanding Cecret Lake. The Lake Flora project will remain in Alta’s MDP until an acceptable alternative is identified. The proposal to remove Albion lift was dropped due to concern over losing redundant lift capacity out of the Albion base area. In November 2017, the WCNF published a Notice of Proposed Action, initiating a second opportunity to comment, this time on a draft of the EA. On the basis of the comments received, the proposed addition to Alf’s restaurant was shortened so that it would not extend as far to the southeast of the existing building in order to increase the buffer distance between the building and the drainage to the south. The reduction in area may be offset by a second story over a portion of the existing building. The final change to the proposed action since scoping involves the Albion parking lot expansion. Construction of a new Snowpine Lodge immediately west of the parking lot began in 2017. This, coupled with Utah Transit Authority (UTA) using additional parking spots in the lot as a waiting area for buses, requires adjustment of Alta’s planning for the parking lot project. Increased flexibility in final planning for the parking expansion is needed to address public comments on the need to separate SR 210 traffic from Albion parking lot traffic, the Snowpine Lodge construction, and additional public transportation needs. As a result, the expansion footprint has been changed to include 30 feet of widening along the northern edge of the lot, opposite the Albion Grill, in addition to the originally proposed fill along the lower, southern edge of the existing access road and parking lot. The remaining projects were unchanged and constitute the proposed action, which includes the following (see section 2.4 for a detailed description of each project):

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Environmental Assessment: Alta Master Development Plan Improvement Projects

1. Albion/Wildcat base parking. 2. Tram from Germania Pass to the top of Mt. Baldy. 3. Gazex or other equivalent technologies to replace artillery and Avalaunchers. 4. Sunnyside lift replacement. 5. Wildcat lift replacement. 6. Flora lift construction from bottom of Sugarbowl to the top of Collins lift. 7. Supreme summer ski run work. 8. Alf’s restaurant building addition. 9. Watson Shelter building addition. 10. Equipment storage facility construction. 1.5 PURPOSE AND NEED The purpose of this action is to review and process the applicant’s proposal to make improvements within the project area. The Forest Service follows laws, regulations, and guidance specific to ski areas, while preventing unnecessary or undue degradation of public land. The need for the proposed action is to respond to Alta’s proposal. The proposed projects occur on lands administered by the UWCNF. The Forest Service Manual provides the following direction for management of privately provided recreation opportunities: “To provide, under special-use authorization, sufficient, suitable facilities and services that supplement or complement those provided by the private sector, State and local government on private land and the Forest Service on National Forest System land to meet public needs, as determined through land and resource management planning. To facilitate the use, enjoyment, understanding and appreciation of natural resource settings in National Forests” (FSM 2340.2). In addition, the Forest Service now operates under the directive to implement the Ski Area Recreational Opportunity Enhancement Act of 2011, which provides long-awaited direction on the types of summer activities the Forest Service should consider authorizing to round out the range of opportunities provided to the public at permitted mountain resorts. The 2003 Revised Forest Plan for the Wasatch-Cache National Forest (Forest Plan) provides overarching direction, goals, standards and guidelines, and desired future conditions for all management activities on the National Forest (Forest Service 2003). The project area is located within the Central Wasatch Management Area (Forest Plan, p. 4-152), where we have identified developed recreation areas, which include ski areas. The applicant’s proposal is consistent with the Forest-wide goal of providing a diverse range of recreation opportunities to a wide segment of the population (Forest Plan, p. 4-11). Alta’s purpose for their proposal is to make more efficient and safe use of the resources within the permit area by replacing outdated equipment, upgrading service facilities, and taking advantage of new technology. Specific needs to be resolved in order to achieve Alta’s purpose include: 1. Improving economic and environmental sustainability. 2. Improving visitor parking. 3. Enhancing avalanche control methods. 4. Upgrading lift service while reducing visual and land impacts. 5. Taking advantage of emerging lift technology to streamline service. 6. Increasing efficiency of access to popular terrain. 7. Upgrading skier services and opportunities while improving skier distribution and circulation.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Project-specific rationales are provided in section 2.4 and explain how these needs would be met. 1.6 DECISION TO BE MADE In consideration of the stated purpose and need and this analysis of environmental effects, the responsible official, the UWCNF Forest Supervisor, will review the proposed action to make the following decisions: 1. Whether to authorize it, all or in part; 2. What design criteria and mitigation measures to require for the actions authorized; and 3. What evaluation methods and documentation to require for monitoring project implementation and mitigation effectiveness. 1.7 PLANNING GUIDANCE

1.7.1 FOREST PLAN The Forest Plan provides primary guidance for management of the land and resources on the UWCNF, including portions of Alta on NFS land. The Forest Plan indicates that Alta’s SUP boundary falls within the Central Wasatch Management Area and is subject to both Forest-wide and management area-specific standards and guidelines pertinent to this type of activity. The Forest Plan provides management prescriptions that define the primary land use allocation for a given land area. Management prescription categories provide a general sense of the management or treatment of the land intended to result in a particular condition being achieved or set of values being maintained or restored. Each management prescription includes a set of standards and guidelines identifying activities that are not allowed and parameters within which activities that are allowed should be conducted. Management prescriptions for each category identify management emphasis and focus, highlighting considerations for harmonious and coordinated multiple-use management, maintenance of productivity, and the relative values of various resources. Alta is primarily located within management prescription 4.5 (Developed Recreation Areas), though small portions around the perimeter are also in 3.1W (Watershed). These management prescriptions are as follows: 4.5 Developed Recreation Areas: These areas include developed facilities such as campgrounds, trailheads, boat docks, and resorts under special use permit as well as adjacent areas associated with these sites. High levels of visitor interaction can be expected where sights and sounds of others are noticeable and there are moderate to high opportunities for social interaction. Access to these areas is primarily by motorized roads with some trails. Visitors can expect higher levels of regulation. Signs and visitor information are noticeable throughout the area. Site development tends toward the Roaded Natural to Rural end of the Recreation Opportunity Spectrum (ROS). Facilities vary from rustic using native materials to facilities designed primarily for visitor comfort or convenience and built using synthetic materials. Visitor impacts can be noticeable. Impacts to natural resources are dealt with through various management techniques and regulations. Management visibility is high with managers focusing on public safety, service, education, user ethics, and enforcement. Americans with Disabilities Act (ADA) level development is encouraged. Because of the large capital investments in these areas, site protection is paramount (Forest Plan, pp. 4-73–74). 3.1W Watershed: Emphasis is on maintaining or improving the quality of watershed conditions and aquatic habitats. Watershed function and aquatic habitat values are recognized as important and may require restoration to reach desired conditions. Areas of

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Environmental Assessment: Alta Master Development Plan Improvement Projects

municipal watershed and public drinking water sources will be managed to maintain or improve soil processes and watershed conditions. Where improvement is needed, it is achieved by implementing watershed improvement projects, and by applying soil and water conservation practices to land-disturbing activities (Forest Plan, p. 4-69). The 3.1W management prescription consists of uplands identified as important watersheds.  (S3.1W) Timber harvest, road construction and new recreation facility development are not allowed.  (G3.1W-1) Vegetation/fuel treatment, prescribed fire, and wildland fire use are allowed for the purposes of maintaining, improving or restoring watersheds to desired conditions, and to protect property in the wildland urban interface.  (G3.1W-3) New trail construction is allowed with consideration of existing road/trail densities.

1.7.2 OTHER PLANNING GUIDANCE CEQ guidance (question 23a, Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations) stipulates that the Forest Service should inquire of other agencies whether there are any potential conflicts that could arise from the proposed action. If so, this EA must acknowledge and describe the extent of those conflicts. It is Forest Service policy to work with local governments and make every effort to comply with local land use plans and regulations, even though the agency may not be legally required to do so. In this case, applicable plans include Salt Lake County’s Wasatch Canyons Master Plan and the Salt Lake City Watershed Management Plan. Local ordinances and regulations that may apply include the Salt Lake County Foothills and Canyons Overlay Zone (FCOZ), Salt Lake Valley Health Department Regulations, Salt Lake City Title 17, Chapter 17.04 (Watershed Areas), and the Town of Alta General Plan.

1.7.2.1 Wasatch Canyons Master Plan Salt Lake County’s Wasatch Canyons Master Plan (Salt Lake County 1989) is intended to guide and coordinate land use and development in the seven major Wasatch Canyons, including . This plan is being revised, but relevant points from the current version can be summarized as follows. Regarding water quality, the plan notes that “All stream segments within the plan area have been designated by the state under the Clean Water Act for antidegradation, which means canyon policies must prevent any water quality degradation... All uses will be carefully reviewed by Salt Lake County with an initial determination of whether the activity after mitigation measures would adversely impact the watershed.” (p. 27) With specific reference to ski areas and Alta, the plan states that:  “The ski resorts must be able to adapt to changes in market size and composition and to innovations in equipment and physical facilities in order to compete in the national market.” (p. 36)  The largest use in Little Cottonwood Canyon is alpine skiing, including Alta and Snowbird ski areas. “The plan provides for existing Canyon roles to continue.” (p. 74)  For Little Cottonwood Canyon: “Ski resorts will be required to evaluate and mitigate project traffic impacts associated with proposals which would increase their use capacities.” (p. 77)

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Environmental Assessment: Alta Master Development Plan Improvement Projects

The plan also lists issues that “are considered to be requisite components of the review process to determine the short- and long-term effect of a development: 1. Water quality, with primary attention to municipal watershed management; 2. Transportation, with assessments of predominant modes, qualification of impacts, and traffic mitigation strategies; 3. Vegetation, including mountain wetlands; 4. Wildlife; 5. Other users of Canyon resources, including public recreation; 6. Visual impacts including signs; 7. Public health and safety; 8. Public infrastructure; 9. Cultural and historical impacts; 10. Other factors deemed important.”(pp. 101-102)

1.7.2.2 Salt Lake City Watershed Management Plan Salt Lake City, a municipal public water supplier as defined by the Federal and State Safe Drinking Water Act, obtains a significant proportion of its culinary water from streams originating in the Wasatch Canyons, including Little Cottonwood Canyon. The purpose of the Salt Lake City Watershed Management Plan (Salt Lake City Department of Public Utilities 1999) is to protect this valuable watershed (p. 1). The Salt Lake City Department of Public Utilities is mandated to monitor and regulate any activities that may threaten water quality (p. 11). This plan is being revised, but relevant points from the current version can be summarized as follows. Under Desired Future Conditions (p. 3), the plan states that: Successful implementation of the ’99 Watershed Plan will achieve a desired future condition in the Wasatch Canyons that maintains excellent water quality and continues to strive for superior water quality. 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. This means that any impact on water quality as a result of the proposed action or other alternatives should be avoided or mitigated.

1.7.2.3 Salt Lake Valley Health Department Regulations The Salt Lake Valley Health Department (SLVHD) provides public health services, including environmental health, to the Salt Lake Valley community. SLVHD regulations applicable to development and use in the Wasatch Canyons, including Little Cottonwood Canyon, include Regulation No. 11, concerning water systems, Regulation No.12 concerning subdivisions, Regulation No.13 concerning wastewater, and Regulation No.14, concerning watershed health. Salt Lake City and the SLVHD have joint decision-making authority under Regulation No. 14.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

1.7.2.4 Salt Lake City Title 17, Chapter 17.04, Watershed Areas Salt Lake City has authority to protect its municipal watersheds outside of its municipal boundaries under the Utah Constitution (Article XI, Section VI) and state statute (Utah Code Ann. 10-8-15). Federal legislation was enacted in 1914 and 1934 (Public Laws 199 and 259) that recognized Salt Lake City’s authority. Salt Lake City has implemented state statutory authority for watershed protection through the adoption of ordinances under Title 17 of the Salt Lake City Code. Title 17 includes all ordinances under the jurisdiction of Salt Lake City Department of Public Utilities. Chapter 17.04 contains ordinances for Salt Lake City’s watershed areas. Relative to ski area management in the watershed, Article IV governs water use and sanitary facilities. Article IV include rules and regulations (17.04.180), sanitary sewage disposal system requirements (17.04.210), garbage or human waste disposal - permit required (17.04.230), chemical toilets or privies (17.04.250), hauling of human waste required (17.04.280), and prohibited locations of toilet vaults (17.04.290).

1.7.2.5 Town of Alta General Plan The 2005 Town of Alta General Plan (Town of Alta 2005, revised 2013 and 2016) includes a vision statement (p. 1) that summarizes the desired balance between growth and development of the community and maintenance of the natural resources that sustain it: Alta’s residents, employees, and business-owners strive for responsible and sustainable growth and development. We celebrate the winter sports activities that are fundamental to our town and we support expansion of Alta’s summer economy. We are committed to protecting Alta’s scenic and natural resources, especially its critical watershed. While emphasizing responsible environmental awareness and stewardship, we welcome the thousands of people who visit Alta for its recreational opportunities, and we invite them to share our vision for Alta… …Albion Basin will be sustained with minimal development. We will carefully consider the effects on the environment, including the watershed, wildflowers, and wildlife; public safety; and traffic in evaluating transportation options within Little Cottonwood Canyon and for transportation and skier connections to Big Cottonwood Canyon and the eastern side of the . The plan goes on to describe how protection of resources and ecological functions including water quality and watershed protection; wetlands; slopes, erosion, and soil stability; construction and avalanche hazard; vegetation; and visual impact are to be managed. Compliance and support of the laws, regulations, and policies of the pertinent regulatory and land-management agencies is the emphasis. 1.8 SCOPING AND IDENTIFICATION OF ISSUES All opportunities for public involvement in this NEPA process are described in Chapter 4. The purpose of the first solicitation was to receive public input on the “scope” of the EA—the issues and concerns to address, and the means to avoid or minimize adverse impacts (i.e., alternatives, design criteria, and mitigation measures). On April 22, 2016, the UWCNF issued a public scoping notice summarizing the proposed action and inviting comments regarding the scope of the associated NEPA review. The notice was mailed to the agencies, organizations, and individuals on the UWCNF mailing list. It was also posted on the UWCNF website and made available on CD or hard copy to anyone requesting it. The scoping period formally began on April 26, 2016, with publication of a legal notice in the Salt Lake Tribune and closed on May 26, 2016. Comments were received from one agency, three organizations, and 123 individuals. A scoping report was prepared that identified commenters, listed the comments received, and noted the disposition of those comments in this NEPA process. The scoping notice, comments, and scoping report are included in the project record.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

The proposed action and scoping results were reviewed by a UWCNF interdisciplinary team (ID Team) to help determine what environmental issues the EA would address (40 CFR 1508.25). Issue statements were formulated, organized by resource discipline, then reviewed and approved by the Responsible Official. They include issues to be analyzed in depth and those dropped from in-depth analysis for various reasons (e.g., because they were beyond the scope of this environmental analysis, expressed opinions rather than raising issues, involved matters covered by other laws or regulations, or were too speculative to analyze effectively). The two categories of issues are discussed in the following sections.

1.8.1 ISSUES SUBJECT TO IN-DEPTH ANALYSIS Scoping and internal, interdisciplinary review identified the following issues which guide the EA’s analysis of direct, indirect, and cumulative effects. The paragraph following each issue statement identifies the potentially affected resources and how they might be affected. It does not describe actual impacts.

Soil, Water, and Watershed Resources  How would the proposed infrastructural development affect soils, erosion, sedimentation, water quality, and overall watershed function? The project area is characterized by steep slopes, erosive soils and, in many areas, sparse ground cover. Construction-related disturbance and subsequent use could result in decreased permeability and productivity, and increased erosion and sediment transport to streams. Since the ski area is in Salt Lake City’s municipal watershed, maintaining water quality is of concern.  Could potential leaks and spills of fuels and other chemicals impact water quality? Construction, maintenance, and use of the proposed facilities would involve the use of fuel and other chemicals. Leaks or spills could adversely affect water quality in Little Cottonwood Creek.  How would the proposed infrastructure affect wetlands and riparian areas? The project area includes several types of wetlands, riparian areas, intermittent and perennial streams, and associated riparian habitat conservation areas (RHCAs). Construction and subsequent use could decrease the functioning and the extent of these valuable, aquatic habitats. The wetlands adjacent to the Albion parking lot are a particular concern.

Vegetation  How would the proposed infrastructure affect special-status plant species? No federally listed plant species are known to occur at Alta, but several Forest Service Region 4 sensitive species and UWCNF watch-list species may occur in potentially disturbed areas. Clearing, grading, excavation, or subsequent use could adversely affect plants of these species.  How would the Baldy tram, in conjunction with climate change, affect the alpine ecosystem on Mt. Baldy? Constructing, maintaining, and operating the Baldy tram could adversely impact alpine vegetation on the peak, and warming trends could exacerbate that impact.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Wildlife  How would the proposed infrastructural development affect special-status terrestrial and aquatic wildlife species and other species of interest or concern? There is no potential habitat for federally listed wildlife species in the project area, but potential habitat for several Forest Service Region 4 sensitive species is present. Other species of concern to the public or agencies are also present, such as migratory birds and big game species. These species could be affected through habitat alteration resulting from clearing, grading, excavation, changed patterns of human activity, or the impacts of Gazex avalanche control. Cultural Resources  How would the proposed infrastructure affect Cultural Concerns, Traditional Cultural Places (TCPs), or Native American Sacred Sites? Section 3.4.1.1 of Alta’s 1997 Master Development Plan Final Environmental Impact Statement (FEIS) states that “prior to European settlement the ski area was used by Native Peoples for both hunting and plant gathering in a lifeway that was otherwise tied to the more abundant resources of the adjacent Salt Lake Valley. This short-term use leaves little archaeological imprint, and few examples of Native sites remain anywhere in the canyon.” Nevertheless, the project area could hold values for Native Peoples that may be affected by the proposed action.  How would the proposed infrastructure affect historic properties? The clearing, grading, and excavation associated with construction of the proposed facilities could affect other historic properties (any cultural resource deemed eligible to the National Register of Historic Places, both prehistoric and historic) in or around the project area.  How would the proposed infrastructure affect the historic integrity of the ski area? Alta was the site of intensive mining activity from the late 19th and early 20th centuries, and it is also one of the oldest continuously operating ski areas in the nation, with the first tow installed in 1939. While most of the historic infrastructure has been removed or replaced, the clearing, grading, and excavation associated with construction of the proposed facilities could further affect the ski area’s historic integrity.

Scenic Resources  How would the proposed infrastructure affect the scenic integrity of the project area? The project area viewscape has been affected by intensive mining activity from the late 19th and early 20th centuries followed by 77 years of ski-area development, but at this point its visual character is generally natural. Additional infrastructure such as the proposed Baldy tram and Gazex installations could alter that character and detract from the area’s scenic integrity.

Recreation  How would the proposed infrastructural development affect skier density and circulation? Changing the types and configurations of lifts could adversely affect skiers’ experience at Alta. Specific concerns noted by commenters are: - Higher-capacity lift upgrades may increase crowding on ski runs. - Eliminating the hike to Mt. Baldy with the tram may reduce its attraction. - The Baldy tram’s lift line and the top terminal of Flora lift may interrupt skier traffic at Germania Pass.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Safety  Does lift access to Mt. Baldy pose a safety risk?

Some of the runs on Mt. Baldy, such as the Baldy Chutes, are experts-only terrain that must be hiked to now, which limits use. The tram may result in skiers without the requisite skills attempting to ski this terrain and being injured.  Would sympathetic avalanche releases from proposed Patsey Marley Gazex installations pose a safety risk for backcountry skiers in Wolverine Cirque?

Wolverine Cirque lies on the other side of Patsey Marley ridge from Alta. It is one of the more heavily used backcountry skiing venues in the Wasatch due to its easy access from Alta and Brighton. The proposed Gazex installations on the Alta side of Patsey Marley could potentially trigger avalanches on the other side, posing a risk to backcountry skiers.

1.8.2 ISSUES CONSIDERED BUT NOT ANALYZED IN DEPTH

Growth-Related Effects The intent of the proposed action, as outlined in EA section 1.5, is to replace outdated equipment, upgrade service facilities, and take advantage of new technology. The proposed action does not open any new terrain; it simply updates the infrastructure serving existing terrain. The new lifts are not designed to add capacity. The Flora lift would replace East Baldy Traverse’s transfer function, not provide ski access. The Mt. Baldy tram would have a very low capacity and would serve primarily to transport ski patrol personnel. Public use would involve primarily those expert skiers who currently hike Mt. Baldy. The Wildcat and Sunnyside lift replacements would have somewhat higher capacities than the existing lifts, but increasing skier capacity is not the rationale for the replacement. As outlined in sections 2.4.3.1 and 2.4.3.2, the upgrades are to replace old, less reliable lift systems, provide redundant capacity when other lifts are down, and meet the current skier market’s desire for high-speed lifts. Sections 3.5.3.2 and 3.5.3.3 describe Alta’s well-established program of maintaining low skier density by adjusting the operating speeds of their lifts and rarely operating them at design capacity. As discussed in sections 2.4.6.1 and 2.4.6.2, the proposed additions to Alf’s restaurant and Watson Shelter are mostly to replace space lost to new retail functions – another adaptation to changing skier demands. In short, the intent of the proposed action is not to increase visitation but to maintain numbers by meeting the needs and expectations of today’s skier market and changing patterns of skier use at Alta. Overall ski area capacity would not change appreciably, and the cap on new parking would remain in place. As a result, this EA focuses on the resource impacts of infrastructural development under the proposed action and alternatives, and not the impact of more visitors to Alta. Impacts in the following areas are not addressed further in this EA: 1. Air Quality 2. Transportation and Parking 3. Utilities 4. Socio-economics 1.9 REQUIRED PERMITS AND AUTHORIZATIONS

Table 1-1 describes other permits, approvals, and consultations that Alta may be required to obtain prior to implementation of any projects approved by the UWCNF on the basis of this analysis.

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Table 1-1. Other permits, approvals, and consultations that may be required for implementation of the proposed action or an action alternative. Agency Type of Action Description of Permit or Action Federal USDA-Forest American National Standards Final designs for approved lifts and structures go through Service Institute, Architectural Barriers Regional-level engineering review to ensure compliance Act, Americans with with applicable codes and agency standards. Lifts also Disabilities Act, and other code require post-construction testing and approvals. compliance review for lifts and structures. US Army Corps of Issuance of Clean Water Act, The COE issues permits required for the discharge of Engineers (COE) Section 404 Permit. dredged or fill materials into Waters of the US, including wetlands. Nationwide or individual permits may be needed. Environmental Review and comment Under NEPA, the EPA is required to review and comment Protection Agency regarding: on “major federal actions that have a substantial impact on (EPA) Clean Air Act, as amended, 42 the human environment.” The EPA’s responsibility and USCA Section 7410-762 (PL role is to provide scoping comments, review EISs, and 95-604, PL 95-95). provide information and appropriate technical assistance during and following the environmental analysis process. Federal Water Pollution Specific environmental legislation for which the EPA is Control Act, as amended by the responsible and which may be applicable to this proposed Clean Water Act, 33 USCA action is shown to the left. Administrative and enforcement Section 1251-1376 (PL 92-500, responsibilities have been delegated to the State of Utah PL 95-217). for these acts. The EPA may be involved in 404 permitting Safe Drinking Water Act, 452 in association with the COE. USCA. Section 300F-300J-10 (PL 93-523). Clean Water Act, Section 404 Permit.

Fish and Wildlife Endangered Species Act, If impacts on federally listed species are possible, the FWS Service (FWS) Section 7 Consultation. will consult with the Forest Service, review a Biological Assessment (BA), and issue a Biological Opinion. The Fish and Wildlife Coordination FWS also coordinates with the Forest Service in Act consultation. accordance with the Fish and Wildlife Coordination Act, Migratory Bird Treaty Act Migratory Bird Treaty Act, Bald and Golden Eagle Protection Act, and reviews Section 404 permit Bald and Golden Eagle applications to avoid adverse impacts to federally listed Protection Act species. Section 404 Permit consultation.

State of Utah Department of Review and Comment The Air Quality Division’s review ensures that state and Environmental federal air quality standards are not exceeded. Approval Issuance of Approval Orders. Quality: Orders are required for certain stationary emissions - Air Quality Section 401 certification. sources. Division Issuance of a construction The Water Quality Division’s review ensures that state and federal water quality standards are not exceeded. Section - Water Quality permit. 401 certification would be required for any point-source

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 1-1 (cont’d). Other permits, approvals, and consultations that may be required for implementation of the proposed action or an action alternative. Agency Type of Action Description of Permit or Action Division discharge and is obtained in conjunction with a Section 404 permit. Preparation of a Storm Water Pollution Prevention Plan (SWPPP) is a requirement for a construction permit. Department of Review and comment The Division of Wildlife Resources is responsible for Natural Resources management and protection of state wildlife and fish resources. - Division of Issuance of Stream Alteration Wildlife Permit. The Division of Water Resources is responsible for Resources determining adequacy of water supply and cumulative - Division of impacts on water supply. They also review plans and issue Water stream alteration permits for projects which alter streams Resources and/or streambeds. State History Consultation on National The Division is responsible for protection of cultural Division Historic Preservation Act, resources. Section 106 compliance process. Salt Lake County Salt Lake Valley Approval of site plans, sanitary Site plans, sanitary facilities, other water usage, and Health Department, facilities, other water uses, and revegetation and erosion control plans must be approved Environmental revegetation and erosion prior to construction. Health control plans pursuant to regulations 11, 12, 13, and 14. Salt Lake City Public Utilities Approval of culinary water The Department is responsible for determining whether Department supply and sewage facilities. proposed projects fall within Salt Lake City’s surplus Approval of site plans and water supply agreement areas. Salt Lake City’s ordinance revegetation and erosion (Title 17, Chapter 17.04) prohibits the expansion of water control plans. supply agreements within the municipal watershed and requires adequate sanitary facilities. Stream setback requirements, site plans and revegetation and erosion control plans must be approved prior to construction. Town of Alta Building Approval of building permits. The Building Department is responsible for building Department permits and approvals. Building Inspector Issuance of building permits. The building inspector is responsible for issuance of building permits.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

CHAPTER 2: PROPOSED ACTION 2.1 INTRODUCTION This chapter provides a detailed description of the proposed action, the alternative formulation process, and the no-action alternative. It concludes with a comparative summary of the anticipated environmental effects of the proposed action and alternatives. 2.2 ALTERNATIVE FORMULATION Analysis of the no-action alternative provides a baseline for assessing the impacts of the proposed action and any action alternatives. In this case, no action would mean that the improvements comprised by the proposed action, described below in section 2.4, were not approved. Action alternatives are different courses of action by which the purpose and need addressed by a proposed action could reasonably be achieved. Scoping comments for this analysis suggested alternatives to several, individual elements of the proposed action but no broad, comprehensive alternatives. None of the element-specific alternatives were carried into in-depth analysis for reasons outlined in section 2.6 below. 2.3 ALTERNATIVE 1 – NO-ACTION Under the no-action alternative, the proposed action would not be authorized. Ongoing ski area operations would continue in accordance with the current SUP, and Alta would not make the proposed improvements to the permitted ski area. As a result:  The Albion parking lot would continue to fill on busy days, forcing visitors to park in the Snowpine lot and alongside the road, then negotiate the steep hill, often icy conditions, and passing traffic to reach the Albion base area. Space for public transit, skier drop-off, and carpooling would remain limited at the Wildcat lot.

 Artillery, Avalaunchers, and helicopter-delivered explosives would remain the primary avalanche-control options on Mt. Baldy, Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley, retaining the associated staff and public safety issues and weather constraints on helicopter operations.

 The age and design of the Sunnyside and Wildcat lifts would continue to jeopardize vital out-of- base lift capacity. Lift failures would become more frequent, resulting in long waits, shortened ski days, and reduced skier experiences due to circulation bottlenecks at either or both of Alta’s base areas.

 East Baldy Traverse would remain the only connection between the top of Sugarloaf lift and the top of Collins lift, posing high demands on slope-maintenance and avalanche-control resources and an often uncomfortable skier experience.

 Lack of a summer-groomed, easier route down would continue to hamper safe, efficient use of the Supreme pod.

 Alf’s restaurant would continue to be a crowded venue for guests, an impediment to circulation, and difficult snow-grooming issue.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

 Sufficient storage, circulation, and food-service seating would be ongoing issues at Watson Shelter.

 Off-site storage of supplies and equipment would continue to cause increased traffic and vehicle emissions on SR 210 and overall inefficiency. 2.4 ALTERNATIVE 2 – PROPOSED ACTION Figure 2-1 shows the projects comprised by the proposed action. They are each described below.

2.4.1 PARKING

2.4.1.1 Albion/Wildcat Base Parking Project Description: Modify and expand the Albion and Snowpine parking lots and the roadway connecting them to replace parking spaces lost to transit development at Alta, balance parking capacity between the Wildcat and Albion base areas, and improve visitor access and safety. The Albion and Snowpine lots would be expanded by filling an area of about 1.3 acres below (south of) the existing lots and access road, and cutting into the bank about 0.4 acres on the opposite (north) side of the Albion lot, across from the ticket office and Albion Grill (see Figure 2-2). The access roadway between the lots would be regraded to reduce the steepness of the transition. Widening along the south side would accommodate a snow-covered bench where skiers could put on their gear and ski down to the ticket office and lift terminals. The Wildcat lot would remain the same size. The exact increase in parking capacity within this space would reflect the number of spaces lost to past and reasonably foreseeable transit development in all three lots. The UWCNF would specify the authorized number prior to commencement of the project. Regardless, the expansion would fall within the proposed footprint. There would be no net increase in parking capacity, since these modifications would only replace parking spaces that have been, or will be, lost to accommodate mass transit. The three existing culverts that carry runoff and stream discharge beneath the existing Albion parking lot would be extended (the current combined 362 feet of culvert would increase to 592 feet). The oil/water separator and pollution control measures already in place in the Albion parking lot would either be maintained or rebuilt as part of the project. These parking improvements would occupy approximately 1.7 acres of NFS land. Project Rationale: In recent years, Alta has allocated space in the Wildcat and Albion lots previously used for parking to facilitate transit. Specifically, the entry to the Wildcat lot has been modified to accommodate UTA buses, passenger drop-off/loading zones have been created, and space has been designated for carpooling. At present, the figures are 50 spaces lost in the Wildcat lot and 48 spaces lost in the Albion lot. Recently, UTA has begun parking idle buses in the Snowpine lot rather than running them down the canyon empty, and other transit options requiring space in the base areas are under discussion. The expanded parking footprint at the Albion and Snowpine lots would allow Alta to maintain parking capacity, in accordance with the best estimate of lost space when the project was finalized. In addition, an imbalance between the capacities of the Albion and Wildcat parking areas has developed. The Albion parking lot has become the lot of choice for intermediate skiers and for summer visitors. Most days the Albion lot fills and skiers’ cars then overflow into the Snowpine lot, resulting in a long walk with a hill to get to and from the ticket office and lift terminals. Increasing use of these lots by backcountry skiers bound for Grizzly Gulch or Cardiff Pass exacerbates the problem. This project would address this imbalance by consolidating replacement of parking lost to transit into the Albion and Snowpine lots.

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Figure 2-1. Overview of the proposed action. 15

Environmental Assessment: Alta Master Development Plan Improvement Projects

Figure 2-2. Proposed redesign plan area for Albion base parking lot.

Finally, the roadway to the Albion lot from the Snowpine lot is steep and narrow, and it can be slick and difficult for kids or those carrying equipment. This poses safety issues by mixing pedestrian and vehicle traffic and creates an undesirable skier experience. Slip-and-fall accidents have occurred. This project would provide easier and safer access in two ways. First, it would regrade the transitions area between the lots to reduce steepness. Second, it would allow space for a bench along the lower edge of the parking lots and transition area that could readily be covered with snow – either natural snow or snow plowed from the road and parking lot –providing visitors a safe area to put on their equipment and ski down to the ticket office and lifts rather than walking along the road.

2.4.2 AVALANCHE CONTROL Alta has traditionally used conventional avalanche control methods in areas accessible via ski patrol routes and military artillery or Avalaunchers in inaccessible areas. Consistent with the ski industry’s efforts to reduce use of military weapons where feasible, and to prepare for unanticipated loss of either military weapons or Avalaunchers, the Forest Service proposes to authorize the following alternative approaches to avalanche control.

2.4.2.1 Tram from Germania Pass to the top of Mt. Baldy Project Description: Install a small (roughly 150 p/h) tram from Germania Pass to a point 90 vertical feet and 340 horizontal feet below the top of Mt. Baldy, above the Perla’s area (Figure 2-3) on the north face of the peak. The site is a sheltered pocket, below both the main ridge and the sub-ridge to the east. The lift would be approximately 1,900 feet long and require top and bottom terminals. No intermediate lift towers would be needed. The bottom terminal and one third of the tram line would be on NFS land, with the remainder of the alignment and upper terminal on Alta’s private land.

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Figure 2-3. Proposed new tram from Germania Pass to the top of Mt. Baldy.

The terminal would be a simple structure, basically a bull wheel and landing platform with associated rigging, similar to the Allen Peak tram at Snowbasin. There would be no building associated with the terminal, and the materials would be concrete and steel. Galvanizing is standard practice at Alta, so the structure would blend with the natural setting. The Baldy tram would be bottom driven, and power would not likely be needed at the upper terminal. An access road approximately 50 feet long and 20 feet wide would be constructed from the existing summer road to the location of the lower terminal. Power for the Baldy tram would be provided by a trenched line running from the top terminal of Collins lift to the lower tram terminal. The trench would be excavated in the running surface or shoulder of the existing Collin’s lift access road, westward down the summer road, and then up the new Baldy tram access road. There would be no access road to the top terminal. All construction materials for the top terminal would be delivered by helicopter, and any earth work would be performed using hand tools. This area of control on the north face is different than the East Baldy Remote Avalanche Mitigation Project, a cumulative action described in section 3.3. That project would install Obell’X or Gazex avalanche control devices on the east face of Mt. Baldy above the East Baldy Traverse. The Peruvian Ridge gun and building would remain in place as the building belongs to the Utah Department of Transportation and the gun is used to control side paths across the canyon that threaten SR 210. Project Rationale: Avalanche control on Mt. Baldy is necessary for Alta to provide skiing not only in the Baldy Chutes but also on Main Street, the Ballroom area, and the Baldy Shoulder area, all of which are popular terrain. There are 23 avalanche-starting zones on the north face of Baldy, and they are currently controlled using a 105mm Howitzer and two Avalaunchers to deliver explosive charges. Both of these

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technologies generate safety and other concerns that are driving an industry-wide shift to alternative technologies. Beyond that, the explosive projectiles penetrate deep into the snowpack, where the explosions are less effective in releasing unstable snowpacks and the potential for damage to soil, vegetation, and habitat is high. Several alternative technologies were assessed as replacements (see section 2.6), including Gazex or similar remotely controlled equipment and helicopter bombing. The other alternative is a lift to transport ski patrollers to a location high enough on Mt. Baldy to allow avalanche control using hand charges, ski cutting, and skier compaction. Three alignments were considered. The proposed lift was identified as the best alternative – in terms of both function and environmental impact – to maintaining the avalanche control necessary to keep key ski terrain on the north side of Mt. Baldy open for safe, public recreation. Hand charges are triggered above or at the snowpack surface, making them more effective at releasing instabilities and less damaging to resources under the snow. The lift could also be used for skier access to the chutes below the tram or to the east and west Baldy areas when conditions allowed, increasing the stabilizing effect of skier compaction. Replacing artillery and Avalaunchers with ski patrol control routes would result in more effective avalanche control and more days when Mt. Baldy and the terrain below were open to the public. The number of explosive charges used would increase, but the net amount of explosives probably would not, due to the smaller size of hand charges (i.e., 2 pounds vs. roughly 10 pounds for a howitzer round).

2.4.2.2 Gazex or Other Equivalent Technologies to Reduce Artillery and Avalauncher Dependency Project Description: Reduce dependency on the use of artillery, Avalaunchers, and helicopter bombing with modernized avalanche control methods such as Gazex or other equivalent avalanche control technologies on Sugarloaf Mountain, East Devil’s Castle (Figure 2-4), and Patsey Marley (Figure 2-5). If current technology Gazex exploders were used, all three locations would have four to eight exploders. An 8-foot-by-8-foot gas storage unit would be needed for every four exploders. Gas lines connecting each exploder to the storage unit would be buried in shallow, hand-excavated trenches. All installations would be on NFS land within Alta’s current permit boundary. Note that the Sugarloaf Mountain installation may entail gas lines crossing a private parcel. If an agreement allowing this were not reached with the landowner, a similar alternative technology such as Obell’X would be used. Project Rationale: Avalanche paths on Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley are now controlled with Avalaunchers or with helicopter-deployed explosives. Changing to Gazex or other equivalent technologies could allow for safer, unmanned, avalanche control. These technologies would allow Alta to minimize the use of three Avalaunchers, hopefully minimizing dependency on explosives and rental helicopter services.

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Figure 2-4. East Devil’s Castle and Sugarloaf Mountain with proposed Gazex locations.

Figure 2-5. Patsey Marley with proposed Gazex locations.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

2.4.3 REPLACEMENT OF LIFTS Alta is an original ski area in the Central Wasatch, and as its lift systems age it can affect the level of service they provide, their reliability, and their repair costs. The Forest Service proposes to authorize the replacement of existing lifts as described below. Detachable lift technology has proven to be an effective tool for adjusting skier distribution by varying lift capacity to match conditions and thus providing a desirable skier experience. For example, lift speeds can be slowed when skier density is too high, thus alleviating crowding in the terrain served by a given lift. As Alta replaces lifts or builds new lifts, they design and operate lift systems with a range of capacities to accommodate demand and provide redundancy. Reflecting these considerations, the figures provided below represent design capacity for replacement lifts and generally overestimate the capacities at which they would normally be operated.

2.4.3.1 Sunnyside Lift Replacement Project Description: Replace the existing Sunnyside lift with a chondola (i.e., a mix of chairs and gondola or cabriolet cabins), gondola, or detachable chair, using the current lift alignment and upper and lower terminal locations (Figure 2-6). Many of the existing towers and tower foundations would be used for the new lift, though some new ones may be required. New towers and cement for the foundations would be flown on site by helicopter, and any new foundations would be excavated by hand crews or spider hoe. As a result, no new tower access roads would be constructed. Old towers would be removed by helicopter, and foundations that were not used would be shortened to 2 feet below the ground surface then covered with soil and revegetated. The determination of which towers would be reused would be made when the lift was designed.

Figure 2-6. Existing Albion and Sunnyside lifts with proposed replacement of Sunnyside lift.

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The alignment of the new Sunnyside lift would be approximately 40-feet wide, following the existing Sunnyside alignment. Due to the clumped distribution of forest stands at Alta, minimal tree clearing would be needed to widen and maintain portions of the new alignment. The alignment is entirely on NFS land. The chondola option would allow cabins and chairs to be used on the same lift line. It would allow flexibility as rider demand, weather conditions, and seasons change. To accommodate different types of users, the chondola would use different loading stations which would resemble a gondola station followed by a chairlift station, or vice versa. Typically, there are more chairs than cabins on a chondola. This type of lift allows for greater versatility throughout the year, and in particular, improves opportunities for summertime guests. Project Rationale: The Sunnyside lift is a detachable triple chair lift that often cannot meet the demand on busy days. A new lift with 2,400-person-per-hour (pph) capacity would meet demand and the expectations of today’s skier market. The new lift would accommodate summer users, beginning skiers, and skiers accessing all upper-mountain lifts. The capability for summer use would provide an option to shuttle buses as a means of reducing vehicle traffic in Albion Basin.

2.4.3.2 Wildcat Lift Replacement Project Description: Replace the Wildcat lift, a fixed-grip double (1,200 pph), with either a fixed-grip or a detachable quad lift (estimated design capacity up to 2,400 pph), using the same top and bottom terminal sites and lift alignment (Figure 2-7). The new lift would be able to reuse some of the existing towers and tower foundations, though new towers and foundations would also be needed. No access roads would be constructed; rather new towers and cement for the foundations would be flown on site, and foundations would be excavated by hand crews or spider hoe. Old towers would also be removed over the snow or flown off site by helicopter, and the foundations would be shortened to 2 feet below the ground surface then covered and revegetated. Though the alignment of a quad lift is wider than that of a double (40 feet vs. 30 feet), only minimal clearing would be necessary because the existing alignment is generally 50- to 70- feet wide in forest stands, with the exception of a few trees. The alignment lies entirely on NFS land. Project Rationale: Wildcat lift is a 33-year-old lift with diminishing parts availability. While reliability and comfort are more important issues than capacity, replacing Wildcat with a higher-capacity lift would provide lift redundancy, allowing Alta to increase Wildcat lift’s operating speed if Collins lift were non- operational or if much of Collins terrain were closed due to avalanche conditions. The two lift pods overlap considerably, so a higher-capacity Wildcat lift could serve as a back-up to Collins as well as making the Wildcat area more attractive to skiers.

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Figure 2-7. Existing Wildcat lift with proposed lift replacement.

2.4.4 NEW LIFT In addition to replacing aged, existing lifts, the Forest Service proposes to authorize the following new lift to make more efficient use of ski terrain within the current ski area boundary.

2.4.4.1 Flora Lift Construction from the Bottom of Sugarbowl to the Top of Collins Lift Project Description: Install a new, roughly 1,200 pph, fixed-grip, top-driven, double chairlift from the flats north of the bottom of Sugarbowl to a point approximately 100 yards north of the ski patrol dispatch building at the top of Collins lift (Figure 2-8). The lift would be approximately 985 feet long and require about four towers in addition to the top and bottom terminals. The upper terminal would be constructed on the east shoulder of the ridge near a topographic saddle and would require some flattening and filling for skier unloading. The lower terminal site would not require contouring outside of the disturbance footprint, and the existing terrain is suitable for the loading maze. The disturbance footprint for both terminals of this smaller fixed-grip lift would be approximately 110 feet long and 75 feet wide. As discussed above for the replacement lifts, the four towers and the cement needed for the foundations would be flown on site by helicopter. The foundations would be excavated by hand crews or spider hoe, and no new access roads would be constructed for the towers. However, an access road approximately 290 feet long and 20 feet wide would be constructed from near the top of the Mambo run to the upper lift terminal. Temporary impacts may occur in an additional 20-foot-wide buffer upslope and downslope from the access road as shown in Figure 2-8. This access road would require some earthwork on the west shoulder of the ridge up to and crossing the topographic saddle, but would largely leave the ridgeline

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intact. Power would be provided from the top terminal of the Collins lift, and would be installed in a trench along the new access road. The new lift would lie entirely on NFS land. Project Rationale: Maintaining the East Baldy Traverse between the top of Sugarloaf lift and the top of Collins lift is a drain on snowcat and avalanche control resources. Rapidly building avalanche hazard due to wind often causes Alta to close the East Baldy Traverse. The closure creates a poor skier experience and disrupts the skier balance by forcing traffic from Sugarloaf that would have gone across the East Baldy Traverse and into Collin’s Gulch onto Devil’s Elbow, which increases skier density on Devil’s Elbow. Even when the East Baldy Traverse is open, the experience for skiers is, more often than not, unpleasant because of wind and blowing snow. Additionally, when Mt. Baldy is open for skiing, the East Baldy Traverse cuts across the lower end of an expert ski run. This lift would allow traffic to consistently flow both ways between Collins Gulch and upper Albion Basin without using the traverse.

Figure 2-8. Proposed new Flora Lift from the bottom of Sugarbowl on Sugarloaf to the top of Collins lift.

2.4.5 SKI RUN WORK As lift systems evolve and patterns of skier use change, a ski area’s run system must be modified to avoid congestion and provide for smooth skier circulation. The Forest Service is proposing to authorize the following run improvement projects.

2.4.5.1 Supreme Summer Ski Run Work Project Description: Two projects exist to create a groomed run from the top of the Supreme lift. The first is to widen and improve the grade on the existing Devil’s Castle Road and tie that in with Lower Rock

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and Roll run (Figure 2-9). This involves cutting trees and excavating the inside bank of the road to improve the width and pitch to become a dual purpose road/ski run. The second project is to begin at the top of Challenger Run and proceed to the skiers left to the Erosion Gullies run, then connect to the Sleepy Hollow run. Some vegetation would be cleared, and two of the four gullies would be re-contoured using fill material imported from the Big Dipper run. Minor vegetation clearing and slope re-contouring would also be needed on the lower segment of Big Dipper to complete the run. Project Rationale: Both projects would create summer groomed runs (a long-term alternative to snowmaking) that would easily open on a normal snow year and provide an intermediate ski option. The second project would provide more of a buffer away from the Devil’s Castle area, and keep skiers further from avalanche run-out zones. It would also repair two of the four erosion gullies. These gullies are steep, deeply rutted relics from early mining, timber removal, and sheep grazing activities.

Figure 2-9. Proposed Supreme summer run work.

2.4.6 BUILDINGS Provision of skier services at dispersed locations continues to be an important aspect of meeting the demands of today’s skier market. The Forest Service proposes to authorize the following upgrades of existing on-mountain facilities and an additional new facility.

2.4.6.1 Alf’s Restaurant Building Addition Project Description: Construct an approximately 2,000-square-foot building addition with a 550-square- foot deck on the south end of the Alf’s restaurant, providing space for additional food-service seating and relocation of the stand-alone Ski Demo Center into the main building (Figure 2-10). The small container building currently housing the demo center would be removed. A second story over a portion of the

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Environmental Assessment: Alta Master Development Plan Improvement Projects

existing building may be added to meet the space requirement. The building addition would lie entirely on NFS land. A 50-foot buffer from the drainage channel to the south would be maintained. Project Rationale: Alf’s restaurant is Alta’s oldest mid-mountain restaurant and was not designed to have a ski shop and demo center. Currently, circulation around the south end of Alf’s functions poorly, in part because of the temporary building housing the ski demo center, a crowded entrance, and a building footprint that makes snow plowing and grading difficult. The small ski shop inside Alf’s has proven very popular in providing basic skier needs for Sugarloaf, Sunnyside, and Supreme skiers. That shop has displaced six tables from the cafeteria seating that could be regained with the additional space. Experience also shows that the facility should have a straighter building line on the southeast facing entrance. Nightly snowcat grooming of the area has proven difficult in maintaining a good ingress/egress height and ski rack area. The proposed improvements would allow for the addition of extra cafeteria tables to help meet the demand for food-service seating and ski shop space. Removal of the container building would improve access, maintenance of the skier entrance, and the aesthetics of the area.

Figure 2-10. Existing Alf’s restaurant building with proposed addition.

2.4.6.2 Watson Shelter Building Addition Project Description: Construct a small 550-square-foot addition under the existing structure’s deck and a 1,000-square-foot expansion on the west side of the building between the lower and upper entrances (Figure 2-11). The space under the expansion would be enclosed. The building addition would lie entirely on NFS land.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Project Rationale: Overall storage needs at Watson Shelter have increased. Skier demand for retail and drinks on the lower level has grown to a point that the addition is needed. Half of the space would provide storage and half would be used for skier seating in the coffee shop and skier flow area in the retail shop. Additionally, the top of the addition could provide additional deck space for the cafeteria. The deck space on the north and east side of the building was originally designed to use for customer seating. However, tables placed on the deck in those locations are rarely used by guests since they are typically in the shade. Expanding the deck off the southwest corner of the building would increase seating on the warmer, sunnier side of the building.

Figure 2-11. Existing Watson Shelter building with proposed addition area.

2.4.6.3 Equipment Storage Facility Construction Project Description: Construct a single-story 6,000-square-foot storage facility to the northwest of the existing vehicle maintenance building along the northern edge of the Albion Base parking lot (Figure 2- 12). The building would be built on NFS land. Project Rationale: Seasonal storage needs have exceeded Alta’s current on-mountain and off-site facilities. Much of the ski area equipment and emergency repair parts are currently stored in a warehouse in west Salt Lake Valley. SR 210 road conditions, transportation costs, and vehicle emissions associated with maintaining a warehouse an hour away make an on-site storage facility the most feasible way to increase storage capacity.

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Figure 2-12. Proposed equipment storage facility building.

2.5 DESIGN CRITERIA Design criteria are measures to avoid or reduce adverse environmental effects that are identified prior to NEPA review. This analysis incorporates a number of design criteria developed on the basis of experience at Alta and other ski areas in the region. Reducing soil erosion and adverse effects on water quality, protecting forest and other native vegetation, maintaining visual quality, ensuring appropriate access to facilities, and protecting heritage resources are the concerns addressed by the following design criteria. They were considered to be in place in analysis of environmental consequences discussed in Chapter 3, which identifies additional project-specific mitigation measures beyond these design criteria (see Appendix A). Implementation of design criteria and mitigation measures may be considered a condition of approval in a UWCNF decision to authorize the proposed action, all or in part. Erosion Control

1. Prior to construction, Alta will prepare a Storm Water Pollution Prevention Plan (SWPPP) that will apply to all authorized projects. The SWPPP is a condition of the Utah Pollutant Discharge Elimination System General Permit and will include appropriate BMPs for erosion control, sediment control, site stabilization, operational controls, and provisions for maintenance and inspection. The UWCNF may request review of SWPPPs. 2. The SWPPP will include appropriate BMPs from National Best Management Practices for Water-Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide (Forest Service 2012a). Pertinent watershed BMPs are listed in Appendix A.

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Vegetation Management

3. Soil disturbance will be minimized, and existing topsoil will be conserved for replacement. 4. Where possible, native vegetation will be retained. 5. In cleared and graded areas, mechanized equipment may be used to fell and remove trees. When possible, trees will be removed over snow to protect the ground surface. Disposal will be in accordance with applicable Forest Service permit requirements. 6. Slash created by tree removal will be disposed of either through utilization, burning, chipping, mastication, lopping and scattering, or removal from the site within a specified timeframe. Disposal will be in accordance with applicable Forest Service and state permit requirements. 7. Alta will follow Forest Service policy (FSM 2070) and use genetically appropriate native materials for rehabilitation and restoration. A qualified Forest Service botanist will be involved in development, review, and/or approval of plant materials selected for use in site rehabilitation and restoration. 8. Any areas of native vegetation that would be disturbed and have not been previously surveyed for special-status plants will be surveyed prior to construction. Results will be reported to the Forest Service permit administrator, and appropriate measures to mitigate impacts will be implemented. 9. All construction equipment and vehicles used will be cleaned and certified free of noxious weeds and their seeds prior to entrance onto the UWCNF. This restriction will include equipment and vehicles intended for both on- and off-road use, whether they are owned, leased, or borrowed by either contractors or subcontractors. 10. Any fill material proposed for the project, including any topsoil, will come from an on-site or in- canyon location. 11. Any straw bales, chips, or other imported mulch used in conjunction with the proposed action will come from a certified weed-free source. Wildlife Protection

12. Construction and refueling helicopters operating during the nesting season (April–June) must approach, and depart, cliff areas from behind and above the cliffs to avoid flushing nesting falcons. 13. Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no more than 10 days prior to commencing work. If no nests are found, project activities may proceed. If nests are found, contact the Forest Service permit administrator. Scenic Integrity

14. Permanent structures will be designed and built in compliance with the Built Environment Image Guide for the National Forests and Grasslands (Forest Service 2001, FS-710). Ensuring that architectural style, building materials, size, and color are consistent and meet the adopted scenery objectives. Compliance will be confirmed through Forest Service engineering review prior to construction. 15. The edges of cleared ski runs will be feathered to appear more like natural openings in forest cover, flowing with the topography and blending with the natural vegetation. Accessibility

16. All buildings will be designed and constructed in accordance with the Accessibility Guidebook for Ski Areas Operating on Public Lands – 2012 Update (Forest Service 2012b). Compliance will be confirmed through Forest Service engineering review prior to construction.

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Undiscovered Heritage Resources

17. If any previously unidentified prehistoric or historic cultural resources are identified or encountered at any time during construction, efforts shall be made to protect the resource(s) until the Forest Service Permit Administrator is notified and the Forest Service fulfills its consultation requirements, including consultation with the appropriate Tribal representatives. 18. If unmarked human remains are encountered at any time during construction, all work in the vicinity of the find shall cease, with the remains covered and protected in place, and the Forest Service permit administrator notified immediately to begin proper notification and consultation procedures with the Utah State Historic Preservation Office, Native American Tribes, and other local officials as needed (e.g., county coroner) to determine to what time period and ethnic group the skeletal material may be ascribed and the appropriate treatment. 19. If any previously unidentified Traditional Cultural Places or sacred sites are identified or encountered at any time during construction, efforts shall be made to protect the resource until the Forest Service permit administrator is notified and the Forest Service fulfills its consultation requirements, including consultation with the appropriate Tribal representatives. Wetland Resources

20. Placement of lift towers in wetland areas will be avoided, the amount of wetland area disturbed will be avoided and minimized. Disturbances will be mitigated when avoidance is not practical. 21. Trench breakers will be used when snowmaking or other utility lines cross sloped wetland areas. Trench breakers will be placed at the lower wetland boundary so that groundwater is not drained through the trench and out of the wetland. 22. Any tree removal from wetlands will be done either over the snow or after the ground has frozen to protect soil resources. 23. When constructing buildings and lift terminals, equipment will not operate in adjacent wetlands and stream channels. 2.6 ALTERNATIVES CONSIDERED BUT NOT CARRIED INTO IN-DEPTH ANALYSIS Several alternatives were considered in development of the proposed action or raised in scoping comments. However, the alternatives were limited to single elements of the proposed action. No comments were raised that suggested a separate unique, alternative. The following paragraphs discuss each suggested single-element alternative and explain why it was not carried into in-depth analysis.

2.6.1 BALDY TRAM ALTERNATIVES Most alternatives considered involved the proposed Baldy tram. Several technologies other than a lift providing ski patrol access for conventional avalanche control were considered but not carried into in- depth analysis. These included:  Continued use of the Howitzer and Avalaunchers, but this would perpetuate safety concerns including over-shoots, dud rounds, and premature detonations. Since these methods can only be used when Alta and Snowbird are closed to the public, relying on them would result in continued terrain closures during storm and wind cycles. Alternative technologies would reduce closures.  Helicopter bombing, but this technology requires clear, calm weather, which is not the norm when avalanche control action is needed.

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 Obell’X, Gazex, or similar remotely controlled installations such as those currently proposed for other locations at Alta (i.e., East Baldy, Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley – see section 2.4.2.2). However, based on the number and spatial extent of starting zones on the north face of Mt. Baldy, it would take an estimated 23 Gazex installations to control the area – an area heavily used by skiers. This concentration of installations would disturb a substantial proportion of the area’s alpine habitat during construction and would permanently degrade its scenic character.  Completing avalanche work on Mt. Baldy from the Snowbird side of the mountain, but this option would not eliminate the need for an extended hike through avalanche-prone terrain for ski patrollers to access the starting zones. This option would also require that Snowbird’s tram be operational, which is dependent on weather on Hidden Peak and other Snowbird operational considerations beyond Alta’s control. Once a lift was identified as the best alternative, three lift alignment options were considered. Two were on Alta’s private land – one from the bottom of Sugarbowl and the other from the Wildcat area. Neither of these would require Forest Service authorization. However, both would end on or near the peak of Mt. Baldy. This location would not only be visible from all directions but would also be subject to high winds that would frequently make the lift inoperable. These alignments would also require intermediate lift towers, increasing both their ground disturbance and their visual impact. The proposed alignment was the third alignment option. As noted above, it would start on NFS land near Germania Pass and end on private land at the top of Alta Chutes, in a sheltered pocket well below the summit. This alignment would provide the needed ski patrol access while dramatically reducing the area from which the lift and top terminal were visible, and it would shield the terminal from the peak’s high winds, allowing more reliable operations. The lift would be a single, unsupported span with no towers between the terminals, reducing construction impacts. This option was identified as the only feasible alternative to effectively maintain avalanche control operations on the north face of Mt. Baldy in a safe and environmentally sound manner. This analysis addresses its potential environmental effects. One commenter suggested that a lift from Gold Miner’s to top of Eagle’s Nest should be constructed instead of the Baldy tram. The suggested lift would not meet the purpose and need to address avalanche control on Mt. Baldy and thus was not carried into in-depth analysis.

2.6.2 FLORA LIFT ALTERNATIVES To accomplish the purpose of replacing East Baldy Traverse as the way for upper mountain for skiers to get from the Albion side of the ski area to the Wildcat side, this lift faced complex and, in some cases, conflicting design considerations. The bottom terminal must be readily and safely accessible to skiers leaving the top of Sugarloaf lift and coming down Little Dipper, the easier way down, or Sugarbowl, the more advanced route. The terminal and routes to it also must not impede skier flow from the top of Collins lift to Sugarloaf lift via Devil’s Way or the cat track. Those imperatives leave little leeway in siting the terminal. To the north and west, the terrain slopes upward. To the south, the topography becomes steep and broken up by forest patches, rocky outcrops, and incised channels. Steep, forested slopes rise immediately east. The low-lying portions between these steep or off-pitch areas that would accommodate the purpose of this lift support wetlands. Considering skier-circulation issues in conjunction with these natural limitations further complicates terminal siting. The location should allow skiers from Sugarloaf lift to access the site in a natural flow that provides adequate pitch to reach the new terminal at a safe and comfortable speed. It should also provide sufficient visibility of other Sugarloaf-lift skiers who are not accessing the Flora lift and Collins- lift skiers who are crossing to Sugarloaf. Forested rock outcrops separate Sugarbowl and Gravy Boat from Little Dipper, and Little Dipper from the cat track, blocking views of crossing skier traffic. Skiers

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continuing down Sugarloaf are often carrying speed out of Sugarbowl, or trying to maintain speed on Little Dipper, to carry over the rise under the Sugarloaf lift line. The proposed site is down in the open basin, allowing sufficient space, lower gradients, and long enough sight lines to safely accommodate this changing circulation pattern. One alternative location, on the lower end of a rock outcrop about 200 feet west of the proposed site, was seriously considered because it met some of the physical criteria and was an upland site. However, this site would require skiers on Sugarbowl to cross skier traffic on Little Dipper at almost a 90 degree angle and with limited visibility. Then skiers from both Sugarbowl and Little Dipper would have to cross the cat track, again with limited visibility, at high enough speed to carry them to the elevated location. This site would avoid wetland impacts, but it would not provide the necessary visibility or sufficient outrun space to reduce the speed of skiers. Based on these considerations, the best location for the bottom terminal in terms of traffic flow and skier safety is at the open, low point in the bowl, which contains wetlands. All alternative locations would either require skiers to climb – not practical for downhill skiers – or mix skier traffic in unsafe ways, or involve construction on steep, rock slopes where disturbance would be far greater. As a result, no alternative locations were carried into in-depth analysis, and this EA thoroughly addresses and discloses the wetland impacts of the proposed terminal site.

2.6.3 GAZEX INSTALLATION ALTERNATIVES Regarding the proposed avalanche-control installations on East Baldy, Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley (section 2.4.2.2), a commenter suggested Obell’X instead of Gazex installations to reduce visual impacts in the summer. Obell’X installations are removed during the snow- free season, leaving only mounting pedestals. However, these systems are better suited to smaller starting zones and are a less developed technology than Gazex. Potential impacts on visual resources due to the use of Gazex are addressed in this analysis. 2.7 SUMMARY AND COMPARISON OF ENVIRONMENTAL EFFECTS Table 2-1 summarizes and compares the direct and indirect environmental effects of the proposed action and alternatives.

Table 2-1. Summary and comparison of environmental effects. Issue No-Action Alternative Proposed Action Soil, Water, and Watershed Resources: How would the proposed No change from current The proposed action would result in temporary infrastructural development situation. Soil productivity is loss of soil productivity from compaction due to affect soils, erosion, limited by about 46 acres of construction of access roads to terminals for the sedimentation, water quality, impermeable surfaces. Baldy tram and Flora lift, affecting about 0.8 and overall watershed Established design criteria and acres. There would be a permanent productivity function? BMPs effectively minimize loss on about 2.5 acres due to paving the expanded erosion and sedimentation in the Albion parking lot and building footprints. Total watershed. impact would be about 3.3 acres, an increase of 6.7%. About 18.9 acres of soil disturbance through grading and excavation would occur. The risk of erosion and sediment delivery to streams would be reduced by implementation of identified BMPs.

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Table 2-1 (cont’d). Summary and comparison of environmental effects. Issue No-Action Alternative Proposed Action Could potential leaks and No change. The Spill Prevention The existing SPCC plan would remain in place to spills of fuels and other Control and Countermeasure identify, isolate, and remove any environmental chemicals impact water (SPCC) currently in place contamination as quickly as possible. All above- quality? minimizes the risk of fuel or ground and below-ground storage tanks would other chemical contamination. continue to be inspected as required by state and federal regulations. How would the proposed No change. Approximately 42 About 0.23 acres of direct wetland impacts subject infrastructure affect wetlands acres of wetland and riparian to COE and other permitting requirements would and riparian areas? areas, and 468 acres of Riparian occur; no net loss. About 675 feet of intermittent Habitat Conservation Areas stream crossings, 506 feet of perennial stream (RHCA), are generally crossings and disturbance of about 5.34 acres of functioning in accordance with RHCA would be consistent with management management objectives. objectives following implementation of identified BMPs. Vegetation: How would the proposed No habitat for federally listed or The proposed action would have no effect on Utah infrastructure affect special- candidate species exists in the angelica, Brownie lady’s slipper, Wasatch status plant species? project area, and field surveys shooting star, slender moonwort, Wasatch fitweed, did not detect any. Potential Wasatch draba, Burke’s draba, rockcress draba, habitat for 14 Forest Service Garrett’s fleabane, Utah ivesia, Wasatch jamesia, sensitive species and three watch Wasatch pepperwort, Garrett’s bladderpod, list species occurs in the project Barneby’s wood aster, tower rockcress, sand area, and Burke’s draba has been fleabane, or broadleaf beardtongue individuals, documented. Ongoing populations, or habitat. The proposed action is not recreational use may impact both likely to cause a trend toward federal listing or a individuals and potential habitat loss of viability of these Forest Service sensitive of these species. The potential species. for that impact would be unchanged from current conditions. How would the Baldy tram, The alpine ecosystem on Mt. Construction, maintenance, and operation of the in conjunction with climate Baldy would continue to Baldy tram would directly affect the alpine change, affect the alpine experience winter and summer ecosystem on Mt. Baldy only within the ecosystem on Mt. Baldy? recreation use. Winter use would disturbance footprint of the upper tram terminal. continue to occur over a layer of Indirect effects would be limited since tram snow and would not impact the operation would occur on the north side of the vegetation component of the summit where the snowpack is less affected by alpine ecosystem. The impact of wind scour and sunlight, and during winter months summer use would not change when plants were dormant and snow covered, and from the existing pattern – wildlife were not active on the surface. concentrated along the trails and dispersed off of the trails. How would the proposed The ongoing operations would Two of the proposed projects overlay known infrastructure affect noxious not increase the risk of noxious infestations of two noxious weeds that are present and non-native invasive plant and non-native invasive species in trace amounts, and account for less than 1 species? becoming established or percent of ground cover. No other infestations of spreading. Monitoring and noxious weeds occur in the proposed action treating past ground disturbances disturbance footprint. for noxious and non-native A number of the projects overlay known

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 2-1 (cont’d). Summary and comparison of environmental effects. Issue No-Action Alternative Proposed Action invasive plant species would infestations of Kentucky bluegrass, smooth brome, continue. Existing infestations yellow sweet clover, and wand mullein, all of would be expected to decrease. which are non-native invasive plants. Some were included in past revegetation and erosion control seed mixes. Monitoring and treating past ground disturbances for noxious and non-native invasive plant species would continue. Existing infestations would be expected to decrease. Wildlife: How would the proposed No threatened or endangered The proposed action would have a very slight infrastructural development species occur in the project area, detrimental impact on three-toed woodpecker, affect special-status terrestrial but seven Forest Service flammulated owl, boreal toad, and northern and aquatic wildlife species sensitive species and a number goshawk due to habitat loss. It would not affect the and other species of interest of migratory birds have been peregrine falcon, spotted bat, Townsend’s western or concern? documented. Past ski area big-eared bat, or Bonneville cutthroat trout. operations have shaped the wildlife community that exists in the project area and the habitat for special-status species. Not implementing the proposed action would have no impacts on any special-status species as proposed action does not address any current problems with populations of these species. Cultural Resources: How would the proposed No Native American concerns No Native American concerns were identified infrastructure affect Cultural have been identified at Alta through consultation on this proposed action, and Concerns, Traditional through past consultation, so no design criteria include measures to protect any Cultural Places (TCPs), or impacts are anticipated. cultural resources discovered during construction. Native American Sacred No impacts are anticipated. Sites? How would the proposed Past review of projects indicated One proposed element, expansion of the Albion infrastructure affect any either no historic properties parking lot, would affect the historic Alta historic properties? present or no adverse effects. Townsite. However, the affect would be covering a portion of the site with fill material, effectively protecting any artifacts that might exist. How would the proposed While the ski area is one of the The proposed action would not further alter the ski infrastructure affect the country’s oldest, its historic area’s historic integrity. historic integrity of the ski integrity is low due to removal area? or replacement of original infrastructure.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 2-1 (cont’d). Summary and comparison of environmental effects. Issue No-Action Alternative Proposed Action Scenic Resources: How would the proposed Not implementing the proposed Generally, implementation of the proposed action infrastructure affect the action would have some minor would affect the area’s landscape character in scenic integrity of the project adverse effects on landscape ways similar to the ski area development that has area? character at Alta. Overall, the occurred over the past 78 years. Some projects Resort Natural Setting landscape would maintain the more natural aspects of the character would remain largely landscape character. Some would have negligible intact, with visible deviations visual effects, and some would increase the built due to the variety of architectural aspect of the landscape character. styles dating back to the 1950s Overall, the proposed action is consistent with the and the rectangular, undivided Resort Natural Setting. It would not alter either the Wildcat parking lot. Scenic architectural variety at the ski area or the visual integrity would continue to be impact of the Wildcat parking lot, so the Resort managed for a High SIO as a Natural Setting landscape character would remain desired condition. reasonably intact, and scenic integrity would continue to be managed for a High SIO as a desired condition. Recreation: How would the proposed Under this alternative, lift Lift upgrades and additions would make skier infrastructural development capacities and skier densities dispersal more efficient, leading to more uniform affect skier density and remain unchanged. As older lifts use of available terrain. While skier densities could circulation? become less reliable, down time increase somewhat in localized areas, the overall will likely increase. As a result, effect would be more efficient management of skiers will either wait longer in skier density. Alta would continue to adjust lift line for stopped lifts or move to operating speeds to balance uphill with downhill other lifts, increasing density in capacity. those alternative pods. Installation of Baldy tram may decrease the Mt. Baldy access continues to attraction of that terrain to those seeking more involve hiking, limiting use and isolation and adventure. preserving that aspect of the Circulation space on Germania pass is limited, but experience. two facts mitigate the potential constraint posed by Skiers coming to Germania Pass the Baldy tram lift maze: the tram will often not be from the Albion side continue to open to public use, so no maze will normally be use East Baldy Traverse, necessary, and with a capacity of 150 pph, the lift merging head-on with skiers will not require a large maze when it is open to the getting off the Collins lift and public. creating congestion on the pass. Flora lift should improve skier circulation on the pass: the terminal would be out of the way; skiers wishing to move from Sugarloaf pod to the Wildcat side would cross the pass in any case; and skiers unloading from the Flora lift would merge with skiers getting off Collins lift rather than approaching from the opposite direction as is the case with skiers coming off East Baldy Traverse. Safety: Does lift access to Mt. Baldy Safety issues on Mt. Baldy With even limited lift access, public use of the pose a safety risk? would not change. The lack of inherently dangerous Baldy Chutes would efficient ski patrol access to the increase. This is a safety management issue with

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 2-1 (cont’d). Summary and comparison of environmental effects. Issue No-Action Alternative Proposed Action top continues to slow avalanche which Alta has decades of experience. Skier control operations necessary to education, closures, rope lines, and signage have open Baldy Chutes and the rest all been incorporated into an effective risk- of the mountain. Once control management system at Alta, and lift access to Mt. work was done, skier safety Baldy would not be a qualitative change in the depends on skier education, rope demands on that system. lines, and signage. Skiers Overall, the increase in injury risk posed by the capable of hiking up Mt. Baldy Baldy tram would be minor and manageable, and continue to face the inherent risk it would be offset by the greater speed and associate with that type of efficiency of avalanche control operations made terrain. possible by the tram. Would sympathetic avalanche Avalanche-control activities on The Gazex installations would function in much releases from proposed Patsey Marley and the effect the same way as the Avalaunchers and helicopter- Patsey Marley Gazex they have on the safety of delivered explosives currently in use; all of these installations pose a safety risk Wolverine Cirque skiers will methods deliver similar amounts of tightly focused for backcountry skiers in remain unchanged. Alta explosive energy to the snow surface in defined Wolverine Cirque? continues to use explosives avalanche starting zones. As a result, the new, delivered by Avalaunchers or higher-tech systems should not differ in their helicopters. Given the distance potential effects on snow stability in the cirque. from Patsey Marley starting If either the current or proposed avalanche control zones to those in the cirque, the methods on Patsey Marley were to trigger a release intervening ridge, and the nature in the cirque, it would be under conditions of of the explosives use, impact on extreme instability when skier use of the cirque Wolverine Cirque from Patsey was highly unlikely. Marley avalanche control is Based on these considerations, the proposed Gazex minimal. installations on Patsey Marley would pose no increased risk to backcountry skiers in Wolverine Cirque.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 3.1 INTRODUCTION This chapter describes the existing resource conditions and the direct, indirect, and cumulative environmental effects of implementing the proposed action and no-action alternative. Discussion is organized by resource and addresses the specific issues associated with each resource identified through public scoping and internal, interdisciplinary review (see section 1.8, Scoping and Identification of Issues). 3.2 DISTURBANCE TYPES AND AREAS Table 3-1 provides the basic dimensions of disturbance associated with various projects. These dimensions were used in calculating the project-specific disturbance areas shown in consecutive tables. Table 3-2 shows disturbances associated with the proposed action. Disturbance types, from least intensive to most intensive, are as follows:  Clearing – removal of all trees and tall shrubs.  Grading – re-contouring and smoothing the soil surface.  Excavation – subsurface soil work, including foundations, trenches, and cut and fill. All three disturbance categories may involve anything from hand work to heavy equipment. Three additional points help put these disturbance-area estimates in context. First, the construction buffers included in these calculations of disturbed areas are generally restored and revegetated when the project is complete (section 3.4.1.3). However, lift terminals typically receive different treatment due to skier circulation and maintenance requirements. Bottom terminal sites include maze and loading areas, and top terminals require off-loading ramps and access to the skiways and runs they serve. All require summer access for maintenance. As a result, terminal areas are typically not restored and revegetated in the way other disturbance buffers are and tend to remain compacted with sparse vegetation. Second, the disturbance areas for the proposed Flora lift and Baldy Tram terminals is considerably less than for the Sunnyside and Wildcat lift replacements. The Flora lift would be a fixed-grip double chair, requiring significantly smaller terminals than the detachable lifts replacing Sunnyside and Wildcat, and with significantly fewer riders, requiring less maze, loading, and off-loading space. Skier numbers using the tram would be even lower, and terminal requirements for a small, jig-back tram are minimal. These differences are reflected in the figures reported in Table 3-2 below. Third, the construction buffers applied for this analysis can be changed on a site-specific basis for resource protection or other reasons. For example, if a wetland fell within an arbitrary construction buffer, permitting requirements and standard BMPs would include all reasonable efforts to avoid disturbing it.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-1. Typical disturbance dimensions1 by project type. Project Type Disturbance Dimensions Disturbance Type2 Parking Areas Footprint size plus 20-foot construction buffer Excavation Chairlifts/Replacements Terminals As designated by footprint Grading/Excavation Towers 25 feet x 25 feet Excavation Alignment Clearing 40-foot width Clearing Access Roads Footprint size plus 20-foot construction buffer Excavation Gazex or Other Technologies Gas storage unit 8 feet x 8 feet Excavation Transmission line 4-foot width Excavation Exploders Upper Footing 15 feet x 15 feet Excavation Lower Footing 7 feet x 7 feet Summer Ski Run Work Actual acreage of planned disturbance Grading/Excavation Buildings and Other Infrastructure Footprint size plus 50-foot construction buffer Excavation/Grading Snowmaking and Utility Lines 12-foot width Excavation 1These are the dimensions of construction-related disturbance, not the finished dimensions of projects. 2 Indicates maximum disturbance intensity (e.g. excavation disturbance also includes grading).

Table 3-2. Disturbance types and acres disturbed under the proposed action. Disturbance Category and Acres Disturbed1 Project Name Clearing2 Grading Excavation Project Total Albion/Wildcat Base Parking (Albion lot) - - 2.81 2.81 Tram from Germania Pass to the top of Mt. Baldy - 0.51 0.51 Access Road - - 0.15 - Lift Corridor - - - - Terminals - - 0.36 - GazEx or Other Equivalent Technologies to Replace Artillery and Avalauncher - - 0.59 0.59 Exploders - - 0.08 - Storage Building - - 0.01 - Trench - - 0.50 - Sunnyside Lift Replacement 1.03 - 1.62 2.65 Lift Corridor 1.03 - - - Terminals - - 1.62 - Wildcat Lift Replacement 0.82 - 1.62 2.44 Lift Corridor 0.82 - - -

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-2 (cont’d). Disturbance types and acres disturbed under the proposed action. Disturbance Category and Acres Disturbed1 Project Name Clearing2 Grading Excavation Project Total Terminals - - 1.62 - Flora Lift Construction from the Bottom of Sugarbowl to 0.99 0.63 0.52 2.14 the Top of Collins Lift Access Road - 0.63 - - Lift Corridor 0.99 - - - Power Line - - 0.06 - Terminals - - 0.46 - Supreme Summer Ski Run Work - - 9.20 9.20 Widen existing Devil’s Castle Road - - 2.64 - Big Dipper Borrow Site - - 0.45 - Re-contouring Erosion Gullies/ Widen Sleepy Hollow Run - - 6.11 - Alf’s Restaurant Building Addition - 0.42 0.09 0.51 Watson Shelter Building Addition - 0.25 0.02 0.27 Equipment Storage Facility Construction - 0.43 0.14 0.57 GRAND TOTAL 2.84 1.74 17.12 21.70 1 Project disturbance that overlapped other projects was only counted once. Priority was given to the project with the most intense disturbance (e.g. excavation had a higher priority than grading). 2 Represents the cleared width if the entire area were forested. Since the alignments are already largely cleared, and are only partially forested, actual clearing will be much less.

3.3 CUMULATIVE ACTIONS The cumulative actions considered in this analysis are those projects identified by the Forest Service that would have temporally and spatially overlapping impacts on the resources affected directly or indirectly by this proposed action or alternatives, in the past, present, or reasonably foreseeable future. Accordingly, the cumulative effects analysis area varies by resource. Table 3-3 describes the cumulative actions considered in this analysis. Note that the effects of other past projects are taken into consideration in the description of the affected environment under each resource discipline.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-3. Cumulative actions considered in this analysis. Project Name Project Description Past Projects Supreme Lift Location: Alta, Utah Replacement and Description: Supreme lift was realigned to start southeast of Alf’s restaurant, continue Cecret Lift Removal upslope to the bottom terminal of the existing Supreme lift, and then bend slightly to follow the existing alignment to the top terminal. Cecret lift was removed, with towers in wetlands flush cut and pulled out over the snow. In total, this project resulted in approximately 2.6 acres of ground disturbance and 1.6 acres of clearing of graded ski run and various vegetation types. Implementation Date: 2017. Quincy Mine Water Location: Alta, Utah. Tank Replacement Description: This project entailed installing a 72-inch culvert, bedded in 12 inches of gravel and then buried, through the existing closed mine portal and extending to a new concrete portal with a steel gate. A 10-inch HDPE (plastic) pipe runs through the new portal to a low bulkhead 200 feet back in the mine to supply water to the new 40-foot-diameter concrete tank plumbed into the existing snowmaking supply line. Only vent and overflow pipes extend above the ground surface. About 0.5 acre of primarily graded ski run was disturbed. Implementation Date: 2016–2017 Snowbird Gad Valley Location: Snowbird, Utah. Improvements Description: Completing projects within the current SUP boundary, including: Baby Thunder beginner facilities, lift maintenance shop relocation to expanded vehicle maintenance shop, Creekside Lodge expansion, conveyor lift to support Mountain School and Wasatch Adaptive Sports, expanding the mountain bike trail system in Gad Valley only, night skiing on Big Emma, Lunch Run summer road relocation, Mid Gad Restaurant remodel, Gad 2 lift upgrade and two trail modification. Excavation and grading affected about 30 acres, across a range of vegetation types, which were subsequently rehabilitated except for infrastructure footprints. Implementation Date: 2013–2018 Corkscrew Project Location: Alta, Utah. Description: Corkscrew trail was widened to approximately 150 feet. Nina’s Curve was filled in and merged into the skier’s left side of Corkscrew. A portion of the ridge between Nina’s and Corkscrew was re-contoured to achieve the width. A culvert was installed in Nina’s Curve gully and buried. 4.7 acres of graded ski run and a mix of vegetation types was disturbed then rehabilitated. Implementation Date: 2014. Ballroom Traverse Location: Alta, Utah. Description: Removal of a few trees and excavation to build a narrow bench, improving access to the Ballroom area (225 feet by 8 feet). About 3.3 acres of primarily graded ski run, access road, and terminal site were disturbed. All but traverse prism was rehabilitated. Implementation Date: 2015

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-3 (cont’d). Cumulative actions considered in this analysis. Project Name Project Description Present Projects Albion Meadows Location: Alta, Utah Trail Reroute Description: Proposal to reroute the Albion Meadows trail from private property onto National Forest System lands. The rerouted section will be approximately 0.3 miles long and 3 feet wide. The old trail will be scarified and revegetated. Implementation Date: Anticipated 2018. Wildcat and Location: Alta, Utah. Buckhorn Parking Description: Increasing the size of the roundabout and private-vehicle drop-off area, Lot Improvements moving the entry to the parking lot approximately 100 feet to the west, and moving the snowmaking water-cooling tower in the Buckhorn lot. About 0.1 acre of previously disturbed ground will be affected. Implementation Date: 2018. Rollercoaster Location: Alta, Utah. Snowmaking Loop Description: Replace a dead-end snowmaking line with a 900-foot loop and three hydrants, increasing efficiency and preventing freeze-ups. It will include about 900 feet of buried snowmaking line supporting three hydrants, disturbing about 0.6 acres in an existing, graded ski run. Implementation Date: 2018. Reasonably Foreseeable Projects Patsey Marley Location: Alta, Utah. Shrontz Utility Right- Description: Construct a 400-foot utility right-of-way and widen 710 feet of the existing of-Way Albion Basin Road (National Forest System Route 028) to improve access to the proposed Patsey Marley Hill Property and subdivision. Expected Implementation: 2018 Snowbird Zip Line Location: Snowbird, Utah. Project Description: Installation of a 2.75-mile, three-segment Zip Tour starting on Hidden Peak and ending at the northwest corner of Lot 1. Launch and land towers would disturb 0.9 acres of graded ski run and forested land. Expected Implementation: 2018. Alta Ski Area East Location: Alta Ski Area, Salt Lake County Baldy Remote Description: Installation of pedestals to place Obell'X Avalanche Control Devices on Mt. Avalanche Mitigation Baldy above the East Baldy Traverse. Project Expected Implementation: 2018.

3.4 PHYSICAL AND BIOLOGICAL ENVIRONMENT

3.4.1 SOIL, WATER, AND WATERSHED RESOURCES

3.4.1.1 Scope of Analysis  How would the proposed infrastructural development affect soils, erosion, sedimentation, water quality, and overall watershed function?

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Environmental Assessment: Alta Master Development Plan Improvement Projects

The project area is characterized by steep slopes, erosive soils and, in many areas, sparse ground cover. Construction-related disturbance and subsequent use could result in decreased permeability and productivity, and increased erosion and sediment transport to streams. Since the ski area is in Salt Lake City’s municipal watershed, maintaining water quality is of concern. Indicators: For soil productivity, calculation of the change in the extent of impermeable surfaces. For erosion, sedimentation, and water quality, a risk rating for each project, calculated using the connected disturbed area (CDA; Furniss et al 2000; Forest Service 2006a) approach that incorporates soil type, disturbance area, intensity of disturbance, slope, presence of a runoff pathway, distance to a water body, and efficacy of proposed design criteria and mitigation. Water quality is the primary indicator of watershed functioning.  Could potential leaks and spills of fuels and other chemicals impact water quality? Construction, maintenance, and use of the proposed facilities would involve the use of fuel and other chemicals. Leaks or spills could adversely affect water quality in the watershed. Indicators: A qualitative assessment of the likelihood of contaminant releases and the efficacy of measures in place to manage them.  How would the proposed infrastructure affect wetlands and riparian areas? The project area includes several types of wetlands, riparian areas, intermittent and perennial streams, and associated riparian habitat conservation areas (RHCAs). Construction and subsequent use could decrease the functioning and the extent of these valuable, aquatic habitats. The wetlands adjacent to the Albion parking lot are a particular concern. Indicators: Calculation of the acreage of these habitats lying within disturbance footprints, and discussion of the resulting direct, indirect, and cumulative effects on the extent and function of these habitats within the watershed boundary. Forest Plan guidance regarding RHCAs states that “This designation still allows for a full range of activities but it emphasis the achievement of riparian management objectives that are identified on a site- by-site basis” (p. GL-32 Forest Service 2003). This review identified several consideration that should be accounted for by objectives: Riparian Class I streams (Little Cottonwood Creek), populations of Bonneville cutthroat trout in Little Cottonwood Creek below the project area, and landslide prone areas. The resulting objectives for project-area RHCAs are: 1. Maintain functions that filter pollution, prevent sedimentation, and support existing levels of water quality in municipal watersheds. 2. Maintain 80 percent bank stability. A stable bank is one that is not sloughing into the channel. 3. Increase woody riparian vegetation adjacent to streams such as willows and sedges to at least 60 percent of the stream reach. 4. Enhance upland soil and vegetation conditions that will reduce pollution and sediment movement to streams. 5. Maintain wildlife habitat and corridors for wildlife. Several of these objectives are based on riparian management objectives in the Inland Native Fish Strategy (INFISH; Forest Service 1995a, 2004) and indices from Habitat Suitability Index (HSI) models (Raleigh et al. 1984) for cold water fish species. Analysis was conducted at a spatial scale defined by the project area boundary.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

3.4.1.2 Affected Environment The project area is defined by two primary watersheds including Albion Basin and Collins Gulch. Albion Basin comprises a majority of the ski area, including the headwaters of Little Cottonwood Creek and Cecret Lake, and extends outside of the project area to the north and east. Snowmelt runoff and shallow groundwater in Albion Basin are captured by intermittent and perennial stream channels that flow into the Little Cottonwood Creek during spring and early summer. The creek is primarily a perennial stream in the project area. Discharge from Cecret Lake occurs when water levels are above the outlet elevation. Collins Gulch is located to the west of Albion Basin and begins above 11,000 feet at Mt. Baldy. Several intermittent stream channels flow into Collins Gulch and provide seasonal discharge to an intermittent tributary of Little Cottonwood Creek near Alta Lodge. Erosion, Sedimentation, and Water Quality Soil, water, and wetland resources were described in the 1997 EIS (Forest Service 1997; incorporated by reference). This section summarizes and updates that information as necessary. Three primary sources of information were used to update a description of the affected environment. First, aerial photos and soil survey information was reviewed and summarized to identify compacted or impervious surfaces and the potential for soil erosion. Second, water quality in Little Cottonwood Canyon is regularly monitored by the Utah Division of Water Quality (DWQ) to insure standards are met and existing levels of quality do not degrade. Results of this monitoring were reviewed. Third, site visits to the proposed project locations were conducted in 2016 and 2017. There are areas of low ground cover in the project area which have an elevated erosion potential. Those areas correspond to alpine areas above the tree line, waste rock piles associated with relic mines, and some of the steep hillslopes. Erosion in some areas is naturally occurring, but in others it may be affected by past mining, timber harvesting, and livestock grazing practices. One such area is located near the appropriately named Erosion Gullies ski run west of the upper terminal of the Supreme lift. A series of erosion gullies have formed that terminate near the headwaters of an intermittent stream, likely having a negative effect on water quality. Soil productivity in the project area was not addressed in the 1996 EIS. For this analysis, the amount of compacted or impervious surface created by buildings and roads was selected as an appropriate measure, as these are the productivity parameters most likely to be affected. Impervious surfaces constitute a permanent, or at least a long term, loss of soil productivity. Paved roads and buildings are a complete loss, and the unpaved, compacted surfaces of roads and trails may be a partial loss, as some functions remain (e.g., some infiltration and vegetation production). Paved surfaces in the project area include parking lots and roads and cover 13.69 acres. Buildings in the project area house lift terminals, equipment storage, and snowmaking infrastructure, and they constitute 2.54 acres of lost soil productivity. Lift towers contribute a negligible amount of impervious surface. Unpaved roads and trails contribute 27.41 acres and 2.23 acres, respectively, of lost soil productivity in the project area. The total loss of soil productivity due to soil compaction and impermeability in the project area is 45.87 acres. Soil resource information in the project area was obtained from the national Soil Survey Geographic Database (NRCS 2017) and a 1973 soil survey completed for the Alta-Little Cottonwood area (Woodward et al. 1974). Additional soil information was found in a more recent soil survey completed for Albion Basin (Jensen 1993) and in the 1996 FEIS for the Alta MDP update (Forest Service 1997). A total of five soil associations are found in the project area (Table 3-4) and the proposed projects are sited on four of these soils. Soil map units in the project area are shown in Figure 3-1. Soils in the project area occur in various combinations based upon slope, glacial geology/landform, and micro-climate. Soil resources in Albion Basin are generally deeper, more consistently developed, and strongly influenced by moisture content (Jensen 1993) in comparison to Collins Gulch. Jensen (1993) estimated that hydric soil characteristics indicative of wetlands were found in many locations in Albion Basin.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-4. Soil units in the project area. Map Mapping Unit Name Area (acre) Unit ID 118 Dromedary-Rock outcrop complex, 30 to 70 percent slopes, parent material is colluvium and till derived from sandstone, shale and conglomerate. Rock outcrop 139 comprises 15 percent of this unit. 159 Parkcity-Dromedary gravelly loams, 15 to 30 percent slopes, parent material is slope alluvium and colluvium derived from sandstone, limestone and quartzite. 458 Rock outcrop comprises 5 percent of this unit. 160 Parkcity-Dromedary gravelly loams, 30 to 70 percent slopes, parent material is colluvium derived from sandstone, limestone and quartzite. Rock outcrop <0.1 comprises 5 percent of this unit. 164 Rock Outcrop, soil associations (including Agassiz, Starley family, Hades, and Parkcity associations) comprise only 10 percent of this unit and the remaining 90 457 percent consists of rock outcropping. 165 Rock outcrop-Starley family complex, 30 to 70 percent slopes, parent material is colluvium derived from limestone, quartzite and sandstone. Rock outcrop 1,004 comprises 50 percent of this unit.

Collins Gulch contains well-drained, gravelly loam soils at lower elevations that decrease in depth with elevation. Shallow drainages that flow into Collins Gulch include hydric soil in isolated areas where seasonal runoff collects. The upper third of Collins Gulch is comprised of 50–90 percent rock outcrop in the form of glacial cirques, talus slopes, and sharp crested ridges. Cirque basins found at upper elevations in Albion Basin and Collins Gulch contain eroded material and shallow residual deposits of soil. Soils in the project area are generally in good condition. Most base area facilities are located near Little Cottonwood Creek on stream banks and terraces composed of coarse glacial deposits of cobble and boulder (Forest Service 1997). Impacts on riparian soils have been stabilized with native vegetation and other nonpoint source controls (Jensen 1993, Forest Service 1997). Limited erosion has occurred due to unsuccessful revegetation following construction projects (Forest Service 1997). Erosion also occurred when a culvert in the bottom of Collins Gulch was completely blocked during peak flows in early summer 2011 (Forest Service 2011). The diverted stream created a small mudflow that travelled downslope to the lift terminal area. Ski area personnel quickly restored flow to the culvert and stabilized the area the following day, resulting in short-term sediment impacts on Little Cottonwood Creek (Forest Service 2011). Water quality in Little Cottonwood Creek is monitored closely by the DWQ and Salt Lake City because the creek is a significant water source for Salt Lake City, supports native aquatic species, and is important for recreation. Little Cottonwood Creek above the National Forest boundary is classified as an antidegradation segment (High Quality Water - Category 1). This classification indicates that existing water quality is higher than state standards, and that the state is required by regulation to maintain this condition. Numeric water quality standards for all beneficial uses assigned to Little Cottonwood Creek are found in Section R317-2, Utah Administrative Code, Standards of Quality of Waters of the State (State of Utah 2016). Little Cottonwood Creek and its tributaries in Little Cottonwood Canyon are assigned the following beneficial uses: secondary contact recreation, cold water aquatic life, and drinking water prior to treatment for culinary use.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Figure 3-1. Watershed resources map including soils, wetland, and RHCAs.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

The DWQ is required by the Clean Water Act to publish an integrated water quality report (IR) every other year that describes the health of waters of the state. This report compares available monitoring data (i.e., chemical, biological, and physical parameters) to numeric standards, indicators, and narrative descriptions. If standards are not met, the water body is included on a list of impaired waters (303[d] list), requiring DWQ to define a Total Maximum Daily Load (TMDL) and develop a plan to restore water quality. The 1998 IR indicated that Little Cottonwood Creek was impaired due to elevated levels of zinc, and the necessary assessment and restoration plan were completed in 2002 (DWQ 2002). Based on additional monitoring data and review, the 2014 IR identified other water quality parameters in Little Cottonwood Creek that exceed water quality standards including copper, cadmium, and pH (DWQ 2014). These parameters have a low priority for completing a TMDL, and additional monitoring and review by DWQ will determine if further action is needed. Potential Leaks and Spills of Fuels and Other Chemicals Maintenance and use of existing facilities at Alta involve machinery and equipment that require fuel, oil (including motor and hydraulic oil), and petroleum-based lubricants. These fluids are a potential source of environmental contamination and are regulated under the Code of Federal Regulations (CFR) 112.1 through 112.8. The regulations require a Spill Prevention Control and Countermeasure (SPCC) plan that defines operating procedures, provides measures to prevent spills, and prevents pollution from entering navigable waters of the US through drains and other paths. The regulations include specific requirements for a SPCC plan based on potential to discharge oil and facility storage capacity. Alta is required to have a SPCC plan due to the potential to discharge oil and an above-ground storage capacity that exceeds 1,320 total gallons. Alta has recently updated their SPCC plan for the base area (Sage Environmental 2016). The vehicle maintenance shop currently has the capacity to store approximately 1,500 gallons of new and used oil, kerosene, and diesel fuel. These fluids are used for vehicle maintenance and to fuel an emergency generator. An additional 1,000 gallons of storage is located outside the Wildcat administration and lift maintenance building for a second emergency generator and two electrical transformers. Small amounts of fuel and oil are also found in ski area vehicles and machinery across the project area. In regard to underground storage, three storage tanks are buried near the maintenance shop. Potential spills and leaks could occur from any source at Alta, and plans are currently in place to identify, isolate, and remove any contamination as quickly as possible. All above-ground bulk storage containers are located inside the vehicle maintenance shop, which has a secondary containment system equal to the capacity of the largest container. All bulk storage containers are monitored for integrity and signs of leaks on a regular basis. Any spills in the shop would be observed immediately, and drains in the shop are connected to an oil/water separator. Outflow from this separator goes to the Salt Lake County District #3 water treatment system. Leaks from smaller containers and equipment in the shop would also be identified quickly due to the visible location of these sources and frequent presence of shop personnel. Leaks from emergency generators would be contained inside of the generator housing. The potential for leaks from electrical transformers is low due to their design, and these sources are constantly monitored as part of routine operations. Vehicles and machinery used to operate the ski area are maintained on a regular schedule which minimizes the potential for leaks to occur. Underground storage tanks at Alta are double walled, monitored with leak detection sensors, and compliant with all underground storage tank regulations. Routine inspections of the underground tanks have not identified leaks (Ausseressus 2017). The SPCC requires monthly inspection of all sources at the vehicle maintenance shop, and records of these inspections are kept in the facility SPCC file. Shop personnel receive annual training on spill response, and all employees at Alta are instructed to report any spill or potential spill situation immediately. The Utah Department of Environmental Quality routinely monitors Alta inspection records

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Environmental Assessment: Alta Master Development Plan Improvement Projects

and completes periodic on-site monitoring to ensure that above and below ground storage containers are properly maintained. No surface spills have occurred at Alta that delivered water to Little Cottonwood Creek or its tributaries (Ausseressus 2017). Wetland and Riparian Resources This analysis uses RHCAs as an efficient basis for addressing potential impacts on riparian areas and aquatic habitats other than wetlands. RHCAs are defined by the following parameters included in the Forest Plan: 300 feet either side of fish-bearing perennial streams; 150 feet either side of perennial non- fish bearing streams and wetlands greater than 1 acre; and 50 feet either side of intermittent streams, wetlands less than 1 acre, and landslides and landslide-prone areas. The 50-foot buffer is increased to 100 feet for water features located in watersheds that contain Bonneville or Colorado River cutthroat trout. As noted previously, Little Cottonwood Creek does contain Bonneville cutthroat trout below the project area and, as a result, RHCAs for intermittent streams have a 100-foot buffer. The extent of the RHCA is based on the digitally-corrected stream locations visible on aerial imagery, and on the National Wetlands Inventory (NWI) data set. NWI is discussed further below. Figure 3-1 shows the extent of RHCAs within the project area. The total RHCA acreage in the project area is 432.77 acres, comprising 422.52 acres associated with aquatic features and 10.25 acres associated with a historic landslide. Overall, the condition of riparian zones in the project area has improved relative to historic conditions and is being maintained in an ecologically sound manner. This improvement in riparian zone condition is contributing to meeting RHCA management objectives (section 3.4.1.1). Remaining water quality concerns are associated with mining, specifically with discharge from mine portals. To address wetlands, this analysis uses the NWI for a broad characterization of wetland resources in the project area, then shifts to actual field-verified delineations of wetlands that would be affected by the proposed action. The NWI underestimates project-area wetlands and is not accurate at finer scales, but it provides the best overview available. A broad-scale inventory was completed in Albion Basin to identify areas with hydric soil conditions and corresponding wetland vegetation (Crowley 1992, Jensen 1993). This inventory classified 485 acres of plant communities in Albion Basin, including 237 acres that could potentially meet wetland soil and vegetation criteria. The third criterion, hydrology, was not assessed. The resulting report identified the maximum extent of potential wetlands in Albion Basin. It has been used as a means of screening potential development for more detailed wetland delineation. Site-specific surveys, including formal wetland delineation if potential wetlands are present, are required prior to construction activities on any public or private land in Little Cottonwood Canyon. Approximately 42 acres of wetland and riparian vegetation were mapped in the project area by the NWI. Table 3-5 shows the acreage of each type of wetland identified. Based on this information, most of the wetland acreage at Alta is defined as riparian wetlands. The remaining wetland resources at Alta are comprised of shrub/scrub wetlands, ponds, and meadow wetlands. Following the broad-scale, NWI-based review of wetland resources, three additional steps were taken to verify the presence or absence of potential wetland areas within the disturbance footprint of proposed projects. First, pedestrian surveys were completed in the disturbance footprints to identify which projects had wetland habitats. Those projects comprised only of upland habitats were not considered further. Second, the boundaries of wetland habitats in the remaining project footprints were digitally delineated from both aerial and color infrared imagery taken in 2006, 2009, and 2012. And third, site investigations were conducted to verify whether wetland vegetation, soils, and hydrology were present in the digitally- delineated wetland habitats. The results of those surveys are provided below in section 3.4.1.3 and provide a more accurate representation of wetland resources that may be impacted by the proposed action.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-5. Wetland resources in the project area. Type Area (acre) Meadow Wetlands 1.13 Shrub/Scrub Wetlands 12.22 Riparian Communities 24.44 Ponds 4.43 TOTAL 42.22

In regard to riparian wetlands, most stream channels are constricted in the project area, with narrow bands of vegetation bordering rocky stream channels. Larger stream channels are located in mid-to-lower elevations and fed by small first-order streams. Shallow groundwater flow supports wider riparian corridors at lower elevations including Little Cottonwood Creek as it exits the project area. The riparian corridor of Little Cottonwood Creek is designated as a Class I riparian area based on rating criteria for riparian resource values (Forest Plan, Appendix VII) and high ratings for Water Quality and Special Administrative Designations categories. The less disturbed portions of the Little Cottonwood Creek riparian zone are dominated by a combination of upland and wetland plants, depending on the topography of the specific site and the elevation of the stream.

3.4.1.3 Direct and Indirect Effects Section 3.4.1, Scope of Analysis, identifies the indicators for this analysis. Most are straightforward, but, the risk rating for erosion and sedimentation, needs explanation. Erosion and transport of sediment to receiving water bodies are focal points in this analysis. Natural erosion processes are part of natural soil development. However, prior to stabilization, erosion from areas disturbed by construction can occur at an accelerated rate. The method used here to assess erosion and sedimentation hazard resulting from proposed development is the connected disturbed area (CDA) approach (Furness et al. 2000; Forest Service 2006a). It involves the following steps for each project: 1. Determining the pre-mitigation erosion potential based on the erosion hazard of the affected soil types, the size of disturbance, the intensity of disturbance (i.e., clearing through excavation), the slope of the disturbed area, and the distance to the closest drainage channel or other runoff pathway (road or trail) and nearest receiving water body (stream or wetland). 2. Identifying appropriate BMPs to mitigate erosion and sedimentation hazard. 3. Assessing the post-mitigation erosion risk based on the efficacy of the identified BMPs. Based on the factors listed in point 1, projects are assigned a pre-mitigation risk rating of high, medium, or low for erosion and sedimentation. Generally, project elements are assigned a high risk rating if they have two or more of the following attributes: large disturbance area (greater than 1 acre), proximity to a runoff pathway or receiving water body, and steep slopes (greater than 50 percent). Projects are assigned a moderate risk rating if they have one of these attributes and a low risk rating if they have none. Other factors, such as the shape and type of disturbance and the amount of disturbance inside stream and wetland buffers are also considered when assigning risk ratings. The CDA approach prescribes “disconnecting” disturbed areas. If sediment sources are disconnected from the “easy pathways” down the mountain, the total sediment yield to major streams can be greatly reduced (Furniss et al. 2000).

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Specific BMPs to reduce erosion, disconnect disturbed areas, and minimize the watershed and water quality impacts of each project are identified in the CDA analysis for the proposed action. These measures are described in more detail in section 3.4.1.5, following the discussion of direct and indirect effects, and in Section 2.5. Most of these BMPs are core measures recommended by the Forest Service for ski area development. A more detailed discussion of these measures is available in Volume 1: National Core BMP Technical Guide (Forest Service 2012a). Alternative 1 – No Action Soil, Erosion, Sedimentation, and Water Quality If the proposed action were not implemented, ongoing ski area operations would continue without further development in the project area. Soil quality and erosion, sedimentation, and water quality dynamics would remain similar to existing conditions as described in section 3.4.1.2. None of the proposed projects would resolve any such issues. Potential leaks and spills of fuels and other chemicals If the proposed action were not implemented, the potential risk for leaks and spills of fuels and other chemicals in the project area would remain at existing levels as described in section 3.4.1.2. The existing SPCC plan would remain in place to identify, isolate, and remove any environmental contamination as quickly as possible. All above-ground and below-ground storage tanks would continue to be inspected by Alta on a regular basis. State inspections would also continue as required by state and federal regulations. Based on the history of previous inspections, no spills or contamination are anticipated. No contamination issues would remain unresolved as a result of not implementing the proposed action. Wetland and Riparian Resources If the proposed action were not implemented, ongoing ski area operations would continue without further development in the project area. The condition of wetland and riparian resources would remain similar to existing conditions as described above in section 3.4.2.2. The total acreage of RHCAs in the project area would remain at 468 acres, and wetlands and stream channels would remain as they are. None of the proposed action projects would resolve wetland or riparian issues. Alternative 2 – Proposed Action Soil, Erosion, Sedimentation, and Water Quality In regard to soil quality, the proposed action would result in a loss of productivity from compaction due to construction of access roads to terminals for the Baldy tram and Flora lift. As shown in Table 3-2, these projects would include 0.15 acres of excavation and 0.63 acres of grading, respectively. As a result, the proposed action would reduce soil productivity on a total of 0.78 acres through compaction. Loss of soil productivity under the proposed action would also result from development of any structure that would cover soil with a hardened surface. These projects would include: the Albion parking lot expansion; upper and lower terminals for the Baldy tram, Sunnyside, Wildcat and Flora lifts; building additions for Alf’s restaurant and Watson Shelter, and construction of the equipment storage facility. Installation of lift towers and Gazex units (i.e. exploders, and gas storage units) would result in a minor amount of impervious surface. Based on disturbance areas shown in Table 3-2, the total disturbance resulting from these projects would be 7.20 acres. However, the actual loss of soil productivity would be 2.55 acres and only include areas covered by paved surfaces and building footprints. The remaining disturbance areas would be rehabilitated following construction. Based on these numbers, there would be a total increase of 3.33 acres of compacted soils and impermeable surface. This would be a 7 percent increase over the 45.87 acres of compacted or impermeable surface currently in the project area. Given the extent of undeveloped acreage in the project area, this loss of productivity due to compaction and paving would not be a notable impact on soil quality.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

The results of the CDA analysis are presented in Table 3-6. Most projects would be located on well- drained colluvium soils in the Starley family association with a severe erosion potential. However, these soil types (mostly 164 and 165; see Table 3-4 above) include 50–90 percent rock outcrop, which is not susceptible to erosion. This substantially reduces the overall erosion and sedimentation potential. The Supreme Summer Ski Run Work project would take place in a previously disturbed area (i.e., adjacent to an existing road and on a steep hill slope where ongoing erosion has created the gullies that the project would be filling). The 1.57 acres of disturbance would involve an RHCA defined by distance from a channel, not “aquatic features.” The 347 feet of intermittent stream channel are located at the downslope end of the disturbance footprint and would not be filled or relocated. After the recontouring, the then-filled erosion gullies would be seeded with appropriate species, and erosion control measures would be implemented. This project would decrease the amount of erosion taking place within the project area, decrease sediment delivery to an intermittent stream channel, and thus improve water quality. Disturbance from individual projects would range from 0.01 acres (Gazex gas storage unit) to 6.11 acres (widening Sleepy Hollow trail). The proposed action would disturb a total of 18.86 acres. This does not include clearing, which generally would not disturb the soil surface, based on design criteria and BMPs (section 2.5 and Appendix A). Most projects associated with the proposed action include excavation, for lift terminals and tower footings, building footprints, utility trenches, and widening ski trails. At total of 17.12 acres would be excavated. Grading disturbance would be less extensive at 1.74 acres, occurring during construction of the Flora lift access road, Alf’s restaurant expansion, Watson Shelter expansion, and the equipment storage facility. Clearing would affect 2.84 acres but would have minimal impact on erosion and sedimentation as surface disturbance would not generally be involved. Project elements that involve very steep areas (i.e., maximum slope within project footprint > 100 percent) for even short distances would include the Baldy tram, Gazex installations, Sunnyside lift replacement, Wildcat lift replacement, Flora lift, and Sleepy Hollow trail. Across projects, maximum slopes range from 50 to 152 percent. All stream crossings (permanent and temporary) and their distance from projects are noted in Table 3-6. Clearing activities for lift corridors cross some stream channels, but no lift towers would be installed in stream channels or floodplains. Widening the Sleepy Hollow Trail would also involve excavation and contouring slopes around an intermittent stream channel segment. Finally, the south edge of the disturbance buffer surrounding the Alf’s restaurant addition spans a perennial segment of Little Cottonwood Creek. Temporary crossings could occur during construction of these projects if equipment were required to cross a channel in order to access a remote location (e.g., lift tower locations). This situation would be unlikely in regard to the Alf’s restaurant addition, where the channel would easily be avoided. Permanent crossings would occur over intermittent and perennial stream segments during construction of the Albion parking lot. Flow in stream channels is currently routed beneath the existing parking lot in several locations. Under the proposed action, two existing culverts would be extended to the south and one to the north in order to accommodate the Albion parking lot expansion. Any disturbance to, or fill of, stream channels would require permitting through the COE and the Utah Division of Water Rights. A stormwater settling basin located near the edge of the Albion parking lot would be moved as part of this project, but it is a manmade water feature and federal regulations pertaining to waters of the US are not applicable. Table 3-6 includes BMPs that address permanent stream crossings. These BMPs are designed to minimize the potential risk of sediment delivery to stream channels, ensure stability in channel crossings, and maintain proper stream function in channel segments above and below each crossing.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Under the proposed action, all project elements are associated with a high or medium risk rating for erosion and sedimentation prior to mitigation. This rating indicates the potential for individual projects to contribute sediment, during or following construction, to intermittent and perennial stream channels and ponds/wetlands in the project area. Projects such as lift corridors get high risk ratings due to the disturbance size and stream crossings. However, these ratings are exaggerated because lifts span stream channels but lift towers would not be located in stream channels of floodplains. Minimal surface disturbance would occur from clearing lift corridors because trees would be felled in place or removed when snow cover is present and soil surfaces are typically frozen. Table 3-6 also identifies BMPs that would minimize or eliminate the potential for erosion and sedimentation for construction aspects other than stream crossings. Some of the more important BMPs used include FAC-2, FAC-9, FAC-10, ROAD-3, ROAD-8, REC-10, REC-12, VEG-1, and VEG-2. These are discussed in section 2.5 and listed in Appendix A. With these mitigation measures in place, the erosion and sedimentation risk ratings for all projects under the proposed action would fall to low. As a result, the proposed action would generate no substantial water quality impacts on stream segments in or downstream of the project area. This conclusion is supported by past experience with implementing similar BMPs in the project area and at other resorts on the UWCNF (Forest Service 1997; Forest Service 2012a). Potential leaks and spills of fuels and other chemicals The proposed action would include Gazex avalanche control equipment that uses a pressurized oxygen/propane mixture to power controlled explosions to set off snow avalanches. Exploders are connected to storage tanks with enough capacity to fuel each system for an entire winter season. Leaks from individual exploders or storage tanks would vaporize and not contaminate soil or water. The proposed equipment storage facility would house mechanical equipment used in routine operations at the ski area. Some of this equipment could include fuel tanks, and motor and hydraulic oil. Similar to existing practices, this equipment would be used in the project area to maintain ski area activities during the winter and summer visitor seasons. As described above, Alta services their equipment on a regular schedule which minimizes the potential for leaks and spills. As a result, routine maintenance activities would continue to pose little threat of contamination. Construction of projects under the proposed action would require use of heavy equipment for excavation and grading. As shown in Table 3-6, some project elements are located near stream and wetland features, and these projects would have relatively greater potential for water quality impacts. Existing practices outlined in the SPCC plan would minimize or prevent spills and leaks from machinery used during construction activities under the proposed action. The potential for leaks occurring would be limited to periods of construction and to the volume of fluids and fuel included in the equipment used at each project site. In the event of spills or leaks, and consistent with the SPCC plan, Alta would quickly identify, isolate, and remove any environmental contamination. BMPs that reduce or eliminate potential spills or leaks include Road-10 and Fac-6 (Appendix A). Additional design criteria are found in section 2.5.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-6. CDA analysis of the Proposed Action. Soil unit1 / Project Pre-Mitigation Max Slope Proximity to Runoff Name and project Erosion Disturbance Intensity Sedimentation BMPs (%) Pathway3 Hazard2 Area (acres) Potential AqEco-2, Fac-2, Rec- Albion/Wildcat Base 159 / Crosses stream, <50 ft. to 2.81 Excavation 81 High 12, Road-7, Road-8, Parking (Albion lot) Moderate road. Road-9, Road-10. Baldy Tram 164 / Not >1,000 ft. to stream, road Access Road 0.15 Excavation 53 High rated crossing. Fac-2, Rec-10, Road- 164 / Not >1000 ft. to stream, <50 ft. 3, Veg-2. Terminal 0.36 Excavation 152 High rated to road. Subtotal 0.51 Gazex Installations 164 / Not <700 ft. to stream, <800 ft. Exploders 0.08 Excavation 128 Moderate rated to road. 164 / Not <1,000 ft. to stream, >1,000 Gas storage unit 0.01 Excavation 86 Moderate Rec-12, Fac-2, Fac-9. rated ft. to road. <700 ft. to stream, <800 ft. Trenches 165 / Severe 0.50 Excavation 133 Moderate to road. Subtotal 0.58 Sunnyside Lift Replacement Crosses Little Cottonwood Lift Corridor 165 / Severe 1.03 Clearing 150 High Creek (LCC) and road. Fac-2, Fac-10, Rec- <100 ft. to LCC, road 10, Veg-2. Terminal 165 / Severe 1.62 Excavation 50 High crossing. Subtotal 2.65

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-6 (cont’d). CDA analysis of the Proposed Action. Soil unit1 / Project Pre-Mitigation Max Slope Proximity to Runoff Name and project Erosion Disturbance Intensity Sedimentation BMPs (%) Pathway3 Hazard2 Area (acres) Potential Wildcat Lift Replacement Crosses stream (in culvert), Lift Corridor 165 / Severe 0.82 Clearing 145 High road crossing. Fac-2, Fac-10, Rec- <200 ft. to LCC, <300 ft. to 10, Veg-1, Veg-2. Terminal 165 / Severe 1.62 Excavation 101 High wetland, road crossing. Subtotal 2.44 Flora Lift >1,000 ft. to stream, <900 ft. Access Road 165 / Severe 0.63 Grading 103 High to wetland, road crossing. Stream crossing, <200 ft. to Lift Corridor 165 / Severe 0.99 Clearing 102 High road. Fac-2, Fac-9, Rec-10, Road-3, Road-7, Veg- >1,000 ft. to stream, <900 ft. Power Line 165 / Severe 0.06 Excavation 104 High 1, Veg-2. to wetland, road crossing. <50 ft. stream, wetland Terminal 165 / Severe 0.46 Excavation 108 High crossing, <200 ft. to road. Subtotal 2.15 Supreme Summer Ski Run Work Widen Devil's Castle <1,000 ft. to stream, <600 ft. Fac-2, Rec-10, Road- 165 / Severe 2.64 Excavation 97 High Road to wetland, road crossing. 3, Veg-2. <100 ft. to stream, >700 ft. Big Dipper Borrow Site 165 / Severe 0.45 Excavation 52 High to road. Fac-2, Rec-10, Veg- Re-contouring Erosion Crosses LCC headwater 2, Road-7. Gullies/Widen Sleepy 165 / Severe 6.11 Excavation 129 High (intermittent) and road. Hollow run Subtotal 9.20

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-6 (cont’d). CDA analysis of the Proposed Action. Soil unit1 / Project Pre-Mitigation Max Slope Proximity to Runoff Name and project Erosion Disturbance Intensity Sedimentation BMPs (%) Pathway3 Hazard2 Area (acres) Potential Alf’s Restaurant 159 / Crosses LCC (buffer only) Fac-2, Rec-12, Veg- 0.51 Excavation4 99 High Building Addition Moderate and road. 2. Watson Shelter <50 ft. to stream and Fac-2, Rec-12, Veg- 165 / Severe 0.27 Excavation4 56 High Building Addition wetland, road crossing. 2. Crosses wetland (buffer Equipment Storage 159 / Fac-2, Rec-12, Road 0.57 Excavation4 77 only), <50 ft. to stream, road High Facility Moderate 8, Veg-2. crossing. Total 21.70 1 Dominant soil type for a project element; other types are present. 2 Erosion hazard Not rated (soil type 164) is 90 percent rock outcrop and soil type 165 is 50 percent rock outcrop. 3 LCC = Little Cottonwood Creek 4 The intensity rating for this project includes primarily grading and about 0.1 ac or less of excavation for building footprints.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Wetland and Riparian Resources Methodologically, project elements are first assessed in terms of the acreage and percentage of RHCA that they would affect, and then on their consistence with the management objectives established for these RHCAs. The RHCA management objectives are listed above in section 3.4.1.1. Each project is evaluated according to whether it prevents, detracts, or enhances meeting those objectives. Several objectives involve water quality, and that issue is addressed in detail above under the discussion of erosion and sedimentation impacts, with the CDA approach as the main analytical tool. Several conclusions can be drawn from that analysis in regard to projects that lie within RHCAs. These conclusions are interpreted in the discussion of impacts and how they relate to RHCA objectives. The main indicator is the acreage of disturbance occurring within RHCAs, which correlates with the potential for sedimentation and thus with the potential for nonpoint-source contributions to receiving water bodies in the project area. Other RHCA objectives are intended to protect in-stream aquatic features, adjacent riparian habitat, and landslide prone areas. These objectives can likewise be addressed based on the amount of disturbance occurring in RHCAs, stream channels, and wetlands and the subsequent potential impacts on stream shading, woody debris, bank stability, riparian cover, and slope stability. As discussed above (section 3.4.1.2), the NWI was used to broadly characterize wetlands and stream channels in the project area, but any wetlands or channels actually within project disturbance footprints were identified and delineated in the field. Disturbances of these resources are defined for each project element and summarized for the proposed action. As to results, Table 3-7 summarizes potential impacts on RHCAs associated with aquatic features and a historic landslide as well as direct impacts on wetlands and intermittent and perennial stream channels. RHCA impacts associated with aquatic features would result from several projects under the proposed action including expansion of the Albion parking lot (1.42 acres), replacement of the Sunnyside lift (1.18 acres), construction of the Flora lift (0.31 acres), the Supreme summer ski run work (1.57 acres), the Alf’s restaurant building addition (0.47 acres), the Watson Shelter addition (0.23 acres), and the equipment storage facility (0.16 acres). No impacts on landslide-prone RHCA acreage would occur under the proposed action. Total impacts on RHCAs associated with aquatic features under the proposed action would be 5.34 acres, or 1.23 percent of the total RHCA acreage in the project area. The site characteristics, design criteria, and mitigation measures discussed below would reduce the intensity and duration of those impacts and allow accurate interpretation of the disturbance percentages in terms of the established RHCA management objectives. The Albion parking lot expansion would permanently impact RHCAs surrounding perennial and intermittent streams. RHCAs in the disturbance footprint would be overlain by fill material and a paved surface. BMPs that would protect RHCAs downstream of this project and stream channels in and downstream of this project include AqEco-2, Fac-2 Road-7, Road-9, and Road-10. These BMPs would maintain or restore the function of healthy riparian corridors and stream channels during and after construction activities.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table 3-7. RHCA and Wetland Table. Intermittent Perennial RHCA – Aquatic Wetlands1 Project Element Stream Length Stream Features1 (acres) (acres) (feet) Length (feet) Albion/Wildcat Base Parking (Albion lot) 1.42 0 155 214 Sunnyside Lift Replacement Lift Corridor 0.86 0 130 Terminal 0.32 0 Flora Lift Lift Corridor 0.31 0.05 67 97 Terminal <0.01 0.18 106 Supreme Summer Ski Run Work Widening Sleepy Hollow trail 1.57 0 347 Alf’s Restaurant Addition 0.47 0 65 Watson Shelter Addition 0.23 0 Equipment Storage Facility 0.16 0 TOTAL 5.34 0.23 675 506 1RHCA and wetland acres in this table are based on the site investigations, and not the NWI data.

The Sunnyside Lift Replacement would impact RHCAs by clearing the lift corridor and by construction activities in the disturbance buffer surrounding the terminal footprint. Impacts in the disturbance buffer rather than in the structure’s footprint would be rehabilitated following construction, but the actual terminal and tower footprints would be permanently impacted. The site is currently occupied by the existing lift terminal, so these impacts would not be new. Similar but fewer impacts on RHCAs would occur from installing the lift corridor and bottom terminal of Flora lift (wetland impacts of the terminal are discussed below). Disturbance in lift corridors would remove any trees and tall shrubs that prevent safe operation and maintenance of ski lifts. Trees would be felled in place or removed when snow cover was present and soils were typically frozen. Terminals require excavation for footings and some trenching for utility lines. Buffers surrounding terminals would be used preferentially (i.e., disturbance would be confined to non- RHCA portions of the construction buffer to the extent practical) to avoid or minimize impacts on RHCAs and protect surface vegetation that filters runoff and prevents sedimentation in receiving water bodies. BMPs that reduce or eliminate impacts to RHCAs from these projects include Fac-2, Fac-10, Rec- 10, Veg-1, and Veg-2. The Supreme summer trail work would impact RHCAs along an intermittent stream channel that passes through the Sleepy Hollow Trail. Areas upslope of the stream channel (including some RHCAs) would be graded and contoured to create the ski run. All disturbed areas would then be revegetated to promote stability and prevent future erosion. BMPs that would restore RHCAs and prevent sedimentation in the intermittent channel segment include Fac-2 and Veg-2. As described above, this project would decrease the amount of erosion taking place within the project area and decrease sediment delivery to an intermittent stream channel.

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The building additions at Alf’s restaurant and Watson Shelter and construction of the equipment storage facility would impact RHCAs near each project site. Disturbance buffers surrounding the footprint of each structure overlap RHCAs. Construction activities inside these buffers would utilize heavy equipment and disturb vegetation and soil surfaces in some areas. Construction activities would be planned to avoid RHCAs in disturbance buffers when possible. BMPs that would minimize impacts on RHCAs for these projects include Fac-2, Rec-12, and Veg-2. Overall, the BMPs listed in Table 3-6 and described in more detail below in section 3.4.1.5 and in Appendix A would minimize or eliminate potential adverse impacts on RHCAs. Some key measures include Fac-2, Rec-10, Rec-12, and Veg-2. Direct impacts on RHCAs under the proposed action would include temporary disturbance (e.g., lift contours, graded ski trails, and disturbance buffers surrounding building footprints that would be revegetated) and permanent disturbance (e.g., culverts and fill material over RHCAs). Based on this analysis and the past effectiveness of these BMPs at Alta, adverse impacts on RHCAs would be minimized or eliminated, and overall progress towards RHCA objectives would continue in the project area. The extent of NWI-identified wetlands within the project footprints differs from the extent identified during the site investigation. Although the NWI shows wetlands in the footprint of the Sunnyside lift replacement, Supreme summer trail work, Alf’s Restaurant addition, and the equipment storage facility projects, no wetlands were observed in those locations during the site investigation. Potential wetland areas were identified from aerial and color infrared imagery in the footprints of the Albion parking lot expansion, a different area of the Sunnyside lift replacement, and Flora lift projects. However, the potential wetlands in the Albion parking lot and Sunnyside lift alignment lacked hydric soil conditions or wetland hydrology, and therefore are not wetlands. The potential wetlands visible in the aerial and color infrared imagery at the lower Flora lift terminal are dominated by hydrophytic vegetation and have hydric soils. Although wetland hydrology was not present during the site investigation, it has been observed during the growing season. Construction of the Flora lift would impact 0.23 acres of palustrine emergent and shrub/scrub wetlands. The lower terminal accounts for 0.18 acres of those impacts. The remaining 0.05 acres are located in the lift alignment and may or may not be impacted by lift towers, depending on tower placement. Though there is a pond in the footprint of the Albion parking lot project, that pond is man-made and is part of the existing non-point stormwater treatment system constructed in the late 1980s. Parking lot runoff flows first into a cement separator at the edge of the Albion lot to remove oil, sediment, and litter. The treated runoff is then discharged into the man-made pond through a culvert where it undergoes a second settling process. Both the cement separator and the pond are cleaned periodically, and the contaminated material is removed for further treatment in the Salt Lake valley. Impacts on this pond would not require COE or Utah Division of Water Rights permits. The remaining projects associated with the proposed action would not impact wetlands. While disturbance buffers around the footprints of the terminal overlap with wetlands and indicate potential for direct disturbance, these buffers are arbitrary, and wetlands within them will be avoided to the extent practicable, in accordance with design criteria in section 2.5. Any disturbance of, or fill to, wetlands under the proposed action would require permitting through the COE and the Utah Division of Water Rights and compensatory mitigation. Those permits must be obtained prior to ground disturbing activities in jurisdictional waters of the U.S. Compensatory mitigation would be implemented at a minimum 5:1 ratio (e.g., every acre of wetland impact would require 5 acres of mitigation). Adherence to that ratio would more than ensure compliance with Executive Order 11990 which mandated a no-net-loss of wetlands. All stream channel crossings (permanent and temporary) under the proposed action are identified in the CDA analysis, and length of disturbance is accounted for in Table 3-7. These crossings would impact

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approximately 675 feet of intermittent steam channel and 506 feet of perennial stream channel resulting from the Albion parking lot expansion, Supreme summer trail work (widening Sleepy Hollow run), Sunnyside lift replacement, Flora lift construction, and the Alf’s restaurant addition. Expanding the Albion parking lot would directly impact approximately 155 feet total of two intermittent stream channels and 214 feet of a perennial channel. All channels are first order, non-fish-bearing streams. These three channels pass beneath the existing Albion parking lot in 255 feet of culverts (intermittent channels) and a 107-foot culvert (perennial channel). These three culverts would be extended to carry flows beneath the proposed expansion, too. The existing channels would be abandoned and filled. Again, these channels are not associated with wetlands. The parking lot project would require permitting through the COE and Utah Division of Water Rights. Constructing the lower Flora lift terminal would directly impact approximately 106 feet of intermittent stream channel. The channel would be rerouted to the north and east around the terminal footprint. Depending on the location of lift towers, the construction of the Flora lift may impact an additional 67 feet of intermittent stream channels and 97 feet of perennial stream channel. Channel rerouting would require permitting through the COE and Utah Division of Water Rights and compensatory mitigation, but could be covered under the same permit for placing fill material into the impacted wetlands discussed above. All other impacts on stream channels shown in Table 3-7 are considered temporary indirect impacts. The Supreme summer trail work incorporates about approximately 347 feet of intermittent stream channel, but no direct disturbance would occur in stream channels. Corridors for the Sunnyside and Flora lifts would span stream channels. The disturbance buffer surrounding the Alf’s restaurant addition footprint crosses a perennial segment of Little Cottonwood Creek, but in accordance with design criteria in section 2.5, no equipment and construction material would enter the stream channel. BMPs listed in Table 3-6, particularly FAC-2, ROAD-7, and VEG-2, would be employed at stream crossings to maintain stability and proper hydrologic function. The recommended BMPs would limit the extent of impacts, restore disturbed areas, and continue progress towards RHCA objectives.

3.4.1.4 Cumulative Effects The cumulative effects analysis area is defined as Little Cottonwood Canyon above White Pine Canyon, where project impacts on wetland and riparian resources could be additive. The time frame for this analysis is 10 years, the period necessary for vegetation to recover. Soil, Erosion, Sedimentation, and Water Quality All of the cumulative actions listed in section 3.3 have the potential to interact with the proposed action in regard to soil, erosion, sedimentation, and water quality. Factors that influence the potential for sediment delivery to water bodies (e.g., slope, soil erosion hazard, disturbance intensity) for each of the cumulative actions are similar to the proposed action. All projects are located in subwatersheds that drain to upper segments of Little Cottonwood Creek. As a result, without BMPs and effective mitigation, these projects would cumulatively contribute to water quality degradation. As discussed in the preceding section, the potential for direct and indirect impacts under the proposed action would be minimized or eliminated with the use of BMPs listed in Table 3-6. Similar mitigation requirements have been, or will be, in place for the cumulative actions. These standard BMPs and mitigation measures have proven to be effective in reducing erosion and sedimentation in the analysis area; previous projects at Alta and Snowbird ski areas have had little impact on these resources. As a result, very little cumulative effect on soil and water resources is expected.

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Potential leaks and spills of fuels and other chemicals Cumulative actions listed in section 3.3 that involve use of heavy equipment and machinery (along with fuel, motor oil, and other fluids) have the potential to interact cumulatively with similar projects under the proposed action. The potential for leaks and spills of fuels and other chemicals at Alta is managed by the most recent SPCC plan, as discussed above. Within the past 10 years, two chemical leaks have been recorded by the Utah Department of Environmental Quality (DEQ). The first involved leaking underground fuel tanks at the Alta Peruvian Lodge. The tanks were removed in 1997, remediation was completed, and the file was closed in 2014. The second incident was a leaking electrical transformer struck by a snowplow on Alta Bypass Road in 2014. Cleanup was completed within days, and no further action was required by DEQ. Although the potential for leaks and spills will increase in a cumulative way as more development occurs, the risk remains small due to training and implementation of plans that address this potential under the proposed action and cumulative actions. The low incidence of spills and successful remediation when they have occurred bears this out. Accordingly, the likelihood of notable cumulative effects due to leaks and spills is low. Wetland and Riparian Resources Two of the cumulative actions listed in section 3.3 directly impacted wetland resources and interact cumulatively with the proposed action. These are the Snowbird Gad Valley Improvements and the Supreme Lift Replacement project. These two projects directly affected 2.7 acres of wetlands. Direct impacts on wetland resources are permitted through the COE and Utah Division of Water Rights. Mitigation measures are required as part of this permitting process, including creating or restoring wetlands (if necessary) to insure that no net loss of wetlands occurs. This was the case for both of the noted projects, and mitigation requirements exceeded the area impacted. Based on these considerations, the cumulative effect on wetlands would be no decrease in wetland acreage or function in upper Little Cottonwood Canyon.

3.4.1.5 Mitigation Section 2.5 contains a summary of general design criteria and BMPs that would be followed in the implementation of the proposed action. This analysis identified additional resource-specific mitigation measures. If the proposed action were implemented, these design criteria and mitigation measures would be applied to maintain soil quality, minimize sedimentation, protect water quality, minimize or eliminate spills and leaks, and sustain riparian and wetland vegetation. With these practices in place, erosion and sedimentation would be minimized, no substantial water quality impacts on stream segments in or downstream of the project area would occur, risk of spills and leaks would be minimized, progress toward RHCA objectives for the project area would continue, impacts on wetlands would be avoided, and effects on stream channels would be negligible. The mitigation measures indicated by this analysis are summarized as follows: WAT-1: Implement the BMPs listed in Appendix A. WAT-2: Obtain appropriate COE, Utah Division of Water Rights, Salt Lake County Health Department, and Salt Lake City Department of Public Utilities permits and authorizations prior to disturbing wetlands or altering stream channels. WAT-3: Mitigate wetland and stream channel impacts in accordance with the permits and authorizations noted above and avoid any net loss of wetlands.

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3.4.2 VEGETATION

3.4.2.1 Scope of Analysis  How would the proposed infrastructure affect special-status plant species? No federally listed plant species are known to occur at Alta, but 17 Forest Service Region 4 sensitive species and four UWCNF watch-list species may occur in potentially disturbed areas. Clearing, grading, excavation, or subsequent use could adversely affect plants of these species. Indicators: Species-specific determinations of the potential individual- and population-level impacts, based primarily on past surveys, surveys completed for this analysis, published information on the species’ distribution and population status, and efficacy of proposed design criteria and mitigation.  How would the Baldy tram, in conjunction with climate change, affect the alpine ecosystem on Mt. Baldy? Constructing, maintaining, and operating the Baldy tram could potentially exacerbate the adverse impact of warming trends on the peak’s alpine vegetation. Indicators: A qualitative assessment of the direct, indirect, and cumulative effects of the Baldy tram on the alpine ecosystem.  How would the proposed infrastructure affect noxious and non-native invasive plant species? A number of noxious and non-native invasive species are known to occur in upper Little Cottonwood Canyon. Clearing, grading, excavation or subsequent use could result in new infestations or spread of existing infestations. Indicators: A risk assessment for whether noxious and non-native invasive species would become established or spread.

3.4.2.2 Affected Environment The project area is located in the upper extent of Little Cottonwood Canyon in the Wasatch Range. The Wildcat base area is at an elevation of 8,540 feet, and the summit of Mt. Baldy is at 11,068 feet. The project area has a predominantly north aspect. The area consists of alpine and montane forest and meadow communities. Due to both natural variation and previous resort development, the habitats are relatively segmented. For example, the evergreen forest communities are divided by rock outcroppings, talus slopes, and cliff areas, especially at higher elevations. Ski runs and roads have further segmented forests. As a result, forest stands resemble islands or patches rather than large contiguous blocks. Riparian communities are also present near streams and springs (see section 3.4.1.2). Within the project area, the forested habitat includes spruce-fir evergreen stands and mixed fir-aspen stands. Forest stands are largely comprised of subalpine fir (Abies lasiocarpa) and aspen (Populus tremuloides). At the higher elevations on the east side of the project area (Patsey Marley) many of the fir trees have a krummholz growth form. The forest stands have thick mountain shrub/tall forb communities in the understory dominated by snowberry (Symphoricarpos oreophilus), currant (Ribes sp.), western mountain ash (Sorbus scopulina), Woods’ rose (Rosa woodsii), gray aster (Eurybia glauca), nettleleaf giant hyssop (Agastache urticifolia), and western coneflower (Rudbeckia occidentalis). Willow (Salix sp.) stands are also common along the margins of riparian areas in Albion Basin. The meadow habitats correspond largely with ski runs, and the vegetation consists of a mixture of native and introduced grasses and forbs including such species as smooth brome (Bromus inermis), mountain brome (Bromus marginatus), meadow foxtail (Alopecurus pratensis), nettleleaf giant hysop, oneflower helianthella (Helianthella uniflora), and silvery lupine (Lupinus argenteus).

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Albion Basin is a popular wildflower viewing destination. As a result, the Albion Basin portion of the project area supports a high number of summer visitors relative to the lesser developed Wildcat portion. Summer hiking occurs both on developed trails and dispersed across the landscape, including in riparian and alpine plant communities. Special Status Species Threatened, Endangered, and Candidate Species One federally listed species, Ute ladies’-tresses (Spiranthes diluvialis), is listed by the US Fish and Wildlife Service (FWS) as potentially occurring in Salt Lake County. It is addressed in the Biological Assessment (BA) prepared for this project (Forest Service 2017a). In summary, the elevation range for this species is generally 4,200 to 5,900 feet, though it has been observed at 7,000 feet. Thus, this species would not occur in the project area based on elevation limitation, and there would be no effect on this species. Furthermore, Ute ladies’-tresses was not observed during the 2015 and 2016 surveys. Therefore, federally listed species are not discussed further in this analysis. Forest Service Sensitive Species A Biological Evaluation (BE) was also prepared for this project (Forest Service 2017b). This document assessed the presence of Forest Service Intermountain Region sensitive species in the project area and analyzed potential impacts on these species from project-related activities. A total of 17 Forest Service sensitive species are known or suspected to occur on the Salt Lake Ranger District, and four additional species are included on the watch list (Table 3-8). Surveys were conducted in 2015 and 2016 on all disturbance sites within the project area to determine if any of these species, or potential suitable habitat, were present. Additional surveys have been completed for other projects during the past two decades, including projects that were categorically excluded. The results of surveys conducted for this analysis and for other projects are incorporated in the species descriptions below and were used in analyzing the environmental consequences of the proposed action. Potential suitable habitat is present in the project area for 17 of the 21 combined sensitive and watch species. Those species are addressed further below. The four sensitive and watch species for which there is no potential suitable habitat are not addressed further in this analysis.

Table 3-8. Sensitive and watch-list plant species occurring or suspected to occur on the Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest and their level of analysis for this project.

Status and Carried into Species Comments2, 3 Rank1 Detailed Analysis? Utah angelica Sensitive Yes Suitable habitat exists in the project area. (Angelica wheeleri) G2, S2 Crenulate moonwort Sensitive No Suitable habitat includes saturated soils near seeps (Botrychium crenulatum) G3, S1 and along streams with dense herbaceous vegetation at 3,000 to 6,000 feet in elevation. Project area is outside of known distribution. Slender moonwort Sensitive Yes Suitable habitat exists in the project area. (Botrychium lineare) Wasatch fitweed Sensitive Yes Suitable habitat exists in the project area. (Corydalis caseana spp. G5, S2 brachycarpa)

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Table 3-8 (cont’d). Sensitive and watch-list plant species occurring or suspected to occur on the Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest and their level of analysis for this project.

Status and Carried into Species Comments2, 3 Rank1 Detailed Analysis? Brownie lady’s slipper Sensitive Yes Poor quality habitat exists in the project area. (Cypripedium fasciculatum) G4, S1 Lesser yellow lady’s slipper Sensitive No Suitable habitat includes shady, moist soils at 4,400 (Cypripedium calceolus var. G5, SNR to 5,280 feet in elevation. Outside of known parviflorum) distribution. Wasatch shooting star Sensitive Yes Suitable habitat exists in the project area. (Dodecatheon utahense) G4, S1 Wasatch draba Sensitive Yes Suitable habitat exists in the project area. (Draba brachystylis) G1, S1 Burke’s draba Sensitive Yes Suitable habitat exists in the project area. (Draba burkei) G3, S2 Rockcress draba Sensitive Yes Suitable habitat exists in the project area. Species (Draba globosa) G3, S2 observed during field surveys. Garrett’s fleabane Sensitive Yes Suitable habitat exists in the project area. (Erigeron garrettii) G2, S2 Utah ivesia Sensitive Yes Suitable habitat exists in the project area. (Ivesia utahensis) G2, S2 Wasatch jamesia Sensitive Yes Suitable habitat exists in the project area. (Jamesia americana var. G5, S2 macrocalyx) Wasatch pepperwort Sensitive Yes Suitable habitat exists in the project area. (Lepidium montanum var. G5, S1 alpinum) Garrett’s bladderpod Sensitive Yes Suitable habitat exists in the project area. (Lesquerella garrettii) G2, S2 Cottam cinquefoil Sensitive No Suitable habitat includes cracks and crevices in (Potentilla cottamii) G1, S1 quartzite outcrops, often shaded from direct midday sunlight, at 7,500-10,400 feet in elevation in Box Elder and Tooele counties. Project area is outside of known distribution. Barneby’s Wood aster Sensitive Yes Suitable habitat exists in the project area. (Tonestus kingii var. G3, S1 barnebyana or Aster kingii var. barnebyana or Herrickia kingii var. barnebyana) Tower rockcress Watch List Yes Suitable habitat exists in the project area. (Arabis glabra var. G5, SNR furcatipilis)

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Table 3-8 (cont’d). Sensitive and watch-list plant species occurring or suspected to occur on the Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest and their level of analysis for this project.

Status and Carried into Species Comments2, 3 Rank1 Detailed Analysis? Spruce wormwood Watch List No Suitable habitat includes spruce-fir, lodgepole pine, (Artemisia norvegica) G5, SNR and alpine tundra communities between 10,700 and 12,000 feet in Summit and Duchesne county. Project area is outside of known distribution. Sand fleabane Watch List Yes Suitable habitat exists in the project area. (Erigeron arenarioides) G3, S3 Broadleaf beardtongue Watch List Yes Suitable habitat exists in the project area. (Penstemon platyphyllus) G3, S3 1Conservation rank: G = Global, S = State. 1 = Critically imperiled, 2 = Imperiled, 3 = Vulnerable, 4 = Apparently secure, 5 = Secure, NR = Not ranked. 2Utah Rare Plant Guide, Utah Native Plant Society http://www.utahrareplants.org/rpg_species.html 3Welsh et al. 2015.

Utah Angelica Utah angelica is a tall forb in the parsley family. It typically grows in boggy or very wet areas, often in riparian communities, seeps, and springs, typically at elevations between 5,600 and 6,800 feet (up to 10,000 feet). It is endemic to Utah and is distributed primarily along the Wasatch Front in Cache, Juab, Piute, Salt Lake, Sevier, Tooele, and Utah counties (Welsh et al. 2015, UNPS 2017). No individuals were observed during 2015 and 2016 field surveys. Slender Moonwort Slender moonwort is a small forb that grows in marsh or spring areas at elevations of around 8,000 feet (UNPS 2017). It is only known from two historic collections in Utah; the population on the Salt Lake Ranger District has not been relocated. However, the UWNCF considers potential habitat to include all riparian areas above elevations of 9,000 feet. A moonwort species similar to slender moonwort was observed on the top of Hidden Peak, approximately 0.6 mile southwest of the project area, and another species was observed near the Devil’s Castle Road in the southern part of the project area. No slender moonwort plants were observed during the 2015 and 2016 plant surveys. Wasatch Fitweed Wasatch fitweed is a conspicuous flowering forb that grows in or along streams or near drainages in montane settings at elevations between 7,500 and 8,500 feet, though it has been observed at elevations up to 10,100 feet. It is endemic to Utah and occurs in Salt Lake, Summit, Utah, Wasatch, and Weber counties (UNPS 2017).Wasatch fitweed is known to occur in Albion Basin, along the banks of a perennial stream. No Wasatch fitweed was observed during the 2015 and 2016 field surveys. Brownie Lady’s Slipper Brownie lady’s slipper is an orchid that inhabits the duff layer in highly-shaded spruce-fir or lodgepole pine forests (Welsh et al. 2015) and along shaded streams (UNPS 2017) between 8,000 and 9,600 feet in elevation. It is known to occur in Cache, Daggett, Salt Lake, Uintah, and perhaps Summit counties (UNPS 2017). There are no expansive stands of spruce-fir in the project area, but there are small spruce- fir islands. Rather than having a duff layer beneath the tree canopy, these tree islands have rock, scree, or

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tall forb understories. As a result, the potential habitat in the project area is considered poor quality. No brownie lady’s slipper was observed during the 2015 or 2016 plant surveys. Wasatch Shooting Star Wasatch shooting star is a wildflower that inhabits shady, moist crevices of rock outcrops, often in the spray of waterfalls. Suitable habitat exists between the elevations of 6,600 and 9,500 feet. Occurrences are known from Big Cottonwood Canyon in Salt Lake County (Welsh et al. 2015). No Wasatch shooting star was observed during the 2015 or 2016 plant surveys. Wasatch Draba Wasatch draba is a small, short-lived annual mustard plant. It is found in shady, moist soils or rock pockets and talus areas, and along stream banks in aspen-fir communities between 5,495 and 9,810 feet in elevation. Wasatch draba is known to occur in Duchesne, Juab, Salt Lake, and Utah counties (Welsh et al. 2015), and has been observed in Albion Basin. Wasatch draba was not observed during the 2015 or 2016 plant surveys. Burke’s Draba Suitable habitat for Burke’s draba includes talus slopes and rocky outcrops of quartzite, limestone, or calcareous shale, in mixed conifer and maple/oak communities at 5,500 to 9,700 feet in elevation. Burke’s draba is endemic to the Wellsville Mountains and northern Wasatch Range (UNPS 2017, Welsh et al. 2015). There is some question as to whether Burke’s draba occurs on the Salt Lake Ranger District. As a conservative measure, it was included as a target species in the 2015 and 2016 plant surveys. Rockcress Draba Rockcress draba is a small, low-growing plant. It occurs in alpine tundra and meadows in the Uinta Mountains and in both Little and Big Cottonwood Canyons in Salt Lake County. Suitable habitat is typically located between 11,000 and 12,500 feet in elevation. Rockcress draba was observed on the summit of Sugarloaf Mountain during the 2015 plant survey and on the ridge dividing the north and east faces of Mt. Baldy during a survey for an un-related project in 2017. Garrett’s Fleabane Garrett’s fleabane is a small, showy daisy that grows on moist, limestone cliff faces and crevices between 8,950 and 12,400 feet in elevation. It is endemic to the Wasatch Mountains in Salt Lake, Utah, and Wasatch counties (Welsh et al. 2015). Garrett’s fleabane is known to occur in Albion Basin but was not observed during the 2015 or 2016 plant surveys. Utah Ivesia Suitable Utah ivesia habitat includes alpine tundra and krummholz communities, often in quartzite talus, at 10,500 to 11,800 feet in elevation in Salt Lake, Summit, Utah, and Wasatch counties. Utah ivesia has been observed on a number of occasions within the Alta SUP boundary, most commonly in the area between Sugarloaf Mountain and Cecret Lake at the top of Albion Basin. It was not observed in the disturbance area of projects associated with the proposed action. Wasatch Jamesia Wasatch jamesia is a flowering shrub found in mountain brush and spruce-fir communities, most commonly on cliffs and rock outcroppings. It is found at elevations between 5,690 to 9,005 feet. Wasatch jamesia occurs in Juab, Salt Lake, Utah, and Wasatch counties. It was observed growing on the steep, rocky, west-facing slopes of Peruvian Ridge, just west of the project area, during a survey for an un- related project in 2016. Wasatch jamesia was not observed in the disturbance footprint of the proposed action during the 2015 or 2016 plant surveys.

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Wasatch Pepperwort Wasatch pepperwort is a mustard plant inhabiting damp, rocky crevices in mountain brush and spruce-fir communities at elevations between 5,000 and 10,000 feet (Welsh et al. 2015). It is endemic to Little and Big Cottonwood Canyons in Salt Lake County and was historically known from the Oquirrh Mountains in Tooele County (UNPS 2017). A single population was identified on the east face of Mt. Baldy during surveys for an un-related project in 2010. Based on the 2015 and 2016 plant surveys, Wasatch pepperwort does not occur in the footprints or disturbance areas of any projects in the proposed action. Garrett’s Bladderpod Garrett’s bladderpod is a small, rosette-forming wildflower that inhabits alpine tundra and spruce-fir communities on limestone, quartzite, or granite talus and rock outcroppings. Suitable habitat is found between elevations of 10,000 and 12,000 feet in Davis, Salt Lake, Utah, and Wasatch counties (Welsh et al. 2015). Garrett’s bladderpod is known to exist in Albion Basin, though it was not observed during the 2015 and 2016 plant surveys. Barneby’s Wood Aster Barneby’s wood aster is a short, white, daisy found in Douglas-fir, mountain brush, and cottonwood communities between the elevations of 6,000 and 10,000 feet. It is endemic to the Canyon Mountains in Millard and Juab counties, where it occurs in mountain mahogany and oak communities on Precambrian quartzite outcrops (UNPS 2017, NatureServe 2017). However, potential habitat exists in the Bear River and Wasatch ranges. Wood aster has been observed in Albion Basin, though perhaps not the barnebyana variety. Because of that observation, this species was included in the analysis. However, Barneby’s wood aster was not observed during the 2015 or 2016 plant surveys. Tower Rockcress Tower rockcress is a slender mustard that grows in a number of communities including sagebrush, pinyon-juniper, mountain brush, aspen, and spruce-fir, ranging in elevations from 5,000 feet to 9,600 feet (UNPS 2017, Welsh et al. 2015). Tower rockcress was not observed during the 2015 or 2016 field surveys. Sand Fleabane Sand fleabane is a small, narrow-leaved daisy that grows in crevices in limestone and quartzite outcrops in the maple, oak, limber pine, and ivesia-eriogonum communities at 4,265 to 9,215 feet in elevation (Welsh et al. 2015). Sand fleabane has been observed on Peruvian Ridge, just west of the project area for an unrelated project. No sand fleabane plants were observed during the 2015 or 2016 field surveys. Broadleaf Beardtongue Broadleaf beardtongue is a penstemon with blue to lavender petals that grows in mountain brush communities between 5,000 and 8,875 feet in elevation (Welsh et al. 2015). It is distributed through the Wasatch Mountains in Salt Lake, Utah, and Weber counties. Broadleaf beardtongue is known to occur in Albion Basin. Broadleaf beardtongue was not observed during 2015 or 2016 field surveys. Alpine Ecosystem on Mt. Baldy Alpine ecosystems are considered sensitive areas due to their limited abundance. As a result, the plants and animals that solely inhabit those ecosystems may also be sensitive. Changing patterns in temperature and precipitation have been observed to influence plant distributions, with plants generally moving upslope or towards the poles (Parmesan and Yohe 2003). Subsequent research across western North America has found that changes in distribution are not uniform. Within the elevation range occupied by a given species, the average elevation went upward for 51 percent of studied species and down for 45 percent of studied species (Harsch and Hille Ris Lambers 2016). These results suggested that both low

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temperature and water availability limit upward shifts at the upper elevation limits, and increased water stress may drive upward shifts at lower elevation limits. The alpine vegetation on the summit of Mt. Baldy consists primarily of low-statured grasses and wildflowers. These plants are growing in a bed of thin soil and small, flakey talus. Plant distribution becomes increasingly sparse toward the summit. The dominant species include bluegrass (Poa sp.), bottlebrush squirreltail (Elymus elymoides), spiny phlox (Phlox hoodii), cutleaf daisy (Erigeron compositus), Ross’ avens (Geum rossii), and sulphur-flower buckwheat (Eriogonum umbellatum). No special-status plant species were observed on the surveyed portion of Mt. Baldy. East of the summit, the ground falls away quickly and transitions to eroded cliffs and talus slopes. The wildlife species that inhabit the Mt. Baldy summit include small mammals such as pika (Ochotona princeps) and Uinta chipmunk (Eutamias umbrinus), big game including mule deer (Odocoileus hemionus) and mountain goat (Oreamnos americanus), and occasional songbirds such as gray-headed junco (Junco caniceps caniceps) and mountain chickadee (Parus gambeli) (Harper and Petersen 1990). These species are most likely to be present or active during the summer and fall but either leave, hibernate, or adopt a subnivean/subterranean lifestyle during the winter and spring (NatureServe 2017). The depth and persistence of the winter snowpack on Mt. Baldy is affected by temperature, sunlight, wind, skier traffic, and the amount and timing of snowfall. Sunlight and wind-scour may remove snowpack from the south and west sides of the summit between storm events. As a result, and when the summit is open, skiers hiking up the boot-pack and accessing the chutes may come in contact with the ground surface or exposed plants, rather than walking on snow. That foot traffic may also compact and reduce the snowpack. The snowpack on the north side of the summit typically persists until July, though snow may be present in north-facing chutes until late August. Skier traffic in those areas largely occurs when plants are both dormant and covered by snow, which likely minimizes the impacts on alpine vegetation. An estimated 200 people hike from Alta and Snowbird to the summit on days when Mt. Baldy is open. The growing season on the summit lasts from July through October, though year-to-year fluctuations are common depending on weather patterns. In the absence of snow-depth data for Mt. Baldy from Alta, UWCNF, or other sources, the NRCS SNOTEL network was used to provide an estimate of the date when the snowpack may melt, and to better understand the year-to-year variability in that date. The nearest SNOTEL site is located near the Mid-Gad Restaurant at Snowbird, 1.1 miles to the west and 1,765 feet lower in elevation. Snow depth has only been recorded there since the end of the 2002 water year. Data from that site indicate that the winter snowpack completely melts away as early as May 30 (2012) and as late as July 10 (2011), with mean and median melt date of June 14 and June 9, respectively (NRCS 2016). Summer hiking trails also access the summit from both Alta and Snowbird. And although the summit is not as popular a destination as areas such as Albion Meadow, it is impacted by those summer hikers. Off of the trails, there is no evidence of notable impact on alpine plants from hiking use. Noxious and Non-Native Invasive Plants Noxious weeds are considered harmful to agriculture, the general public, and the environment because they tend to displace native plants, degrade wildlife habitat, alter nutrient cycle and fire behavior, contribute to soil erosion, and potentially reduce recreational values. They have developed many characteristics, such as rapid growth rates, high seed production, and extended growing period, that give them competitive advantages over native plants. Weeds may be introduced during ground disturbing activities if the equipment used has been previously used in an area with infestations. Disturbing soil adjacent to existing infestations may facilitate the growth of the infestation. Landowners with noxious weed infestations are required to implement control measures (Utah Code 4-17-109[2][a]).

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Non-native invasive plants are also aggressive species capable of degrading environmental quality or causing economic harm. Invasive plants are undesirable in forest ecosystems for reasons similar to noxious weeds. Management direction regarding noxious weeds and invasive species includes Executive Order 13112, issued in February 1999, which directs federal agencies to “…prevent the introduction of invasive species and provide for their control and to minimize the economic, ecological, and human health impacts that invasive species cause…” One of the goals of the National Forest Management Act (NFMA) is to provide a diversity of plant and animal communities. NFMA also includes a disclosure requirement for proposed noxious weed control activities on NFS lands. The Forest Service Manual (FSM) section on invasive species management sets objectives, policies, and responsibilities for weed management on NFS lands, and specifies the use of an integrated approach including prevention, control, cooperation, and education. And finally, Forest-specific guidance for detecting, monitoring, and treating noxious weeds is provided in the Wasatch-Cache National Forest Noxious Weed Strategy (Forest Service 2005) and the Wasatch- Cache National Forest Noxious Weed Treatment Program (Forest Service 2006b). Forest Service data indicate that a number of noxious and non-native invasive species are present in upper Little Cottonwood Canyon. Four species are documented to occur within the project area: Canada thistle (Cirsium arvense), field bindweed (Convolvulus arvensis), Dalmatian toadflax (Linaria dalmatica), and Scotch thistle (Onopordum acanthium). These species are considered noxious by the Utah Department of Agriculture and Food. Most infestations occur near roads, parking lots, and other disturbed sites in the base area. Alta ski area is part of the Cottonwood Canyons Foundation (CCF), a collective group of entities that monitors and treats noxious and non-native invasive species throughout the Wasatch Front canyons. As part of that group, Alta’s Environmental Center has established a pro-active protocol for dealing with noxious and non-native invasive plants. That protocol includes identifying zones where ground disturbance would occur, planting desirable native species, monitoring and treating weeds for 3 consecutive years following the disturbance, and then monitoring every 5 years to ensure that native vegetation seedings have been successful. The zones exist indefinitely and can be monitored and treated as needed beyond this time period. New zones are created that correspond with subsequent disturbances. Most weed infestations are controlled by hand-pulling, rather than herbicide applications to minimize potential impacts to desired vegetation. This system has successfully reduced weed infestations on past projects. For example, non-native invasive plants comprised 54 percent of ground cover on the Corkscrew project (Zone 34) in 2015, and as a result of monitoring and treatment, non-native plants only comprised 0 and 1 percent ground cover in 2016 and 2017. Similar results have been observed in the other zones; overall weed coverage decreased from 15 percent in 2015 to 5 percent in 2016. The CCF data identifies four additional Utah State noxious weeds not recorded by the Forest Service within the project area: musk thistle (Carduus nutans), spotted knapweed (Centaurea maculosa), houndstongue (Cynoglossum officinale), and perennial pepperweed (Lepidium latifolium). Those species have been documented at some point since 2012. As with the Forest Service data, most of the infestations identified by the CCF are located in disturbed sites in the base area. The monitoring data collected by the CCF was incorporated into this analysis. Other non-native invasive plants in the project area include curlycup gumweed (Grindelia squarrosa), curly dock (Rumex crispus), yellow sweet clover (Melilotus officinalis), common knotweed (Polygonum plebeium), and wand mullein (Verbascum verbatim). Surveys were also completed for noxious and non-native invasive plant species in the disturbance area associated with the proposed action. No additional federal or Utah State noxious weeds were observed in the areas surveyed. However, two non-native invasive species were observed: Kentucky bluegrass (Poa pratensis) and smooth brome. These species may have been intentionally planted as past revegetation efforts, or may have spread during past ground-disturbing activities.

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3.4.2.3 Direct and Indirect Effects Alternative 1 – No Action Forest Service Sensitive Species Potential habitat for 17 Forest Service sensitive species and four watch list species occurs in the project area. While there would be no development with the potential to affect these species or their habitats, ongoing recreational use may impact both individuals and potential habitat. The likelihood of that impact would be unchanged from existing conditions. Alpine Ecosystem on Mt. Baldy Under ongoing operations, the alpine ecosystem on Mt. Baldy would continue to experience both winter and summer recreation use, as discussed above under Affected Environment. Winter use on the south may occur over either snowpack or the ground surface depending on conditions, and any exposed plants may be damaged. Both wind scour and skier traffic can remove snowcover in localized areas. Winter use on the north side of the summit and in the chutes would continue to occur over more intact snow cover and would generally not impact the vegetation component of the alpine ecosystem. On days when Mt. Baldy is open, skier use would continue as it has in the past (roughly 200 people). The impact of summer use on the alpine ecosystem would not change from the existing pattern – concentrated along the trails and dispersed off of the trails. Under this alternative, avalanche control would continue to involve artillery-type technology. As discussed above (section 2.4.2.1), these explosive projectiles generally detonate on contact with the ground surface rather than the snow cover, resulting in more damage to soil and vegetation. As a result, control activities would continue to pose a localized threat to alpine vegetation on Mt. Baldy as well as other high-elevation avalanche starting zones targeted by artillery. In regard to the effects of climate change on Mt. Baldy’s alpine ecosystem, the Resources Planning Act April 2007 (Interim Update of the 2000 Renewable Resources Planning Act Assessment, Publication #FS-874) acknowledges and addresses climate change. It also indicates that climate variability makes predictions about drought, rainfall, and temperature extremes highly uncertain. Based on the best available science, it would be too remote and speculative to factor any specific ecological trends or substantial changes in climate into the analysis of environmental impacts of this project. Although there is a consensus that global warming is occurring, there is still much uncertainty about subsequent ecological interactions and trends at the local or site-specific scale. The best available science concerning climate change is not yet adequate to support reliable predictions about ecological interactions and trends at this site-specific scale. As a result, only a general conclusion can be drawn regarding how climate change might interact with the effects of the no-action alternative. The ongoing, adverse effects of ongoing recreational use could be exacerbated to the degree that Mt. Baldy became warmer, placing additional stress on the alpine ecosystem. Noxious and Non-Native Invasive Plants The ongoing operations would not increase the risk of noxious and non-native invasive species becoming established or spreading. In coordination with the CCF and the Forest Service, the Alta Environmental Center would continue to monitor and treat past ground disturbances for noxious and non-native invasive plant species. Existing infestations would be expected to decrease.

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Alternative 2 – Proposed Action Forest Service Sensitive Species Utah Angelica Construction of the proposed Sunnyside lift and Flora lift would disturb areas supporting boggy, wet, or riparian communities. These communities are all potential habitat for Utah angelica. The proposed Sunnyside lift would cross over two riparian areas near the lower terminal. Lift towers would be built outside of these riparian areas, similar to the current design. As a result, the lift would span riparian areas without impacting unoccupied potential Utah angelica habitat. The proposed Flora lift alignment would cross over one riparian area and would require excavation in one wet meadow for construction of the lower terminal. However, the Flora lift project area is located above the elevation range inhabited by Utah angelica, and no Utah angelica were observed during pedestrian surveys. Adherence to the riparian area BMPs listed in Appendix A would minimize the potential for erosion or sedimentation in unoccupied riparian habitat adjacent disturbances, and thus would minimize indirect effects. The proposed action would have no impact on Utah angelica individuals or populations. Slender Moonwort The proposed Sunnyside and Flora lifts cross, or are located in, marsh and spring areas that are potential slender moonwort habitat. As described above in the Utah angelica discussion, the Sunnyside lift project spans the riparian areas, and thus would not directly impact slender moonwort habitat. The Flora lift would require excavation in riparian or marsh areas for the construction of the lower lift terminal. Since slender moonwort was not observed in the footprint of any of these projects during the pedestrian surveys, the proposed action would have no impact on slender moonwort. Adherence to the riparian area BMPs listed in Appendix A would minimize the potential for erosion or sedimentation in unoccupied riparian habitat adjacent disturbances, and thus would minimize indirect effects. Wasatch Fitweed The proposed Sunnyside lift alignment includes riparian areas and is within the elevation range of Wasatch fitweed. The alignment spans riparian areas but would not require any excavation or other ground disturbances in Wasatch fitweed habitat. Wasatch fitweed was not observed in the Sunnyside lift disturbance area. Adherence to the riparian area BMPs listed in Appendix A would minimize the potential for erosion or sedimentation in unoccupied riparian habitat adjacent to the Sunnyside lift, and thus would minimize indirect effects. The proposed action would have no impact on Wasatch fitweed individuals or populations. Brownie Lady’s Slipper None of the proposed projects would impact spruce-fir or lodgepole pine forest stands that have a duff layer beneath the canopy. As described in section 3.4.2.2, the forest stands in the project area are segmented and have understories comprised of rock, scree, or tall forbs. Although the proposed Sunnyside lift alignment spans marginally shaded stream segments, construction would not result in any ground disturbance. No brownie lady’s slipper plants were observed in the project area during the pedestrian surveys. The proposed action would have no impact on brownie lady’s slipper individuals or populations. Wasatch Shooting Star None of the proposed projects would impact crevices in the spray of waterfalls. However, the Sunnyside lift project alignment does span a riparian area with some exposed rock crevices that are marginal

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potential habitat. Constructing the lift would not result in any ground disturbances in the riparian area. Other projects located in or adjacent to riparian areas would occur above the elevation inhabited by this species. Wasatch shooting star was not observed during the pedestrian surveys. The proposed action would have no impact on Wasatch shooting star individuals or populations. Adhering to the riparian area BMPs listed in Appendix A would minimize the potential for erosion or sedimentation in unoccupied riparian habitats, and thus would minimize indirect effects. Wasatch Draba The Sunnyside lift replacement, Wildcat lift replacement, and Gazex projects all include areas with either shady or moist soils, rock pockets, or talus areas within the elevation range of Wasatch draba. The Sunnyside lift alignment also crosses stream banks in aspen-fir communities that may be habitat. Excavation for new lift towers and to remove old towers would result in ground disturbance within the Sunnyside and Wildcat alignments. The Sunnyside alignment crosses riparian areas but would not result in ground disturbances on stream banks. Excavation for two of the Gazex exploder sites on Patsey Marley would disturb potential Wasatch draba habitat, but the remainder of the exploder sites would be above the species’ elevation range. The lift alignments and Gazex sites were included in the pedestrian surveys, and no Wasatch draba was observed. The proposed action would have no impact on Wasatch draba individuals or populations. Burke’s Draba The proposed Sunnyside and Wildcat lift replacement alignments pass over rock outcroppings within forested areas considered potential Burke’s draba habitat. In those alignments, impacts would be limited to excavation for tower construction. The Watson Shelter and Alf’s restaurant are within the elevation range, but excavation associated with those projects would occur on previously disturbed ground. Burke’s draba was not observed growing in the disturbance footprints of any projects associated with the proposed action. The proposed action would have no impact on Burke’s draba individuals or populations. Rockcress Draba The proposed Gazex installations near the summit of Sugarloaf Mountain are within alpine tundra and the elevation range of rockcress draba, and when the summit was surveyed, a new population of rockcress draba was located. The proposed gas storage unit site is approximately 50 feet east of one part of the population and 50 feet northwest of another part. No rockcress draba were observed at the site itself. Flagging the boundaries of these nearby groups of plants prior to construction would minimize the potential to negatively impact rockcress draba (mitigation measure VEG-1). The Gazex installations on Patsey Marley and Devil’s Castle would be below the rockcress draba elevation zone. The top terminal of the proposed Baldy tram would be constructed in potential rockcress draba habitat. However, no individuals were observed on Mt. Baldy during the pedestrian surveys. The proposed action would have no impact on rockcress draba individuals or populations. Garrett’s Fleabane The proposed Sunnyside lift and Wildcat lift replacement alignments include segments with moist crevices and limestone outcroppings that are potential Garrett’s fleabane habitat. The lift terminals are not in areas of suitable habitat, but some of the tower locations may be. The terminal sites are within the elevational range of Garrett’s fleabane. No individuals of this species were observed within these alignments during the pedestrian surveys. The proposed action would have no impact on Garrett’s fleabane individuals or populations.

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Utah Ivesia The proposed Gazex installations on Sugarloaf Mountain would be constructed approximately 1,100 feet upslope from the nearest known populations of Utah ivesia. The Gazex system would be constructed in unoccupied, potential habitat. The Flora lift project would be constructed on the opposite side of a small drainage and 800 feet away from the same population of Utah ivesia, and just below the species’ elevation range. The proposed action would have no impact on Utah ivesia individuals or populations. Wasatch Jamesia Tower construction or removal associated with the proposed Sunnyside and Wildcat lift replacement projects would result in ground disturbances in marginal potential Wasatch jamesia habitat. This habitat has a north aspect (as opposed to west), is less steep, has less exposed rock, and has a higher grass and forb cover than the habitat occupied by the Peruvian Ridge population west of the project area. Pedestrian surveys in the marginal habitat within the disturbance footprint of the Wildcat and Sunnyside lifts did not identify any Wasatch jamesia. The proposed action would have no impact on Wasatch jamesia individuals or populations. Wasatch Pepperwort The disturbance footprints of the proposed Sunnyside and Wildcat lift replacements and the Gazex installations on Patsey Marley would all include areas with damp, rocky crevices in mountain brush and spruce-fir communities within the elevation range of Wasatch pepperwort. Potential habitat within the lift alignments is limited to isolated rock outcroppings where excavation for tower construction and removal could result in ground disturbance. There is no habitat at the terminal locations. No Wasatch pepperwort individuals were observed in those areas during pedestrian surveys. The proposed action would have no impact on Wasatch pepperwort individuals or populations. Garrett’s Bladderpod The proposed Flora lift, Baldy tram, Gazex, and Supreme summer trail work projects would occur in alpine tundra and spruce-fir communities on talus and rock outcroppings within the appropriate elevation range of Garrett’s bladderpod. Excavation and grading associated with these projects would disturb the ground surface within that habitat. As mentioned above, no Garrett’s bladderpod individuals were observed during the 2015 and 2016 pedestrian surveys. The proposed action would have no impact on Garrett’s bladderpod individuals or populations. Barneby’s Wood Aster The Sunnyside and Wildcat lift replacement, Albion base parking lot, and equipment storage facility projects occur in mountain brush communities that are broadly considered Barneby’s wood aster habitat. All of these projects include excavation or grading that would disturb the ground surface. The Watson Shelter and Alf’s restaurant are within the elevation range, but those projects would largely occur in the areas disturbed when those buildings were constructed. The disturbance footprint of each project was included in the pedestrian surveys and no Barneby’s wood aster was observed. The proposed action would have no impact on Barneby’s wood aster individuals or populations. Tower Rockcress The Sunnyside and Wildcat lift replacement, Albion base parking lot, and equipment storage facility projects occur in mountain brush, aspen, and spruce-fir communities within the elevation range of tower rockcress. Excavation and grading disturbances would occur in each of these four projects. The Watson Shelter and Alf’s restaurant are within the elevation range, but those projects would occur on ground

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disturbed during the original construction of those buildings. Tower rockcress was not observed during the pedestrian surveys. The proposed action would have no impact on tower rockcress individuals or populations. Sand Fleabane The Sunnyside and Wildcat lift replacement, and Albion base parking projects are located in communities that have components of eriogonum and ivesia, and isolated limber pine and maple trees within the elevation range of sand fleabane. No sand fleabane plants were observed in the footprint of these projects during pedestrian surveys. Of the three projects, the Wildcat lift replacement is closest to the known populations on the far side of Peruvian Ridge. Additional eriogonum and ivesia communities are present within the project area, but are above the 9,215-foot-elevation habitat threshold. The proposed action would have no impact on sand fleabane individuals or populations. Broadleaf Beardtongue Lower portions of the Sunnyside and Wildcat lift replacement, the Albion base parking, and the equipment storage facility project areas have components of mountain brush plant communities that are habitat for broadleaf beardtongue within the elevation range of broadleaf beardtongue. The species was not observed during the pedestrian surveys. The proposed action would have no impact on broadleaf beardtongue individuals or populations. Summary The proposed action would have no impact on any Forest Service sensitive plant species or its habitat as long as the design criteria listed in section 2.5 and the riparian area BMPs listed in Appendix A were adhered to. The proposed action is not likely to cause a trend toward federal listing or a loss of viability of any of these species. Alpine Ecosystem on Mt. Baldy The upper terminal of the proposed Baldy tram would be located in the alpine ecosystem on Mt. Baldy described above under Affected Environment. Construction of the terminal would include excavation and grading within the 0.18-acre disturbance footprint. Any animals using that footprint would be displaced, and plant species present would be permanently removed. Maintenance of the terminal would include inspections, cable load testing, and completing any necessary repairs. Those activities would involve having personnel on-site during annual maintenance in the summer and on an as-needed basis in the winter. These activities would maintain a low level of disturbance in the localized area of the terminal. The avalanche mitigation activities supported by the tram would not substantially impact the alpine ecosystem because the starting zones of concern are on the north side of the peak and avalanche control would take place during the winter months, when the plants were dormant and snow covered, and when wildlife had either left the area, entered hibernation, or adopted a subnivean/subterranean lifestyle. The change in avalanche-control methods resulting from tram installation would have a positive effect. Smaller, hand-delivered explosives would replace the high-explosive artillery and Avalauncher rounds currently in use, resulting in less physical impact and debris. In addition, hand charges are deployed either over or on the surface of the snowpack, rather than deep in the snowpack or on the underlying ground surface, as occurs with artillery and Avalauncher rounds. While more individual charges would be used, the net amount of explosives involved would not change significantly due to smaller charge sizes and the intensity of their force at the ground surface would decrease. As a result, the impact of avalanche control activities on the alpine ecosystem on Mt. Baldy would decrease. Similar benefits would result from the switch to Gazex installations at other high-elevation locations currently controlled with artillery.

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The change in skier use of Mt. Baldy resulting from the tram installation may have minor impacts on the alpine ecosystem. As discussed in section 3.5.3.3, skier numbers on days when Mt. Baldy was open would probably increase somewhat, but the mountain would be open considerably more days per season. The ecosystem effects would be limited since that use would also occur primarily on the north side of the summit where plants were dormant and snow covered, and wildlife were absent, hibernating, or had adopted subnivean or subterranean lifestyles. However, some skiers would undoubtedly hike to the summit to ski other aspects of the mountain, so increased skier numbers could result in more areas scraped clear of snow where the impact of skis or ski boots on unprotected soil surfaces could damage vegetation and the soil surface. This would add to the effect of current use. To mitigate the impact of recreational use on Mt. Baldy, the ski area should work with the UWCNF to develop and provide educational signage and other interpretive material to inform the public about the importance of alpine ecosystems and the need to protecting them by staying on trails or on snow cover when that is not possible. The tram would not be used during summer months and is not expected to affect recreation use on Mt. Baldy. Therefore, the impact of summer use on the alpine ecosystem would not change from the existing pattern – concentrated along the trails and dispersed off of the trails. In summary, construction, maintenance, and operation of the Baldy tram would directly affect the alpine ecosystem on Mt. Baldy within the disturbance footprint of the upper tram terminal. Indirect effects would be limited since tram operation would occur on the north side of the summit where the snowpack is less affected by wind scour and sunlight, and during winter months when plants were dormant and snow covered, and wildlife were not active on the surface. As discussed in more detail above under the no-action alternative, the degree to which these effects might interact with climate change cannot be objectively assessed. These effects could be exacerbated to the degree that Mt. Baldy became warmer, placing additional stress on the alpine ecosystem. Noxious and Non-Native Invasive Plants The proposed projects overlay known infestations of two noxious weeds: Dalmatian toadflax (Sunnyside lift replacement) and field bindweed (Albion parking lot). Both species are present in trace amounts, and account for less than 1 percent of ground cover. No other infestations of noxious weeds occur in the proposed action disturbance footprint. Kentucky bluegrass occurs within the disturbance footprint of the Baldy tram, Sunnyside and Wildcat lift replacements, Flora lift, and Devil’s Castle portion of the Supreme summer ski run project. Smooth brome occurs in the disturbance footprint of the Albion parking lot, Sunnyside and Wildcat lift replacements, Devil’s Castle portion of the Supreme summer ski run project, Watson Shelter addition, Alf’s Restaurant addition, and equipment storage facility projects. Sweet yellow clover occurs in the disturbance footprint of the Albion parking lot, Sunnyside lift replacement, and Flora lift projects. Wand mullein occurs in the Albion parking lot expansion, Wildcat lift replacement, and equipment storage facility projects. The CCF would create new noxious and non-native invasive plant monitoring and treatment zones for each proposed action project. For three years following project construction, the Alta Environmental Center would coordinate with the CCF to monitor and treat any such plant species. Disturbed areas would also be seeded/planted with approved native species. Five years after project construction, the zones would be monitored to determine whether past treatments were successful and if the desired native vegetation is established. If necessary, additional treatments would be prescribed. BMPs would be employed to prevent the introduction of additional noxious and non-native invasive plants, or the spread of existing infestations, and would reduce impacts from competition and habitat alteration on residual desired species.

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3.4.2.4 Cumulative Effects Forest Service Sensitive Species All of the cumulative actions listed in section 3.3 have the potential to interact cumulatively with the proposed action on Forest Service sensitive species. With the exception of the Patsey Marley Shrontz Utility Right-of-Way, the footprints of the cumulative actions listed in section 3.3 were also surveyed for Forest Service sensitive species and habitat prior to authorization. No individuals or populations of sensitive species were observed during the surveys, similar to the proposed action; therefore, there is no potential for cumulative effects. Alpine Ecosystem on Mt. Baldy None of the actions listed in section 3.3 would directly or indirectly affect the alpine ecosystem on Mt. Baldy; therefore, there is no potential for cumulative effects. Noxious and Non-Native Invasive Plants All of the cumulative actions listed in section 3.3 have the potential to interact cumulatively with the proposed action’s effects on noxious and non-native invasive plants. Each of the cumulative actions includes an aspect of ground disturbance which could create opportunities for either new infestations or the spread of existing infestations. Those actions include weed BMPs as part of their design criteria or as mitigation measures, and adherence to the WCNF noxious weed strategy and noxious weed treatment direction (Forest Service 2005 and Forest Service 2006b), which would minimize potential adverse effects. As a result, there is potential for cumulative effects, though they are anticipated to be minimal.

3.4.2.5 Mitigation VEG-1: Delineate the boundaries of nearby rockcress draba populations on Sugarloaf Mountain using pin flags prior to construction of the Gazex system. Avoid any activity near the delineated boundary. VEG-2: Monitor and treat noxious and non-native invasive plant infestations at all areas disturbed by the proposed action for a period of at least three years following construction. VEG-3: Provide educational signage and other interpretive material to inform the public about the importance of alpine ecosystems and the need to protect them by staying on trails or on snow cover when that is not possible.

3.4.3 WILDLIFE

3.4.3.1 Scope of Analysis  How would the proposed infrastructural development affect special-status terrestrial and aquatic wildlife species and other species of interest or concern? There is no suitable habitat for federally listed wildlife species in the project area, but potential habitat for several Forest Service Region 4 sensitive species is present. Other species of concern to the public or agencies are also present, such as migratory birds. These species could be affected through habitat alteration resulting from clearing, grading, excavation, changed patterns of human activity, or the impacts of Gazex avalanche control. Indicators: Species-specific determinations of the potential individual- and population-level impacts, based primarily on past surveys, surveys completed for this analysis, published information on the species’ habitat distribution and population status, and efficacy of proposed design criteria and mitigation.

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3.4.3.2 Affected Environment Threatened, Endangered, and Candidate Species The U.S. Fish and Wildlife Service (FWS) identified three species protected by the Endangered Species Act (ESA) that may occur in the project area and/or may be affected by the project (FWS 2017a). These species are listed in Table 3-9 below. Since suitable habitat for these species is not present within the project area, none are carried into detailed analysis.

Table 3-9. Threatened, endangered, and candidate species identified by FWS that may occur in the project area and/or may be affected by the project.

Carried into Species Status Comments Detailed Analysis? Birds Yellow-billed Threatened No This species requires large riparian areas dominated by cuckoo cottonwoods.1 There is no such habitat within or near the Coccyzus project area. No critical habitat or proposed critical habitat 2 americanus exists within the project area. Fishes June sucker Endangered No This species is found in Utah Lake and the Provo River.3 Chasmistes liorus There is no downstream hydrologic connection between the project area and these water bodies. Mammals Canada lynx Threatened No This species requires old-growth forests for all aspects of its 3 Lynx canadensis life history. A previous Forest Service assessment mapped potential lynx habitat at Alta, but this habitat currently lacks characteristics necessary for use by lynx (e.g., large woody debris, thick understory brush, low snow compaction). The FWS identifies no critical habitat or proposed critical habitat within the project area.2 1 Birds of North America, http://bna.birds.cornell.edu/bna 2 (FWS 2017a) 3 NatureServe Explorer, www.explorer.natureserve.org

Forest Service Sensitive Species Several species identified by the Forest Service as sensitive are known or suspected to occur on the UWCNF. They are listed below in Table 3-10 (Forest Service 2016). Habitat for seven of these species is found in the project area, and these seven are carried into detailed analysis.

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Table 3-10. Special-status species occurring or suspected to occur on the Uinta-Wasatch-Cache National Forest and their level of analysis for this project.

Carried into Species Status Detailed Comments Analysis? Amphibians Columbia spotted frog Sensitive No This species has been documented in the project Rana luteiventris area, but no suitable habitat exists in potentially disturbed areas.1 5 Boreal toad Sensitive Yes There is suitable habitat, and there are records of 1 5 Bufo boreas this species in the project area. Birds American Three-toed Sensitive Yes There is suitable habitat, and there are records of woodpecker this species in the project area.3 4 Picoides tridactylus Bald eagle Sensitive No There is no suitable habitat in the project area.4 Haliaeetus leucocephalus Boreal owl Sensitive No The project area is outside the historic range of 4 Aegolius funereus this species. Columbian sharp-tailed grouse Sensitive No There is no suitable habitat in the project area.4 Tympanuchus phasianellus columbianus Flammulated owl Sensitive Yes There is suitable habitat in the project area, and 3 4 Psiloscops flammeolus there are records of this species in the vicinity. Great gray owl Sensitive No The project area is outside the historic range of 4 Strix nebulosa this species. Greater sage-grouse Sensitive No There is no suitable habitat in the project area.4 Centrocercus urophasianus Northern goshawk Sensitive Yes There is suitable habitat, and there are records of 3 4 5 Accipiter gentilis this species in the project area. Peregrine falcon Sensitive Yes There is suitable habitat, and there are records of 3 4 5 Falco peregrinus this species in the project area. Mammals Gray wolf Sensitive No The project area represents extremely poor Canis lupus quality habitat for this species due to human presence. No wolf packs or individuals are known to occur in the area.1 5 Rocky Mountain bighorn Sensitive No There is suitable habitat in the project area, but sheep there are no bighorn sheep herds in the vicinity. Ovis canadensis canadensis

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Table 3-10 (cont’d). Special-status species occurring or suspected to occur on the Uinta-Wasatch-Cache National Forest and their level of analysis for this project.

Carried into Species Status Detailed Comments Analysis? Spotted bat Sensitive Yes There is suitable habitat in the project area. Euderma maculatum Townsend’s big-eared bat Sensitive Yes There is suitable habitat in the project area, and Corynorhinus townsendii this species has been documented in the vicinity.5 Wolverine Proposed No This species generally avoids areas with high 6 Gulo gulo Threatened/ levels of human disturbance. There are no Sensitive recent records of this species in the vicinity.5 Fish Bonneville cutthroat trout Sensitive Yes This species occurs in Little Cottonwood Creek,

Oncorhynchus clarki utah downstream from the project area. Colorado River cutthroat trout Sensitive No The project area is outside the range of this

Oncorhynchus clarki species. pleuriticus Northern leatherside chub Sensitive No The project area is outside the range of this 7 Lepidomeda copei species. Southern leatherside chub Sensitive No The project area is outside the range of this 8 Lepidomeda aliciae species. 1 NatureServe, www.natureserve.org 2 (UDWR 2007) 3 eBird, www.ebird.org 4 Birds of North America, http://bna.birds.cornell.edu/bna 5 Utah Natural Heritage Database 6 Heinemeyer and Squires 2014 7 Northern Leatherside Fact Sheet, http://nas.er.usgs.gov/queries/factsheet.aspx?SpeciesID=651 8 Southern Leatherside Conservation Agreement, http://wildlife.utah.gov/habitat/pdf/southern_leatherside.pdf Boreal Toad Boreal toads are found in western North America, from Alaska to Baja California, with their range extending as far east as Colorado. They are found at a wide range of elevations from sea level to more than 11,000 feet. Boreal toads can occur around any slow moving or still water in their range. They use shallow, slow moving portions of these habitats for egg laying which occurs in late spring or early summer, following snow melt in high elevation habitats. Eggs hatch in 3–12 days and metamorphose in 1–3 months, with shorter durations in warmer habitats and longer durations in colder habitats. While boreal toads are dependent on water, they can travel several kilometers away from water to find new habitats (NatureServe 2017). The major threat to boreal toads is Batrachochytrium dendrobatidis, a fungus in the phylum Chytridiomycota. This fungus, commonly referred to as “chytrid” fungus, has been documented in at least 287 amphibian species worldwide (Kriger and Hero 2009). Symptoms of chytrid fungus include: lethargy,

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reluctance to flee, skin abnormalities, loss of righting reflexes, and extended back legs. Minor threats include habitat loss and alteration, drought, grazing, and roads (UDWR 2005). There is one record of one or more boreal toads in Little Cottonwood Creek, near the wildcat base area, dating from 1985. This species has not been documented in the project area since that time. However, there is a substantial amount of potential habitat in the project area, including potential breeding habitat in the disturbance area. Three-toed Woodpecker The American three-toed woodpecker occurs in high-elevation coniferous forests (usually above 8,000 feet in Utah), wherever bark beetles and other wood-boring insects are abundant. Aspen can provide nesting sites when intermixed with or adjacent to coniferous forests (Parish et al. 2002). Three-toed woodpeckers forage mainly on larvae of bark beetles and wood-boring beetles, and are most abundant in years and locations where trees have high insect populations. They are attracted to stands affected by wildfire, insect outbreaks, disease, blow-down, or other die-offs generating high densities of snags since these areas often have an abundance of beetle larvae. They generally excavate nest cavities in soft snags but may occasionally excavate live trees. They are not considered migratory, but insect outbreaks may cause irruptive movements. (Leonard 2001) Three-toed woodpeckers are detrimentally impacted by fire suppression, salvage logging, pest control, and harvest of old-growth coniferous forests. All of these activities reduce the prey base and nesting habitat available for the species. (Leonard 2001) There are several reported observations of three-toed woodpeckers at Alta, including one detected during wildlife surveys for this project in 2013. There is suitable habitat in the area, although snags at the ski area are often removed for skier safety reasons. Due to the irruptive nature of three-toed woodpeckers, a disturbance event could bring them into the area at any time. Flammulated Owl Flammulated owls are generally associated with open, xeric, ponderosa pine forests. In northern Utah, this species is known to occur in areas without ponderosa pine, such as Douglas fir and aspen stands. This species is insectivorous and feeds primarily on moths, beetles, crickets, and grasshoppers captured on the wing or gleaned off trees or the ground. Flammulated owls are secondary cavity nesters and expel woodpeckers and other cavity-nesting species from occupied sites. (Linkhart and Mccallum 2013) The primary threat to flammulated owls is habitat loss. These owls require mature trees with cavities for nesting and are more abundant in mature forest. Loss of mature forest occurs through wildfire and timber harvest. (Linkhart and Mccallum 2013) There are no reported sightings of flammulated owls at Alta. However, there is some habitat at Alta, and this species has been reported in the vicinity. Northern Goshawk Goshawks are generally found in old-growth coniferous, mixed, and deciduous forests. Nesting occurs in high canopy closure (> 70 percent) forest patches 25 to 250 acres in size. Goshawks hunt in a variety of habitats including forests, riparian areas, and sagebrush communities. Prey species vary widely by region, season, and availability, but squirrels, lagomorphs, grouse, and other large birds are common prey groups. (Squires and Reynolds 1997) The primary threat to northern goshawks is habitat destruction and degradation through timber harvest. Clear-cutting results in obvious loss of habitat, but goshawks also avoid nesting in forest stands that have been selectively logged, or thinned. (Squires and Reynolds 1997, NatureServe 2014a) There are reported sightings of goshawks at Alta. Nesting habitat in the project area is suboptimal due to the small size of forest patches and low tree density at the ski area, but there is good nesting habitat in the

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vicinity. The project area does not overlap with any 30-acre buffers around goshawk nests mentioned in the Forest Plan (Forest Service 2003). Peregrine Falcon Peregrine falcons occupy a wide range of habitats. They are typically found in open country near rivers, marshes, and coasts. Cliffs are preferred nesting sites, although reintroduced birds now regularly nest on man-made structures such as towers and high-rise buildings. Peregrines may travel more than 15 miles from the nest site to hunt for ducks, shorebirds, or songbirds. However a 5-mile radius around the nest is an average hunting area, with 60 percent of foraging occurring within this distance. (White et al. 2002) Peregrine falcons are resilient to most forms of human disturbance, and current threats to this species are minimal. Helicopter activity can cause disruption at nest sites by flushing adults and causing eggs or nestlings to be dislodged from the nest area. (White et al. 2002) There are reported sightings of peregrine falcons at Alta. The entire project area could be considered foraging habitat, and the cliffs could provide nesting habitat. Spotted Bat Spotted bats are found throughout the West in a wide variety of habitats. In Utah they are most often found in the southern two thirds of the state, in low-elevation canyons where they roost in caves and rock crevices. However, this species has been recorded at elevations up to 10,600 feet in New Mexico (Luce and Keinath 2007). In general, spotted bats are found within 6 miles of cliffs with nearby permanent water. (Priday and Luce 1999) The biggest threat to bats worldwide is white nose syndrome (WNS). WNS is caused by the fungus Pseudogymnoascus destructans and prevents bats from hibernating through the winter by causing irritation that wakes them from hibernation. Once wakened, bats expend calories at a higher rate than during hibernation. If enough calories are expended in this manner, the bats have insufficient reserves to last through the winter and they die. WNS has not reached most of the western US yet but has been spreading west steadily since at least 2006 (FWS 2017b). WNS has not been documented in this species (FWS 2017b), likely because the range of WNS and the spotted bat do not overlap. Other threats to this species are alteration of wet meadows and other foraging areas, scientific collection, pesticide use, and roost disturbance (Luce and Keinath 2007). Scientific collection and pesticide use are not likely threats in the project area. However, habitat alteration and roost disturbance could be issues. There are no records for this species in the Utah Natural Heritage Database near the project area, and no bat-specific surveys have been conducted at Alta. Suitable mines and caves exist in the project area, and for the purposes of this analysis we assume this species is present. Townsend’s Western Big-eared Bat During spring, summer, and fall Townsend’s big-eared bats roost in buildings, mines, and caves at elevations up to 11,000 feet. Hibernacula used in winter are almost exclusively mines or caves and can be up to 20 miles away from summer-use sites. Townsend’s big-eared bats eat moths and other flying insects that they take on the wing, generally at the margins of forest patches. (Kunz and Martin 1982) The fungus that causes WNS has been documented in Townsend’s big-eared bats but not in Utah (FWS 2017b). Other threats to this species include human disturbance of roost sites (IUCN 2017). There is one record for this species in the Utah Natural Heritage Database approximately 3 miles from the project area. No bat-specific surveys have been conducted at Alta. Suitable mines and caves exist in the project area, and for the purposes of this analysis we assume this species is present.

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Bonneville Cutthroat Trout Bonneville cutthroat trout generally occupy small, cold, headwater streams with water temperatures around 55 degrees Fahrenheit. These trout spawn in clean sand or gravel substrates with flowing water. (NatureServe 2014b) Threats to this species are primarily related to hybridization with non-native trout species and habitat fragmentation through barrier construction on small streams. (NatureServe 2014b) Bonneville cutthroat trout occur in Little Cottonwood Creek downstream from the project area. Migratory Birds Migratory birds are protected under the Migratory Bird Treaty Act of 1918. Executive Order 13186 (66 FR 3853, January 17, 2001) details the responsibilities of federal agencies to protect bald and golden eagles and other migratory birds. Each agency was encouraged to immediately develop a memorandum of understanding with the FWS and to begin implementing the conservation measures specified in Sec. 3 (e) of the Executive Order, as appropriate and practicable. Table 3-11 lists all Partners in Flight Priority Species, FWS Birds of Conservation Concern and species listed on the FWS Information for Planning and Conservation (IPAC) website with potential to occur in the vicinity. There are habitat and records for 17 of these species in the project area. Three of these 17 are also Region 4 sensitive species and are discussed at their higher level of protection above in section 3.6.2.2, Forest Service Sensitive Species. The remaining 14 species are carried into detailed analysis under this category.

Table 3-11. Partners in Flight Priority species for Utah, FWS Birds of Conservation Concern of Region 16, and species listed on the FWS IPAC website with potential to occur in the vicinity.

PIF or Carried into Species Comments BCC? Detailed Analysis? American white pelican PIF No There is no habitat for this species in the Pelecanus erythrorhynchos project area, and while individuals have been observed soaring over the project area, none have been observed to use habitats in the vicinity.1 2 Bald Eagle BCC No This species occasionally winters in the 1 Haliaeetus leucocephalus vicinity , but no breeding habitat exists within the project area.2 Black rosy-finch PIF, BCC Yes There is suitable habitat, and individuals have been documented in the project area.1 2 Leucosticte atrata 3

Black swift PIF No There is no habitat for this species in the Cypseloides niger project area, and no individuals have been observed.1 2 Individuals have been observed soaring further downcanyon.1 Black-throated gray warbler PIF Yes There is suitable habitat, and individuals 1 2 Dendroica nigrescens have been documented in the vicinity. Brewer’s sparrow PIF, BCC Yes There is suitable habitat, and individuals 1 2 Spizella breweri have been documented in the project area.

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Table 3-11 (cont’d). Partners in Flight Priority species for Utah, FWS Birds of Conservation Concern of Region 16, and species listed on the FWS IPAC website with potential to occur in the vicinity. PIF or Carried into Species Comments BCC? Detailed Analysis? Broad-tailed hummingbird PIF Yes There is suitable habitat, and individuals 1 2 Selasphorus platycercus have been documented in the project area. Brown-capped rosy finch BCC No The project area is out of the historic range 2 Leucosticite australis of this species. There are records for this species nearby at the town of Alta, but given the historic range of this species, these were likely transient individuals.1 Calliope hummingbird IPAC Yes There is suitable habitat, and individuals 1 2 Selasphorus calliope have been documented in the project area. Cassin’s finch BCC Yes There is suitable habitat, and individuals 1 2 Haemorhous cassinii have been documented in the project area. Ferruginous hawk PIF, BCC No The project area is too high in elevation for 2 Buteo regalis this species to use as breeding habitat. A few individuals have been observed foraging in the vicinity; however, this species normally forages at much lower elevations.1 2 Flammulated owl BCC Yes (as R4 sensitive There is suitable habitat, and individuals 1 2 Psiloscops flammeolus species) have been documented in the project area. Fox sparrow IPAC Yes There is suitable habitat, and individuals 1 2 Passerella iliaca have been documented in the project area. Golden eagle BCC Yes There is suitable habitat, and individuals 1 2 Aquila chrysaetos have been documented in the project area. Juniper titmouse BCC No There is no habitat for this species in the 2 Baeolophus ridgwayi project area. There is one record of this species in the project area but, given the lack of habitat, this was likely a misidentification or transient individual.1 Lewis’s woodpecker PIF, BCC Yes There is suitable habitat, and individuals 1 2 Melanerpes lewis have been documented in the project area. Peregrine falcon BCC Yes (as R4 sensitive There is suitable habitat, and individuals 1 2 Falco peregrinus species) have been documented in the vicinity. Prairie falcon BCC Yes There is suitable habitat, and individuals 1 2 Falco mexicanus have been documented in the project area. Rufous hummingbird IPAC Yes The project area is outside of breeding Selasphorus rufus habitat but there is suitable foraging habitat in the project area, and individuals have been documented at the ski area.1 2

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Table 3-11 (cont’d). Partners in Flight Priority species for Utah, FWS Birds of Conservation Concern of Region 16, and species listed on the FWS IPAC website with potential to occur in the vicinity. PIF or Carried into Species Comments BCC? Detailed Analysis? Swainson’s hawk IPAC No There is no habitat for this species in the project area.2 Individuals have been documented at the ski area; however, those were likely transient individuals moving from one area to another.1 Three-toed woodpecker PIF Yes (as R4 sensitive There is minimal habitat for this species in 2 Picoides tridactylus species) the project area , and individuals have been observed in the vicinity. Virginia’s warbler PIF Yes There is suitable habitat, and individuals 1 2 Oreothlypis virginiae have been documented in the project area.

Williamson’s sapsucker IPAC Yes There is suitable habitat, and individuals 1 2 Sphyrapicus thyroideus have been documented in the project area. Willow flycatcher BCC Yes There is suitable habitat, and individuals 1 2 Empidonax traillii have been documented in the project area. 1 eBird, www.ebird.org 2 Birds of North America, http://bna.birds.cornell.edu/bna 3 Utah Natural Heritage Database

Black Rosy-finch Black rosy-finches are common at Alta (eBird 2017). In summer, this species is found in a variety of open alpine habitats where individuals forage on seeds and insects. Black rosy-finches nest on the ground or on cliffs at high elevations. (Johnson 2002) Black-throated Gray Warbler Black-throated gray warblers have not been reported at Alta, and they are rarely reported in the vicinity (eBird 2017). This species is found in open coniferous or mixed forest habitats with brushy understory. Black-throated gray warblers are tree nesters, and they eat primarily insects. (Guzy and Lowther 2012) Brewer’s Sparrow Brewer’s sparrows are somewhat commonly reported at Alta (eBird 2017). The Brewer’s sparrow subspecies that is found at Alta may be the timberline sparrow subspecies (Spizella breweri taverneri). The timberline subspecies occurs in krumholtz-subalpine habitats with low vegetation whereas the nominate subspecies generally occurs in shrub steppe areas. (Rotenberry et al. 2012) Broad-tailed Hummingbird Broad-tailed hummingbirds are common at Alta (eBird 2017). They nest in aspen and coniferous forests at elevations up to 10,600 feet, where small nests are built on branches shielded from view and weather by foliage. Like most hummingbirds they primarily nectar feeders and require flowering plants from which to gather nectar. (Camfield et al. 2013)

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Calliope Hummingbird Calliope hummingbirds are common at Alta (eBird 2017). They nest in coniferous forests at elevations up to 11,100 feet, where small nests are built on branches shielded from view and weather by foliage. Like most hummingbirds they primarily nectar feeders and require flowering plants from which to gather nectar. (Calder and Calder 1994) Cassin’s Finch Cassin’s finches are common at Alta (eBird 2017). They are found in coniferous forests up to timberline in summer and lower-elevation, mixed forest habitats or even urban areas during the winter. Nests are built in conifers, with the nest usually placed near the end of a large limb. This species feeds on buds, berries, and conifer seeds (Hahn 1996). Fox Sparrow Fox sparrows are common at Alta (eBird 2017). They are found most often in riparian habitats, where they nest in thick brush. This species feeds on arthropods as well as seeds, fruit, and other plant matter. (Weckstein et al. 2002) Golden Eagle Golden eagles are common at Alta (eBird 2017). Golden eagles nest on cliffs and hunt in open areas. Suitable nesting habitat is available on cliffs in the area. (Kochert et al. 2002) Lewis’s Woodpecker Lewis’s woodpeckers are rare at Alta. This species is found in a variety of forested habitats where they forage on insects, nuts, and fruit. Lewis’s woodpeckers nest mostly in existing tree cavities but will sometimes excavate their own cavities. (Vierling et al. 2014) Prairie Falcon Prairie falcons are rare at Alta (eBird 2017). They nest on cliffs and hunt in open areas. Suitable nesting habitat is available on cliffs in the area. (Steenhof 2013) Rufous Hummingbird Rufous hummingbirds are common at Alta (eBird 2017). This species nests further north than Utah but is commonly seen in meadow and recently disturbed habitat at Alta during migration. Like most hummingbirds, they primarily nectar feeders and require flowering plants from which to gather nectar. (Healy and Calder 2006) Virginia’s Warbler Virginia’s warblers are rare at Alta (eBird 2017). They are found in brushy mixed or deciduous forests but never strictly coniferous forests. This species is entirely insectivorous and nests in open canopy forests. (Olson and Martin 1999) Williamson’s Sapsucker Williamson’s sapsuckers are rare at Alta (eBird 2017). This species is found in middle- to high-elevation conifer and mixed conifer forests. They are cavity nesters, generally excavating a new cavity each year. This species eats primarily tree sap but also takes ants and beetles opportunistically. (Gyug et al. 2012) Willow Flycatcher Willow flycatchers are rare at Alta (eBird 2017). They are most often found in shrubby riparian areas up to 8,200 feet. Nests are built in shrubs or small trees near water. (Sedgwick 2000)

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3.4.3.3 Direct and Indirect Effects Alternative 1 – No Action Alternative Under this alternative ski area operations would continue as they have in the past. Past operations have largely shaped the species community that exists in the project area and the habitat for special-status species. Not implementing the proposed action would have no impacts on any special-status species as there are no current problems with populations of these species that the proposed action addresses. Alternative 2 – Proposed Action Threatened and Endangered Species No threatened or endangered species occur in the project area; therefore, there would be no impact on threatened or endangered species under this alternative. Forest Service Sensitive Species Boreal Toad Almost all of the area impacted could provide boreal toad foraging or dispersal habitat. However, almost the entire ski area provides this kind of habitat so only a very small fraction of the available habitat would be impacted. Impacted habitat that is not in the footprint of a structure (e.g., lift tower, building, or parking lot) would remain suitable habitat following revegetation. Approximately 0.23 acres of palustrine emergent and shrub/scrub wetlands would be impacted by the proposed action. These wetlands are mostly moist ground with wetland vegetation, but in some years there could be enough standing water for breeding. The proposed action would also impact 506 feet of perennial stream channel that could provide breeding habitat in slow-moving pools, if present. A large amount of reliably suitable breeding habitat exists in the project area and this habitat is likely not limiting. Given their small size and camouflage, it is possible that some boreal toads could be inadvertently crushed by construction equipment. It is anticipated that this would be a rare occurrence since there is a large amount of habitat and that habitat is not known to be densely occupied. Based on these considerations, the proposed action would have a very slight detrimental impact on this species due to habitat loss and the potential for crushing of individuals. Three-toed Woodpecker, Flammulated Owl, and Northern Goshawk The proposed action would impact a total of 2.5 acres of non-contiguous aspen, conifer, or mixed conifer/aspen habitat, spread across the entire ski area, where these habitat types are common. The largest contiguous patch would be roughly 0.16 acres (associated with the Supreme summer run) and only one other patch would be over 0.1 acres (also associated with the Supreme summer run). None of this habitat is unique in the area or of substantial value to populations of these species in the area. The overall 2.5 acres of disturbance would constitute a very small fraction of the existing habitat for these species in the area. Based on these considerations, the proposed action would have a very slight detrimental impact on these species due to habitat loss. Peregrine Falcon While Gazex systems would be installed near some potential peregrine falcon nesting habitat, these installations would be constructed by hand with a very limited disturbance footprint. As a result, no peregrine falcon nesting habitat would be directly impacted by the proposed action. Helicopter flights during construction of the Gazex systems and for carrying in replacement gas canisters have the potential to impact any nesting peregrine falcons in the area (White et al. 2002). Mitigation measure WIL-1 would require helicopters operating during the nesting season (April–June) to approach

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and depart cliff areas from behind and above the cliffs to avoid flushing nesting falcons. This mitigation measure would eliminate potential impacts from helicopter flights associated with the Gazex installations. Changes that would occur elsewhere at Alta would not affect the value of the ski area as peregrine falcon foraging habitat. Therefore, with mitigation measure WIL-1 in place, this alternative would have no impact on peregrine falcons. Spotted Bat and Townsend’s Western Big-eared Bat While Gazex systems would be installed near some potential bat roosting or hibernating sites, these installations would be constructed by hand with a very limited disturbance footprint. No potential for the spread of WNS would occur since construction would not involve entering any mines or caves. As a result, no bat roosting or hibernating habitat would be directly impacted by the proposed action. There are several mines in the vicinity of the Gazex systems that could potentially serve as hibernacula. The areas where the Gazex systems would be installed are currently shelled using artillery or Avalaunchers for avalanche control, so shifting to Gazex under this alternative would not alter the potential effect on hibernacula. The changes that would occur elsewhere at Alta would not alter the value of the ski area as foraging habitat for these species. Therefore, this alternative would have no impact on these species. Bonneville Cutthroat Trout Under this alternative, no effects on water quality would occur (see section 3.4.1); therefore, there would be no impact on populations of Bonneville cutthroat trout downstream from the project area. Migratory Birds Black Rosy-finch This alternative would have no impact on black rosy-finches. There would be no effect on potential cliff- nesting sites, and this alternative would not detrimentally impact foraging areas. This species is often observed at ski resorts in Utah (Snowbird and Alta), and skiing is a compatible use of black rosy-finch foraging habitat (Johnson 2002, eBird 2017). Black-throated Gray Warbler, Cassin’s Finch, and Williamson’s Sapsucker The proposed action would impact a total of 2.5 acres of non-contiguous aspen, conifer, or mixed conifer/aspen habitat, spread across the entire ski area, where these habitat types are common. The largest contiguous patch would be roughly 0.16 acres (associated with the Supreme summer run) and only one other patch would be over 0.1 acres (also associated with the Supreme summer run). None of this habitat is unique in the area or of substantial value to populations of these species in the area. The overall 2.5 acres of disturbance would constitute a very small fraction of the existing habitat for these species in the area. Based on these considerations, the proposed action could have a detrimental impact on these species, primarily due to habitat loss. The impact would likely be small considering the small fraction of potential nesting habitat affected and mitigation measure WIL-2. This measure would prohibit cutting of trees during the migratory bird nesting season unless surveys were conducted prior to construction and the affected trees were free of nesting birds. Broad-tailed Hummingbird, Calliope Hummingbird, and Rufous Hummingbird Hummingbirds are common at Alta, and most of the ski area supports trees and forbs that provide nectar or potential nest sites for these species. Only a small fraction of the suitable habitat at the ski area would be affected by this alternative, and those effects would generally not reduce habitat value once remediation was done. Based on these considerations, this alternative would constitute an immeasurable impact on populations of these species in the area.

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Brewer’s Sparrow The proposed action would impact a total of less than 0.02 acres of non-contiguous krumholtz habitat. This habitat type is common in high-elevation portions of the ski area. Fifteen very small (less than 0.01 acres) patches of krumholtz habitat would be impacted by the Gazex installations. None of this habitat is unique in the area or of substantial value to populations of this species in the area. The overall 0.02 acres of disturbance would constitute a very small fraction of the existing habitat in the area for this species. Based on these considerations, the proposed action could have a detrimental impact on this species, primarily due to habitat loss. The impact would likely be small considering the small fraction of potential nesting habitat affected and mitigation measure WIL-2. This measure would prohibit cutting of trees during the migratory bird nesting season unless surveys were conducted prior to construction and the affected trees were free of nesting birds. Golden Eagle While Gazex systems would be installed near some potential golden eagle nesting habitat, these installations would be constructed by hand with a very limited disturbance footprint. As a result, no golden eagle nesting habitat would be directly impacted by the proposed action. Helicopter overflights are generally not disruptive to nesting golden eagles (Kochert et al. 2002). However, mitigation measure WIL-1 would afford protections to golden eagle nesting habitat as well as peregrine falcon nesting habitat. The changes that would occur elsewhere at Alta would not alter the value of the ski area as golden eagle foraging habitat. Therefore, this alternative would have no impact on golden eagles. Lewis’s Woodpecker The proposed action would impact a total of 2.5 acres of non-contiguous aspen, conifer, or mixed conifer/aspen habitat, spread across the entire ski area, where these habitat types are common. The largest contiguous patch would be roughly 0.16 acres (associated with the Supreme summer run) and only one other patch would be over 0.1 acres (also associated with the Supreme summer run). None of this habitat is unique in the area or of substantial value to populations of this species in the area. The overall 2.5 acres of disturbance would constitute a very small fraction of the existing habitat for this species in the area. Based on these considerations, the proposed action could have a detrimental impact on this species, primarily due to habitat loss. The impact would likely be small considering the small fraction of potential nesting habitat affected and mitigation measure WIL-2. This measure would prohibit cutting of trees during the migratory bird nesting season unless surveys were conducted prior to construction and the affected trees were free of nesting birds. Prairie Falcon While Gazex systems would be installed near some potential prairie falcon nesting habitat, these installations would be constructed by hand with a very limited disturbance footprint. As a result, no prairie falcon nesting habitat would be directly impacted by the proposed action. Helicopter flights during construction of the Gazex systems and for restocking gas canisters have the potential to impact any nesting prairie falcons in the area (Craig and Craig 1984). Mitigation measure WIL-1 would require helicopters operating during the nesting season (April–June) to approach and depart cliff areas from behind and above the cliffs to avoid flushing nesting falcons. This mitigation measure would eliminate potential impacts from helicopter flights associated with the Gazex installations. The changes that would occur elsewhere at Alta would not alter the value of the ski area as peregrine falcon foraging habitat. Therefore, with mitigation measure WIL-1 in place, this alternative would have no impact on prairie falcons.

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Virginia’s Warbler The proposed action would impact a total of 0.76 acres of non-contiguous aspen, willow, or mixed conifer/aspen habitat, spread across the entire ski area, where these habitat types are common. The largest contiguous patch would be roughly 0.41 acres (associated with the Albion base parking lot) and no other patch would be over 0.1 acres. None of this habitat is unique in the area or of substantial value to populations of this species in the area. The overall 0.76 acres of disturbance would constitute a very small fraction of the existing habitat in the area for this species. Based on these considerations, the proposed action could have a detrimental impact on this species, primarily due to habitat loss. The impact would likely be small considering the small fraction of potential nesting habitat affected and mitigation measure WIL-2. This measure would prohibit cutting of trees during the migratory bird nesting season unless surveys were conducted prior to construction and the affected trees were free of nesting birds. Willow Flycatcher and Fox Sparrow The proposed action would impact a total of 0.4 acres of non-contiguous riparian/willow habitat. The largest contiguous patch would be roughly 0.4 acres (associated with the Albion base parking lot), and no other patch would be over 0.1 acres. None of this habitat is unique in the area or of substantial value to populations of these species in the area. The overall 0.4 acres of disturbance would constitute a small fraction of the existing habitat in the area for these species. Based on these considerations, the proposed action could have a detrimental impact on these species, primarily due to habitat loss. The impact would likely be small considering the small fraction of potential nesting habitat affected and mitigation measure WIL-2. This measure would prohibit cutting of trees during the migratory bird nesting season unless surveys were conducted prior to construction and the affected trees were free of nesting birds.

3.4.3.4 Cumulative Effects The cumulative actions listed in section 3.3 are any projects that would have temporally and spatially overlapping impacts on the same resources affected directly or indirectly by these alternatives. Table 3-12 identifies these projects and summarizes their cumulative effects on wildlife. Only wildlife species that would be impacted by the proposed action are discussed in Table 3-12 since there can be no cumulative effects if no direct or indirect effects are projected to occur.

Table 3-12. Special-status wildlife cumulative effects. Action Cumulative Effects Boreal Toad Various elements of this project impacted a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability Snowbird Gad Valley habitat in the area, the effects of this cumulative action would not interact Improvements cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Corkscrew Project Various elements of this project impacted a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area.

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Table 3-12 (cont’d). Special-status wildlife cumulative effects. Action Cumulative Effects Ballroom Traverse Various elements of this project impacted a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Supreme Lift Replacement and Various elements of this project impacted a small amount of boreal toad Cecret Lift Removal habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Quincy Mine Water Tank This project did not impact any boreal toad habitat. Replacement Albion Meadows Trail Reroute Various elements of this project may impact a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Wildcat and Buckhorn Parking This project does not impact any boreal toad habitat. Lot Improvements Rollercoaster Snowmaking Loop Various elements of this project may impact a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Various elements of this project may impact a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability Patsey Marley Shrontz Utility habitat in the area, the effects of this cumulative action would not interact Right-of-Way cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Various elements of this project may impact a small amount of boreal toad habitat. Given the small amount of habitat impacted and the availability Snowbird Zip Line Project habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact boreal toad populations in the area. Three-toed Woodpecker Various elements of this project impacted a small amount of three-toed woodpecker habitat. Given the small amount of habitat impacted and the Snowbird Gad Valley availability habitat in the area, the effects of this cumulative action would not Improvements interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area. Corkscrew Project Tree removal associated with this project impacted a small amount of three- toed woodpecker habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area.

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Table 3-12 (cont’d). Special-status wildlife cumulative effects. Action Cumulative Effects Ballroom Traverse Tree removal associated with this project impacted a small amount of three- toed woodpecker habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area. Supreme Lift Replacement and Tree removal associated with this project impacted a small amount of three- Cecret Lift Removal toed woodpecker habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area. Quincy Mine Water Tank This project did not impact any three-toed woodpecker habitat. Replacement Albion Meadows Trail Reroute This project does not impact any three-toed woodpecker habitat. Wildcat and Buckhorn Parking This project does not impact any three-toed woodpecker habitat. Lot Improvements Rollercoaster Snowmaking Loop This project does not impact any three-toed woodpecker habitat. This project has the potential to impact a very small amount of three-toed woodpecker habitat along the existing Albion Basin Road. Given the small Patsey Marley Shrontz Utility amount of habitat impacted and the availability habitat in the area, the effects Right-of-Way of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area. This project has the potential to impact a very small amount of three-toed woodpecker habitat along the cable alignments and launch and landing towers. Given the small amount of habitat impacted and the availability Snowbird Zip Line Project habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact three-toed woodpecker populations in the area. Flammulated Owl Various elements of this project have the potential to impact a small amount of flammulated owl habitat. Given the small amount of habitat impacted and Snowbird Gad Valley the availability habitat in the area, the effects of this cumulative action would Improvements not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area. Corkscrew Project Tree removal associated with this project impacted a small amount of flammulated owl habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area. Ballroom Traverse Tree removal associated with this project impacted a small amount of flammulated owl habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area.

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Table 3-12 (cont’d). Special-status wildlife cumulative effects. Action Cumulative Effects Supreme Lift Replacement and Tree removal associated with this project impacted a small amount of Cecret Lift Removal flammulated owl habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area. Quincy Mine Water Tank This project did not impact any flammulated owl habitat. Replacement Albion Meadows Trail Reroute This project does not impact any flammulated owl habitat. Wildcat and Buckhorn Parking This project does not impact any flammulated owl habitat. Lot Improvements Rollercoaster Snowmaking Loop This project does not impact any flammulated owl habitat. This project has the potential to impact a very small amount of flammulated owl habitat along the existing Albion Basin Road. Given the small amount of Patsey Marley Shrontz Utility habitat impacted and the availability habitat in the area, the effects of this Right-of-Way cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area. This project has the potential to impact a very small amount of flammulated owl habitat along the cable alignments and launch and landing towers. Given the small amount of habitat impacted and the availability habitat in the area, Snowbird Zip Line Project the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact flammulated owl populations in the area. Northern Goshawk Various elements of this project have the potential to impact a small amount of northern goshawk habitat. Given the small amount of habitat impacted and Snowbird Gad Valley the availability habitat in the area, the effects of this cumulative action would Improvements not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area.

Corkscrew Project Tree removal associated with this project impacted a small amount of northern goshawk habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area.

Ballroom Traverse Tree removal associated with this project impacted a small amount of northern goshawk habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area.

Supreme Lift Replacement and Tree removal associated with this project impacted a small amount of Cecret Lift Removal northern goshawk habitat. Given the small amount of habitat impacted and the availability habitat in the area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area.

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Table 3-12 (cont’d). Special-status wildlife cumulative effects. Action Cumulative Effects Quincy Mine Water Tank This project did not impact any northern goshawk l habitat. Replacement Albion Meadows Trail Reroute This project does not impact any northern goshawk habitat. Wildcat and Buckhorn Parking This project does not impact any northern goshawk habitat. Lot Improvements Rollercoaster Snowmaking Loop This project does not impact any northern goshawk habitat. This project has the potential to impact a very small amount of northern goshawk habitat along the existing Albion Basin Road. Given the small Patsey Marley Shrontz Utility amount of habitat impacted and the availability habitat in the area, the effects Right-of-Way of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area. This project has the potential to impact a very small amount of f northern goshawk habitat along the cable alignments and launch and landing towers. Given the small amount of habitat impacted and the availability habitat in the Snowbird Zip Line Project area, the effects of this cumulative action would not interact cumulatively with the minor impacts of this project in any way that would substantially impact northern goshawk populations in the area.

3.4.3.5 Mitigation WIL-1: Construction and refueling helicopters operating during the nesting season (April–June) must approach, and depart, cliff areas from behind and above the cliffs to avoid flushing nesting falcons. WIL-2: Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no more than 10 days prior to commencing work. If no nests are found, project activities may proceed. If nests are found, contact the Forest Service permit administrator. 3.5 HUMAN ENVIRONMENT

3.5.1 CULTURAL RESOURCES

3.5.1.1 Scope of Analysis  How would the proposed infrastructure affect Cultural Concerns, Traditional Cultural Places (TCPs), or Native American Sacred Sites? Section 3.4.1.1 of Alta’s 1997 Master Development Plan Final Environmental Impact Statement (FEIS) states that “prior to European settlement the ski area was used by Native Peoples for both hunting and plant gathering in a lifeway that was otherwise tied to the more abundant resources of the adjacent Salt Lake Valley. This short-term use leaves little archaeological imprint, and few examples of Native sites remain anywhere in the canyon.” Nevertheless, the project area could hold values for Native Peoples that may be affected by the proposed action. Indicators: Government-to-government consultation with Native American Tribes of concern regarding this proposed action. Any concerns identified by the Tribes has been taken into account in analyzing the

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potential of the proposed development to affect cultural concerns, TCPs, or Native American Sacred Sites.  How would the proposed infrastructure affect historic properties? The clearing, grading, and excavation associated with construction of the proposed facilities could affect other historic properties (any cultural resource deemed eligible to the National Register of Historic Places, both prehistoric and historic) in or around the project area. Indicators: Assessment of the potential for any ground disturbing activity to affect Historic Properties (i.e., any cultural resource deemed eligible for the National Register of Historic Places, both prehistoric and historic).  How would the proposed infrastructure affect the historic integrity of the ski area? Alta was the site of intensive mining activity from the late 19th and early 20th centuries, and it is also one of the oldest continuously operating ski areas in the nation, with the first tow installed in 1939. While most of the historic infrastructure has been removed or replaced, the clearing, grading, and excavation associated with construction of the proposed facilities could further affect the resort’s historic integrity. Indicators: Assessment of how well the ski area currently reflects its long history and how the proposed development would affect its historical integrity.

3.5.1.2 Affected Environment In 2015 and 2016, the proposed action was reviewed in accordance with Forest Service procedures for compliance with section 106 of the National Historic Preservation Act (NHPA). A review of past records was conducted, and areas potentially affected were surveyed on the ground. Reports were prepared and submitted to the SHPO for review, and the SHPO provided letters of concurrence with the reported findings. This analysis summarizes the finding of those reports (USU Archaeological Services 2015, 2016a, and 2016b). Native American Concerns The project area lies within the traditional homeland of the Ute and Western Shoshone. Locally, the area was the traditional home range of the Cumumba, or Weber Ute, who settled the Weber River Valley and south to present day Salt Lake City. Further south was the home range of the Tϋmpanogots who settled the Wasatch Range centered around Mount Timpanogos and along the shores of Utah Lake, including the river canyons of the Spanish Fork, Diamond Fork, Hobble Creek, American Fork and Provo Rivers. North and west were the Western Shoshone bands of the Hukundϋka (“fish eaters”) and Tubadϋka (“pine nut eaters”), respectively. The home ranges during the contact period likely had been in place for generations, with home ranges (or districts) defined in large part by kinship and band affiliation. It was also quite fluid based upon season of the year and who was living with whom. The introduction of the horse and access to Euroamerican trade items probably had the greatest influence on mobility and subsistence. Prior to the adoption of the horse, transportation of people and goods occurred on foot and was likely more restrictive. Mobility and subsistence were intricately meshed to seasonal availability of plant and animal resources. Diets in the Great Basin and Colorado Plateau were diverse ranging from insects, such as grasshoppers, to bison. Over 150 vegetable foods have also been identified. Beginning in the 1840s with emigrant travel to the west coast and settlement by members of the Church of Jesus Christ of Latter Day Saints (Mormons), the traditional home ranges and lifeways of the Shoshone, Utes, and other western tribes came under assault. The introduction of grazing cattle and horses put increasing pressure on a fragile ecosystem that often resulted in violence against native groups

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and emigrants. Two decades of persistent violence culminated with the massacre of over 250 Shoshone on 29 January 1863 with the Bear River Massacre. In all practical ways, this brought an end to the traditional lifeways of these western tribes. Historic Properties Little Cottonwood Canyon played an important role in the historic development of the Salt Lake Valley. Economic resources including lumber, stone, and mineral resources first drew Euroamerican exploration and use of the canyon beginning in the early 1850s. For example, granite quarried from Little Cottonwood Canyon went to build both Salt Lake City’s Mormon Temple and the Utah Capitol Building. Additionally, lumber resources from the canyon were instrumental in the construction of buildings in Salt Lake City and the surrounding communities. Mining and prospecting in the Little Cottonwood Canyon began during the early 1860s. Following the discovery of ore in Big and Little Cottonwood Canyons, miners organized into mining districts. These districts changed shape and size through the early years as prospectors located new ore deposits. The districts included the Wasatch Mountain Mining District (1863 to circa 1864), Mountain Lakes Mining District (1864 to 1871), Cottonwood Lakes Mining District (1868 to 1869), and finally Little Cottonwood Canyon Mining District (1869 to present). By 1871, the community of Alta was formed at the location of steam sawmill owned by the Emma Silver Mining Company. Alta attained a population of 5,000 with stores, hotels, three breweries, six sawmills, one newspaper, and a mule-drawn railroad. The town quickly became notorious for violence, prostitution, drinking, gambling, as well as for the numerous avalanche and mining disasters that plagued the community. Mining activities expanded in Little Cottonwood Canyon in 1871 when the Utah Central Railroad (between Ogden and Salt Lake City) built the Sandy Terminal. The following year the Wasatch and Jordan Valley Railroad Company began constructing a narrow-gauge railroad line connecting the Sandy Station to Little Cottonwood Canyon, specifically the Wasatch area. In 1873, the first locomotive use of the line began to transport granite from Little Cottonwood Canyon to the construction site of the Mormon Temple. In 1875, eastern investors purchased the Wasatch and Jordan Valley Railroad with the goal of continuing locomotive rail service to Alta. However, the route from Wasatch to Alta was too steep for locomotives of the day. The last leg of the rail line to Alta required the use of carts pulled by packhorses and mules. The railroad soon became so important to mining operations and the occupants at Alta that, beginning in 1876, a series of resilient wood snow sheds were built covering the tramway to protect the route from damages caused by the frequent avalanches. By 1913, the railroad from the Sandy Station to Wasatch was replaced by the Salt Lake and Alta Railroad Company’s line. The purpose of this new railroad was to transport granite for the Utah Capitol Building. In 1915, the Alta-Cottonwood Railroad Company began to replace the narrow-gauge railroad from Wasatch to Alta. This newly constructed railroad could handle locomotives but not heavy freight carts due to steep grades and sharp turns. By 1928, the Alta-Cottonwood Railroad was out of service. Soon thereafter (1934), the Salt Lake and Alta Railroad Company’s railroad was abandoned. Abandonment of railroad service coupled with the Great Depression mining activities effectively signaled the decline of the mining industry in the Little Cottonwood Canyon. Alta Townsite almost became a ghost town when mining activities ended in Little Cottonwood Canyon. At the same time, public interest in winter time recreational activities began to increase and was promoted by local recreational groups and various government entities (e.g., Chambers of Commerce, city and county governments) as a means to stimulate the economy. By 1936, enough interest developed that the Salt Lake City Winter Sports Association (later named Alta Ski Lifts Company) was formed through a

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collaboration with skiers, tourists, businessmen, and investors to support and promote local winter sports. In the 1930s, a large portion of Alta was converted into the base facilities for the ski area complex. Most of the original buildings have been destroyed for development of new facilities within both the ski area and the town of Alta. Nevertheless, the Forest Service has made the determination that the Alta Townsite is eligible for the National Register of Historic Places. The Utah SHPO concurred with this determination in 2016. Substantial archaeological research on the site has not been conducted, but cursory research and pedestrian archaeological survey to date suggests that there are likely buried artifacts and features of Alta’s mining history within the site that could add to the historic era knowledge of the area. Ski Area’s Historic Integrity The first ski lift (Collins Lift) was built at Alta for the 1938-39 winter ski season, though frequent delays and malfunctions hampered its use. The ski area continued to grow, and by the end of WWII, facilities included the Rustler lift, Peruvian lift, Collins lift, and various buildings including the Watson Shelter, Rock Shelter, and the Alta Lodge. Though it maintains its reputation as a no-frills skiers’ mountain, Alta has continued to develop and upgrade its basic infrastructure. The only structure dating back beyond 50 years now is the Old Watson Shelter. It was determined to be eligible for the National Register of Historic Places in 2015. No other eligible structures remain. As a result, despite its long history, Alta’s historic integrity is low.

3.5.1.3 Direct and Indirect Effects No-Action Alternative Native American Concerns Under this alternative, the current situation regarding Native American concerns would be unchanged. The UWCNF consulted with representatives of area Native American Tribes, the Ute and Western Shoshone, in the course of previous NEPA reviews to ensure that no Tribal concerns were overlooked. No Tribal concerns about TCPs, sacred sites, Tribal resource gathering areas, or prehistoric archeological sites were identified. Historic Properties The situation would also be unchanged in terms of historic properties. Section 106 processes completed for past development identified only the historic Alta Townsite as an historic property. The townsite would not be affected under this alternative. As a result, no impact on historic properties is anticipated. Ski Area’s Historic Integrity As noted above, the historic integrity of the ski area is currently low. Older facilities have been replaced or upgraded, and little remains of early days of Alta skiing. The no-action scenario would be more of the same – basic operation and maintenance of the ski area infrastructure that has developed over time. The ski area’s historic integrity would not be affected. Proposed Action Native American Concerns As discussed above for the no-action alternative, no concerns have been identified by the Tribes, and representatives of these Tribes were notified again of this proposed action. No concerns were identified. As a result, no impact on these resources is anticipated. In accordance with design criteria 16, 17, and 18 (section 2.5), if any cultural resources, TCPs, sacred sites, or other resources of Tribal concern are encountered at the ski area, any action that could adversely affect them must cease, and the Forest Archaeologist must report the find to appropriate Tribal representatives and fulfill consultation requirements. These requirements would effectively mitigate any adverse effect on these resources.

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Other Historic Properties One element of the proposed action would be sited within the historic Alta Townsite – the Wildcat/Albion base area parking improvements. Work on the Wildcat parking lot would involve modified areas largely within the built lot or on a heavily disturbed adjacent area. As a result, it is unlikely to have any impact on the historic townsite. However, the proposed expansion of the Albion parking lot would involve some less disturbed areas (see Figure 2-2). These areas lie downslope from the existing parking lot and access road, and as a result they would be subject fill rather than excavation. “Burying the site” was identified as one way of “avoiding adverse effects” on the historic townsite in the SHPO concurrence letter (SHPO 2016). Accordingly, placement of fill material over a small, less-disturbed portion of the townsite should have no adverse effect. As no other adverse effects were identified, the same conclusion would apply to the proposed action as a whole. Design criterion 16 (section 2.5) calls for efforts to protect any buried resources encountered during construction until the Forest Service Permit Administrator is notified and the Forest Service fulfills its consultation requirements. However, in that this is a known, National Register-eligible site, monitoring by a qualified archaeologist during all ground-disturbing activities associated with expansion of the Albion parking lot would further mitigate potential adverse effects (section 3.5.1.5). Resort’s Historic Integrity As noted above, little remains from the early days of Alta skiing, and the ski area’s current historic integrity is low. Proposed action elements would not replace or alter any historic aspects of the resort, but would simply maintain and improve the infrastructure, as it has evolved to this point, in much the same way as the no-action alternative. The ski area’s historic integrity would not be affected.

3.5.1.4 Cumulative Effects Based on completed section 106 compliance processes, one of the cumulative actions listed in section 3.3 has the potential to cumulatively affect cultural resources in the project area. The relocated portion of the Albion Meadows hiking trail would pass through a new, eligible for listing mine site (Hecla Mine) discovered during the NHPA section 106 process addressing that project (USU Archaeological Services 2016c). That process reached the conclusion that as long as the new trail followed the existing user- created trail, any adverse effect could be avoided. However, the trail to be decommissioned passes through the Alta Townsite, creating the potential for adverse effects. Mitigation in the form of archaeological monitoring during trail construction through the site was suggested, and the SHPO concurred that this would provide added assurance. In regard to the other cumulative actions, the EA prepared for the Snowbird Gad Valley Improvements concluded that all elements of the selected alternative had been relocated to avoid any adverse effects on cultural resources (Forest Service 2013a; p. 126). The Patsey Marley Shrontz Utility Right-of-Way project is currently under analysis, but it lies outside the currently identified boundary of the Alta Townsite and thus would not affect any cultural resources directly or indirectly impacted by this proposed action. Section 106 processes have been completed for the Snowbird Zip Tour (USU Archaeological Services 2016d), the Corkscrew project (Forest Service 2015), the Ballroom Traverse (Forest Service 2013b), the Wildcat and Buckhorn parking lot project (USU Archaeological Services 2015), the Supreme lift replacement and Cecret lift removal (USU Archaeological Services 2015), the Quincy Mine project (USU Archaeological Services 2016c), and the Roller Coaster snowmaking loop (USU Archaeological Services 2016e). These concluded that either historic properties were not present or would not be affected. As a result, these projects pose no apparent potential for cumulative effects on cultural resources.

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3.5.1.5 Mitigation This analysis indicated the need for one mitigation measure: CUL-1: A qualified archaeologist will monitor all surface disturbing activities during all ground- disturbing activities associated with expansion of the Albion parking lot to avoid potential effects on the historic Alta Townsite.

3.5.2 SCENIC RESOURCES 3.5.2.1 Scope of Analysis  How would the proposed infrastructure affect the scenic integrity of the project area? The SUP area viewscape has been affected by intensive mining activity from the late 19th and early 20th centuries followed by 77 years of ski-area development, but at this point its visual character is generally natural. Additional infrastructure such as the proposed Baldy tram and Gazex installations could alter that character and detract from the area’s scenic integrity. Indicators: Analysis of effects using the method prescribed in the Forest Service Scenery Management System (SMS; Forest Service 1995b). Indicators are the degree of intactness of the landscape character and the resulting level of scenic integrity. The Forest Plan assigns Alta’s permit area the landscape character theme of Resort Natural Setting and the scenic integrity objective (SIO) of High. The analysis area is upper Little Cottonwood Canyon, beyond Hellgate on SR 210 and extending to the surrounding ridgelines to the north, east, and south. Key viewpoints from which effects are analyzed include SR 210, and the Wildcat and Albion base areas, the primary areas of concentrated use.

3.5.2.2 Forest Plan Direction Management direction in the 2003 Forest Plan includes the following Desired Future Condition regarding scenery management for Alta: Development will be designed with a high level of attention to scenic integrity, within the context of overall resort development. Facilities will be designed and constructed to harmonize with the natural setting, rather than to contrast with that setting. While developments in base areas will be visually dominant, that dominance will decline on the mountainsides and new development on ridgelines, beyond the levels approved at the time of plan revision, will be minimal. Special attention will be given to the scenic integrity of views from backcountry and wilderness trails. Non-winter recreational opportunities provided in base areas will rely more heavily on constructed facilities, while those higher on the mountain will become increasingly oriented toward the natural setting. (P. 4-161.) The Forest Plan describes five landscape character themes, including landscape character descriptions and SIOs applied to the WCNF. These allocations are applied using the SMS framework and criteria in conjunction with adjustments for local management direction. For Management Prescription 4.5 – Developed Recreation Area, the landscape character theme is “Resort Natural Setting”: This landscape character theme is characteristic of developed recreation facilities such as ski resorts and recreation resort communities. In these areas, recreation amenities are the main attraction for people and why they come to an area. Facilities are designed and constructed to harmonize with the natural setting. While the form of the base area facilities dominate the foreground views, it declines as it transitions into the mountain and becomes subordinate in the middleground and background views. Likewise, recreational opportunities provided in base areas rely more heavily on constructed facilities, while those higher on the mountain become increasingly oriented toward the

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natural setting. This landscape character is adjacent to Natural Evolving, Natural Appearing and Developed Natural Appearing landscape character themes and should draw from, complement and harmonize with these themes. (P. 4-99.) Within this theme, recreational amenities are an expected and desired landscape component. The SIO is High at ski resorts because architectural amenities are designed and maintained to complement and harmonize with the natural-appearing landscape. The Forest Plan describes the desired conditions within resort boundaries emphasizing how the dominance of the built environment in the base area should decline and become more subordinate in the middleground and background views as the scene transitions up the mountain.

3.5.2.3 Built Environment Image Guide The Forest Service Built Environment Image Guide for National Forest and Grasslands (BEIG; Forest Service 2001) provides direction to help ensure that buildings, other structures, and all constructed infrastructure installed, operated, or authorized by the Forest Service “incorporate[s] the principles of sustainability, reflect their place within the natural and cultural landscape, and provide optimal service to our customers and cooperators.” It employs the natural setting of specified geographic provinces to outline architectural guidelines for design and construction within each province. Alta lies in the Rocky Mountain province. Guidelines are summarized as, “include overscaled building elements, such as oversized doors and windows, heavy timber structures, and boulders incorporated into the building base…” to “help humans relate to the overpowering scale of the landscape,” and “make the scale, color, and texture of materials correspond to the setting.” Any given developed site should reflect a consistent architectural theme. Alta created its own site specific BEIG, tiered to the FS BEIG for the Rocky Mountain Province, to guide development of the future built environment within the Alta permit area. The site-specific BEIG incorporates practical elements of the overall direction but tailors them to meet Alta’s conditions. Alta’s area-specific BEIG (Forest Service 2012c) provides design guidelines outlining specific materials and design practices typical of Alta architecture to be incorporated in future facilities, ensuring a more consistent theme over time. The BEIG notes that Alta “is changing from the architectural character of the existing facilities constructed between the 1950’s and 1990’s with the wood siding and sloped roofs to a more functional, durable and modern architectural style which includes flat roofs, concrete, stone and glass facade elements.” The following effects analysis cites area-specific BEIG guidance, along with Forest Plan direction, as appropriate.

3.5.2.4 Affected Environment Alta’s viewshed is limited. The ski area lies at the top of Little Cottonwood Canyon, just beyond the point that the east-west oriented canyon turns south. From Salt Lake Valley, the canyon bottom, and SR 210, Alta is screened by terrain until visitors round the corner at Hellgate, between Snowbird and Alta. Portions of the ski area are visible from higher elevations on the ridge separating Little and Big Cottonwood canyons. A small portion of the ski area’s upper elevation is visible from Mt. Superior, in the Twin Peaks Wilderness, but beyond that other wildernesses are not affected. In practical terms, Alta is visible only to people visiting Alta and Albion Basin. In terms of assessing Alta’s scenic character, the UWCNF adopted SMS in the 2003 Forest Plan. SMS accommodates human elements into the viewscape, particularly in the Resort Natural Setting landscape character theme assigned to the resort. Development at the resort to date has been designed in consideration of the site’s scenic resources and the landscape character is reasonably intact (Figure 3-2). The natural setting is characterized by the steep and rocky peaks over 11,000 feet and jagged, connecting ridgelines typical to the Central Wasatch. Mining and grazing peaked roughly a century ago, leaving the

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slopes bare of trees for the most part. Forest vegetation has recovered to a degree, but trees are generally restricted to lower slopes and deep-soiled draws. Bare rock cliffs, outcrops, and the scree fields below them dominate the high elevations. Snow dominates the natural landscape during winter and is present in the viewscape much of the remainder of the year. Ski area facilities are concentrated in the two base areas and dominate the foreground view from those vantage points. Buildings for food and other skier services, administration, and maintenance were designed and built over several decades, resulting in a variety of architectural styles rather than a consistent theme. Development since 2012 has followed the area-specific BEIG, resulting in a more consistent theme since that date. Parking lots may be the most visually striking features, looking down on them from SR 210. The Wildcat lot does not follow natural contours or include vegetated strips to break up its geometry. Private-land residential and commercial development – the Town of Alta – connects the base areas but is concentrated around the Wildcat base, particularly to the west of it. There is little consistence in architecture or materials in the private-land development. While private-land development is not subject to Forest Service management direction or part of the base line for this analysis, it is an important component of Alta’s landscape character and provides visual context for the permit area.

Figure 3-2. Alta ski area.

Constructed facilities on the mountain are more dispersed. The two on-mountain lodges, the Watson Shelter and Alf’s restaurant, are screened from all but nearby vantage points by topography or vegetation, and their siting, scale, design, and materials make them blend effectively. As evident in Figure 3-2, ski

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runs and lift corridors were generally laid out and cleared in a manner that blends with avalanche paths and other elements of the natural setting. Upper lift terminals are mostly below the skyline, though the tops of Sugarloaf and Supreme lifts are on ridgelines. Their distance, placement, and color make them visually subordinate in the middleground and background from the base area vantage points and SR 210. Overall, to the casual observer, the ski area infrastructure generally blends with the natural setting in terms of form, line, color, texture, and pattern. The Resort Natural Setting landscape character is reasonably intact, but the diverse architecture and the rectangular Wildcat parking lot deviate from it. However, the entire ski area is being managed to have a High SIO as a desired condition.

3.5.2.5 Direct and Indirect Effects No-Action Alternative Not implementing the proposed action would have some minor effects on landscape character at Alta. Without the proposed parking lot improvements, parking on busy days would continue to be less orderly than desired, particularly in the Albion area. Curbing and paint lines would not be in place, so once the main lots were full, visitors would continue to park wherever and however they could, including along lot edges and road shoulders. This would result in a jumbled appearance and would damage adjacent vegetation. These effects would be generated by lower skier numbers at the Albion base area without the additional spaces shifted from Wildcat. Alf’s restaurant would continue to have a more cluttered appearance due to the temporary building housing the ski demo center, entryway crowding, and obstacles to snowcat grooming around the facility. Overall, the Resort Natural Setting landscape character would remain largely intact, with visible deviations due to the variety of architectural styles dating back to the 1950s and the rectangular, undivided Wildcat parking lot. Scenic integrity would continue to be managed for a High SIO as a desired condition. Proposed Action Generally, implementation of the proposed action would affect the area’s landscape character in ways similar to the ski area development that has occurred over the past 78 years. Some projects would maintain the more natural aspects of the landscape character (e.g., consolidating functions in the Alf’s restaurant addition). Some would have negligible visual effects (e.g., the Flora lift, summer trail work, lift replacements, and the Watson Shelter addition), and some would increase the built aspect of the landscape character. These projects include:  The Albion base parking lot changes.  The Baldy tram.  The Flora lift.  Gazex installations on Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley.  The equipment storage facility at the Albion base area. As discussed under Affected Environment, the base area parking lots, viewed from above on SR 210, are visually dominant features, particularly the Wildcat lot. Expansion of the Albion lot by about 1.3 acres, or 29 percent, would increase the visual impact of that lot. However, the Albion lot currently conforms to natural contours, and the proposed expansion would not alter that. It would continue to harmonize reasonably well with the natural landscape. Beyond that, the lot is in a base area, where the Resort Natural Setting landscape character theme recognizes that facilities are visually dominant. The Baldy tram, or specifically the top terminal, would not be visible from either base area, but it would be seen from SR 210 through the Town of Alta at a distance of 1.5 miles. It would be clearly visible only from the mid to upper reaches of the Collins and Wildcat pods. Siting the terminal 90 vertical feet (340 horizontal feet) below the ridgeline, north of the peak of Mt. Baldy just above the Perla’s area of Baldy

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Chutes, would shield it from view from western vantage points, including Hidden Peak at Snowbird and down-canyon locations, as well as from the south (i.e., American Fork Canyon) and the east, including Albion Basin and beyond. Despite the tram terminal’s limited viewshed, it would likely be visible from Mt. Superior, in the Twin Peaks Wilderness, a visually sensitive viewpoint according to the Forest Plan. That would be a distance of 2.4 miles. While it would not be visible from the popular Albion Meadows trail, it would be visible from the Cecret Lake and Catherine’s Pass trails above their Albion Basin trailheads. The terminal would be a simple structure, basically a bull wheel and landing platform with associated rigging. There would be no building associated with it, and the materials would be concrete and steel. Galvanizing is standard practice at Alta, so the structure would blend with the natural setting. Overall, based on the terminal’s siting, form, and colors, it would be consistent with the landscape character theme’s criteria for infrastructure high on the mountain, in the background. The top terminal of the proposed Flora lift would be near the ridgeline between Collins Gulch and Albion Basin, roughly 500 feet north of Germania Pass. While this location is near a ridgeline, it is a secondary ridge about 650 feet below Mt. Baldy. As a result, the terminal would not be visible from either base area or from SR 210 due to topographic screening. It would be visible from Mt. Superior, in the Twin Peaks Wilderness, at a distance greater than 2 miles. The Forest Plan directs that ridgeline development be “minimal.” Based on the limited viewshed of this terminal and the fact that only the Supreme and Sugarloaf top terminals are on ridgelines, this project would be consistent with that direction. The Gazex project calls for four to eight exploder installations at each of three sites: Sugarloaf Mountain, East Devil’s Castle, and Patsey Marley. Each exploder is a 24-inch diameter, J-shaped, galvanized steel tube about 16 feet long extending at roughly a right angle from the rock face, with a support leg on a 4- foot-by-4-foot concrete base. One small gas storage unit (about 8 feet by 8 feet) would be installed for every four exploders. Buried lines would convey gas from the gas storage units to the exploders. The Sugarloaf and Patsey Marley installations would be within the field of view from the Albion base area, and the Patsey Marley installations would be in the field of view from the Wildcat base. All three would be in the viewshed from various places on the Albion Basin road, and extension of SR 210. Several factors would make them blend with the natural landscape:  Distance. The installations would be from 0.75 to 1.75 miles from the nearest base area. This alone would make objects of this size difficult for the human eye to discern.  Color and texture. The exploder tubes and gas storage units would be acid etched to blend with the natural background.  Form and line. The installations would exhibit a mixture of tubular and rounded rectilinear forms and straight lines, curves, and angles that, given their variety and relative size in the natural landscape, would blend in sufficiently.  Location: The gas storage unit for the Sugarloaf installation would be on the opposite side of the ridge, above Mineral Basin, where it would be indistinguishable from the rocky background. Based on these considerations, the Gazex installations would be consistent with the landscape character theme’s criteria for infrastructure high on the mountain as they are intended to blend into the background. The equipment storage building would be constructed in the maintenance area adjacent to the Albion base area, just off the northwest corner of the shop in a cleared area currently used to store snow plowed from the parking lot. The Albion Grill is nearby, and roads bracket both sites. The 6,000-square-foot structure would be architecturally basic but would comply with Alta’s emerging architectural character and reflect pertinent area-specific BEIG design guidelines. It would be angular and

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flat roofed, incorporating stone and metal fascia, and its colors would be earth tones – gray, brown, or green. Within these BEIG parameters, it would blend with the adjacent vehicle maintenance shop. It would comply with the BEIG siting recommendation to locate buildings on previously developed sites and would be consistent with adjacent buildings. It would be consistent with the Resort Natural Setting theme where visually dominant structures are an anticipated base-area feature but should harmonize with the natural setting. Overall, based on this analysis, the proposed action is consistent with the Resort Natural Setting. It would not alter either the architectural variety at the ski area or the visual impact of the Wildcat parking lot, so the Resort Natural Setting landscape character would remain reasonably intact, and scenic integrity would continue to be managed for a High SIO as a desired condition.

3.5.2.6 Cumulative Effects All of the projects described in section 3.3 have some potential to interact cumulatively with the scenic effects of the proposed action. The Wildcat and Buckhorn parking lot project, Albion Meadows trail re- route, and several of Snowbird’s Gad Valley improvement projects would contribute to developed character of upper Little Cottonwood Canyon’s resort base areas. The Corkscrew project, Supreme replacement and Cecret removal, Quincy Mine project, some Snowbird Gad Valley improvements, and the Snowbird Zip Tour would affect middleground views. The Ballroom Traverse, Roller Coaster snowmaking, and the higher elevation Gad Valley improvements at Snowbird would fall in background views. All would add to the effects of ski area development that began in the 1940s, as the visual impact of decades of mining was beginning to heal. These cumulative effects must be assessed in the same terms as direct and indirect scenic effects – in accordance with Forest Plan direction. Structures in base areas would become marginally more dominant, as anticipated in the Resort Natural Setting theme, but they would continue through design, siting, and material selection to harmonize with the mountain setting. The on-mountain effects would remain less visually dominant, blending more with the natural setting. Overall, the cumulative effects would be consistent with the landscape character theme and the scenic integrity of upper Little Cottonwood Canyon ski areas.

3.5.2.7 Mitigation This analysis suggested the following mitigation for the Gazex installations: SCE-1: Acid etch the exploder tubes and gas storage units to blend with the natural background. Beyond that, no needs for additional mitigation of scenic effects were identified as long as the projects are completed as described in Chapter 2, with the listed design criteria in place (section 2.5).

3.5.3 RECREATION

3.5.3.1 Scope of Analysis  How would the proposed infrastructural development affect skier density and circulation? Changing the types and configurations of lifts could adversely affect skiers’ experience at Alta. Specific concerns noted by commenters are: - Higher-capacity lift upgrades may increase crowding on ski runs. - Eliminating the hike to Mt. Baldy with the tram may reduce its attraction. - The Baldy tram’s lift line and the top terminal of Flora lift may interrupt skier traffic at Germania Pass.

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Indicators: Case-by-case assessment of the proposed infrastructural development will address these specific concerns.

3.5.3.2 Affected Environment Lift Upgrades and Skier Density Alta’s hallmark is uncrowded skiing on minimally developed terrain. Skier density is generally significantly lower than industry standards. One important tool the ski area uses to maintain low density is adjustment of the speed at which they operate lifts. For instance, when there is sufficient snowpack, and avalanche control work has been completed, or when avalanche activity is minimal, most of the permit- area terrain is in skiable. Under these conditions, running the lifts at higher speed puts more skiers on the mountain faster, and the ample terrain accommodates them without crowding. At the other extreme, when there is insufficient snowpack, or when there are extensive terrain closures, lift speed is dropped to avoid higher density. Skiers wait in line longer but get a less crowded experience in return. Due to their easy loading and unloading, modern detachable lifts provide much more flexibility to balance uphill and downhill capacity in this way. Two specific areas at Alta have been identified as routinely having higher skier densities: the last steep drop to Wildcat base area from Collins Gulch, and the skiway off the main run on Sugarloaf formerly known as Glory Hole cat track. The Corkscrew grading project, completed 2 years ago, substantially alleviated the first problem. Widening of the cat track – now known as Wide Track – reduced but did not eliminate high skier densities at the second problem area. Attraction of Mt. Baldy Mt. Baldy lies on the Alta/Snowbird boundary and offers primarily hike-to terrain from both ski areas. Due to high avalanche hazard and limited options for avalanche control, Mt. Baldy is rarely open to the public. On the Alta side, this terrain ranges from the experts-only Mt. Baldy Chutes to quality intermediate terrain like East Baldy and Livin’ the Dream. When the peak is open, up to several hundred people per day hike to the top to ski the chutes or other runs, but because of the prevailing avalanche closure, Mt. Baldy is lightly used. Undoubtedly, the rare hike to the top limits use and is part of Mt. Baldy’s attraction to some skiers. Germania Pass Circulation Germania Pass is the on-mountain crossover point between the Albion and Wildcat sides of ski area, and it can be a congested place. The main lift from Wildcat base area, Collins lift, delivers skiers to the pass, as does East Baldy Traverse from the top of Sugarloaf lift. From the pass, skiers staying on the Wildcat side drop onto Ballroom Traverse, High Main Street, Mambo, and the High Traverse. To go to the Albion side of the pass, skiers can take Devil’s Way. The pass is about 450 feet wide. Collins lift and entries to each of the noted runs and traverses are spaced along it.

3.5.3.3 Direct and Indirect Effects No-Action Alternative Lift Upgrades and Skier Density Under this alternative, lift capacities would remain unchanged, as would skier densities in general. However, as older lifts became less reliable, down time would likely increase. As a result, skiers would either wait longer in line for stopped lifts or move to other lifts and terrain, increasing density in those alternative pods.

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Attraction of Mt. Baldy Under this alternative, no lift would be installed on Mt. Baldy. Avalanche control would continue to be difficult, so closure would remain the norm. On days when the peak was open, those willing to make the hike to the summit would enjoy a unique, backcountry-type experience skiing extreme terrain within 1,500 feet of a chairlift. Germania Pass Circulation Without the Flora lift, skiers coming to the pass from the Albion side would continue to use East Baldy Traverse. Skier traffic on the traverse merges head-on with skiers getting off the Collins lift. This would continue to create congestion on the pass. Proposed Action Lift Upgrades and Skier Density Under this alternative, the Sunnyside lift would be upgraded to a chondola (i.e., both chairs and gondola cabins) or alternative, more modern design, allowing for summer/non-skier use. Design capacity of the existing lifts is about 2,500 pph, while the chondola is slated for 2,400 pph. In light of the discussion above about adjusting lift speed to match terrain availability, this difference does not translate to a notable change either way in uphill capacity or a threat of crowding on the slopes. The other lift upgrade would be more substantial. Wildcat lift would be upgraded from a fixed-grip double rated at 1,200 pph to a fixed-grip or detachable quad with design capacity of up to 2,400 pph. The comfort and convenience of a detachable lift could result in more people riding Wildcat. However, given the degree of overlap between the Wildcat and Collins pods, many of these riders would simply be choosing to use Wildcat rather than Collins, which would not affect skier density in the combined pods. Wildcat also provides redundancy, allowing use of the Wildcat area when Collins is not operating for mechanical reasons or because of high avalanche hazard in the upper reaches of the Collins pod. In either case, Alta would continue to adjust operating speeds to ensure desired skier densities. The new higher- capacity lift would give them increased flexibility to keep the Wildcat area in use and to manage skier density ski-area wide. Another new lift, the Flora lift, would be a 1,200-pph fixed-grip double used primarily as a transit lift rather than a skiing lift. It would replace the difficult-to-maintain East Baldy Traverse as the main way to cross from the Albion area to the Wildcat area. This could marginally increase the number of skiers making this shift, which in turn would decrease density in the more heavily used Albion area. The last new lift would be the Baldy tram. While its primary function is to transport snow safety personnel to the top to conduct avalanche control activities, the tram could be opened for public use when snow and weather conditions were appropriate. It would be a low-capacity lift – about 150 pph – but it would provide the first lift access to Mt. Baldy terrain. As noted above, this is popular hike-to terrain that gets tracked up quickly on powder days. Public use of the tram would hasten that process, but given the lift capacity and the amount of terrain available, crowding would not be a serious threat. In addition to lift upgrades and new lifts, this alternative includes a trail project that would alleviate the potential for increased skier density on Big Dipper run once the Supreme lift upgrade was complete. This project, referred to as the Supreme summer trail work, includes two projects for creating summer- groomable, intermediate runs down from Supreme. The first project is widening the existing Devil’s Castle service road. The second is to develop a new graded ski run starting in the Challenger area, moving skier’s left through the re-contoured erosion gullies, and hence down Sleepy Hollow to lower Big Dipper. This would alleviate crowding on upper Big Dipper and make the Supreme pod more functional overall. Collectively, these lift upgrades and additions would make skier dispersal more efficient, leading to more uniform use of available terrain. While skier densities could increase somewhat in localized areas, such as

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Mt. Baldy and the runs off Peruvian Ridge that are accessed most easily by Wildcat lift, the overall effect would be more efficient management of skier density ski-area wide. Attraction of Mt. Baldy It is uncertain under what circumstances the tram from Germania Pass to the top of Mt. Baldy would be open to the public, or how often those circumstances might occur. With the tram providing ski patrol access for much improved avalanche control, Mt. Baldy would open more frequently. Once ski patrol access needs were met and the peak was open, the tram would probably be opened to the public. Despite its low capacity (proposed 150 pph), the tram would likely add to the number of skiers on the mountain on open days. The combination of more open days, more skiers on the mountain when it was open, and the option of lift access rather than a hike would undoubtedly detract from the experience of those who have appreciated the rare opportunity to hike and ski the peak in the past. Germania Pass Circulation The bottom terminal of the Baldy tram would be at the southern end of Germania Pass, south of the lower end of East Baldy Traverse, and south of the upper ends of Main Street and Ballroom Traverse. Circulation space would be limited, so the loading maze would need to be kept close to the terminal and out of the way. This is an operational issue of the type that ski areas deal with routinely, but several facts mitigate the potential constraint. First, the tram will often not be open to public use, so no maze will be necessary. Second, with a capacity of 150 pph, the lift will not require a large maze when it is open to the public. Third, managing such circulation issues are a routine aspect of ski area operations, and signage and rope lines should be sufficient to maintain adequate circulation. The top terminal of the Flora lift would be beyond the other end of the pass, about 300 feet north and up the ridge from the Collins lift top terminal. Overall, this arrangement should improve rather detract from skier circulation at Germania Pass. First, the lift terminal would be out of the way. Second, the lift would add redundancy to the East Baldy Traverse in conveying skiers from the Sugarloaf pod to the Wildcat side. Skiers wishing to make that shift would cross Germania Pass in any case. Third, skiers unloading from the Flora lift and heading for the Wildcat side would merge with the flow of skiers getting off Collins rather than approaching from the opposite direction as is the case with skiers coming off East Baldy Traverse. Overall, the tram maze could be managed to have little or no effect on circulation at Germania Pass, and the Flora lift should improve it somewhat.

3.5.3.4 Cumulative Effects Lift Upgrades and Skier Density Several of the projects discussed in section 3.3 would have positive cumulative effects in terms of skier density. The Corkscrew project increases skier flow through a typically congested area above the steeper drop into the Wildcat base area. Similarly, the Ballroom Traverse improvements reduce congestion on Germania Pass and improve access to another underutilized area. The Supreme lift replacement project increased lift access to an underutilized portion of the ski area, reducing density elsewhere on the mountain. Rollercoaster snowmaking will improve skier circulation and distribution through an existing bottleneck when natural snow cover is lacking. Attraction of Mt. Baldy None of the actions described in section 3.3 would have any discernable effect on this issue, so there is no potential for a cumulative impact.

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Germania Pass Circulation The only project in section 3.3 with the potential to interact cumulatively with the proposed action in terms of this issue is the Ballroom Traverse improvements. Making it easier for skiers to access the Ballroom area from Germania Pass reduces congestion on the pass, a positive cumulative effect.

3.5.3.5 Mitigation This analysis suggested the following mitigation for potential skier density increases: REC-1: Alta will continue to operate lifts at speeds that are appropriate for the conditional capacity of the terrain, regardless of the design capacity of the lifts.

3.5.4 SAFETY

3.5.4.1 Scope of Analysis  Does lift access to Mt. Baldy pose a safety risk?

Some of the runs on Mt. Baldy, such as the Baldy Chutes, are experts-only terrain that must be hiked to now, which limits use. The tram may result in skiers without the requisite skills attempting to ski this terrain and being injured. Indicators: Qualitative assessment of conditions under which the tram would be open for public use and the practices Alta would implement to limit access to hazardous terrain.  Would sympathetic avalanche releases from proposed Patsey Marley Gazex installations pose a safety risk for backcountry skiers in Wolverine Cirque?

Wolverine Cirque lies on the other side of Patsey Marley ridge from Alta. It is one of the more heavily used backcountry skiing venues in the Wasatch due to its easy access from Alta and Brighton. The proposed Gazex installations on the Alta side of Patsey Marley could potentially trigger avalanches on the other side, posing a risk to backcountry skiers. Indicators: Qualitative assessment of the risk of Gazex installations triggering sympathetic releases across the ridge.

3.5.4.2 Affected Environment Mt. Baldy Mt. Baldy offers popular hike-to terrain, accessible primarily via a boot-pack track up the east ridge from Sugarloaf lift at Alta and Baldy Express at Snowbird. Another track up the southwest ridge provides access from Snowbird’s tram. The north-facing Baldy Chutes are expert terrain. After snowstorms, Alta’s first focus on Mt. Baldy is opening the chutes to protect popular lower-angle terrain below, and lines of skiers form in anticipation. Subsequent control efforts allow the rest of Baldy to be opened, and the entire peak is skied. As discussed above (sections 2.4.2.1 and 2.6), dependence on artillery and Avalaunchers makes avalanche control difficult and time consuming, so Mt. Baldy is generally closed for much of the season. Nevertheless, demand for Mt. Baldy’s experts-only terrain is high. Wolverine Cirque Wolverine Cirque is a large, steep bowl on the north side of Mount Wolverine. Backcountry skiers most often access the peak from Brighton’s Millicent lift or up Grizzly Gulch from Alta. The cirque’s high angle chutes provide some of the most technically difficult and hazardous terrain in this popular touring area. High avalanche hazard further limits its use until the snowpack becomes stable. Spring conditions initiate an increase in use.

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The western side of the cirque is across the ridge from the Patsey Marley area where Gazex avalanche control systems are proposed. Currently, Alta conducts conventional avalanche-control activities on Patsey Marley under a special-use permit specifically for this purpose. Avalaunchers and occasionally helicopter-delivered explosives are used to target defined starting zones. This provides protection primarily for Alta’s most extensive beginner terrain, the Crooked Mile run, and the Sunnyside and Albion lifts that serve it.

3.5.4.3 Direct and Indirect Effects No-Action Alternative Mt. Baldy Under this alternative, safety issues on Mt. Baldy would not change. The lack of efficient ski patrol access to the top would continue to slow avalanche control operations necessary to open Baldy Chutes and the rest of the mountain. Once control work was done, skier safety would depend, as it does now, on skier education, rope lines, and signage. Skiers capable of hiking up Mt. Baldy would continue to face the inherent risk associated with that type of terrain. Wolverine Cirque Avalanche-control activities on Patsey Marley and the effect they have on the safety of Wolverine Cirque skiers will remain unchanged. The cirque’s inherently high avalanche hazard will limit use until conditions stabilize naturally. In order to hasten the natural stabilizing process on Patsey Marley, Alta will continue to use explosives delivered by Avalaunchers or helicopters. Given the distance from Patsey Marley starting zones to those in the cirque, the intervening ridge, and the nature of the explosives use (i.e., energy applied to the snow surface), impact on Wolverine Cirque from Patsey Marley avalanche control is currently minimal. Proposed Action Mt. Baldy The proposed project of concern is the Baldy tram. While the purpose of this low-capacity (i.e., roughly 150 pph) lift is to transport ski patrol personnel conducting avalanche control operations, it will be used by the public when 1) Baldy terrain is open, and 2) there is capacity available beyond ski patrol demands. As a result, public use of the inherently dangerous Baldy Chutes could increase, with a corresponding increase in the likelihood of injuries. This is a safety management issue with which Alta has decades of experience. Skier education, closures, rope lines, and signage have all been incorporated into an effective risk-management system at Alta, and lift access to Mt. Baldy would not be a qualitative change in the demands on that system. Skiers are always instructed to follow the Skier Responsibility Code, and the terrain on Mt. Baldy would be managed the same way other “most difficult” terrain is. The tram would also have download capability, providing a way down for skiers who reach the summit and change their minds. That option does not currently exist. Overall, the increase in injury risk posed by the Baldy tram would be minor and manageable, and it would be offset by the greater speed and efficiency of avalanche control operations made possible by the tram. Wolverine Cirque The issue here is whether the proposed Gazex avalanche control systems would increase the avalanche risk to skiers in Wolverine Cirque. As discussed above under Affected Environment, Alta has undertaken avalanche control operations on Patsey Marley for decades with no notable effect on snow safety in the cirque. The Gazex installations would function in much the same way as the Avalaunchers and helicopter- delivered explosives currently in use; all of these methods deliver similar amounts of tightly focused

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explosive energy to the snow surface in defined avalanche starting zones. As a result, the new, higher- tech systems should not differ in their potential effects on snow stability in the cirque. As discussed above, Wolverine Cirque is inherently avalanche prone, which limits skier use to periods of stable snowpack. If either the current or proposed avalanche control methods on Patsey Marley were to trigger a release in the cirque, it would be under conditions of extreme instability when skier use of the cirque was highly unlikely. Based on these considerations, the proposed Gazex installations on Patsey Marley would pose no increased risk to backcountry skiers in Wolverine Cirque.

3.5.4.4 Cumulative Effects Of the cumulative actions identified in section 3.3, only the Shrontz Utility Right-of-Way project has the potential for cumulative safety impacts. While the proposed Gazex installations on Patsey Marley would be further up the ridge and east of the Patsey Marley Hill subdivision, the more timely and efficient avalanche control provided by the installations could reduce avalanche risk to the subdivision. Reducing the risk to a larger number of people would be a positive cumulative effect. The Supreme lift replacement could marginally increase the number of skiers in Wolverine Cirque. While Supreme is not a major access point for the cirque, some skiers do hike north then west from Supreme to Mount Wolverine. The upgraded lift could increase the number of skiers choosing this option to access the cirque, but no notable change is likely.

3.5.4.5 Mitigation This analysis did not indicate the need to mitigate any safety impacts.

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CHAPTER 4: CONSULTATION AND COORDINATION 4.1 INTRODUCTION This chapter identifies the agencies and other entities consulted during the preparation of this EA. 4.2 PUBLIC SCOPING AND NOTICE AND COMMENT ON THE PROPOSED ACTION This proposed action would implement a land management plan and is not authorized under the Healthy Forest Restoration Act. As a result, it is subject to subparts A and B of the Project-level Predecisional Administrative Review Process (36 CFR 218). The UWCNF issued a public scoping notice summarizings Alta’ proposed improvement projects (the proposed action) and inviting comments regarding the scope of the associated NEPA review. The improvement projects included in the proposed action were described in detail in the Description of the Proposed Action: Alta MDP Improvements Projects which accompanied the scoping notice. The proposed action included 12 projects which Alta proposed to implement within the next five years. Three of the projects reflect relatively minor changes from the master development plan update (MDP update). The scoping notice was mailed to the agencies, organizations, and individuals on the UWCNF mailing list. The notice was also posted on the UWCNF website and made available on CD or in hard-copy form to anyone requesting it. The scoping period formally began on April 26, 2016, when the UWCNF’s legal notice was published in the Salt Lake Tribune (Newspaper of Record), and closed on May 26, 2016. Responses were received from 1 agency, 3 organizations, and 123 individuals. The scoping notice and responses are included in the project record. On January 10, 2017, the UWCNF issued a public scoping notice for the proposed replacement of the Supreme lift and associated removal of the Cecret lift and invited comments regarding the scope of the associated NEPA review. Two changes were made to this project in response to scoping comments received on the larger proposal and further field review of the lift site. First, Alta revised the alignment of the new Supreme lift to avoid potential wetland impacts and circulation concerns. Second, the UWCNF withdrew the project from the proposed action to authorize it separately. Theo F rest Service authorized this portion of the project under a categorical exclusion (CE), precluding it from more detailed NEPA review. The Forest Service concluded that there were no extraordinary circumstances relating to this portion of the project. The Decision Memo was signed on February 6, 2017. In accordance with the Forest Service’s Pre-Decisional Administrative Review Process (36 CFR 218), the UWCNF issued a Notice of Opportunity to Comment on the proposed action. The full-text preliminary EA was released for review and comment. The Notice of Opportunity to Comment was mailed to the agencies, organizations, and individuals on the UWCNF mailingt list. I was also posted on the UWCNF project website and made available on CD or in hard-copy form to anyone requesting it. The 30-day comment period began on October 20, 2017, when a legal notice was published in the Salt Lake Tribune, and closed on November 20, 2017. A total of 214 responses were received, including two from agencies, three from organization, and 209 from individuals. A report was prepared listing the name, address, response number, and comment topics for each response, then responding how each comment would be addressed in this NEPA process. The Notice of Opportunity to Comment, all responses, and the report are included in the project record.

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4.3 OTHER CONSULTATION Other consultation, completed in compliance with regulations and agreements currently in place, included:  Consultation with the Utah SHPO, in accordance with section 106 of the National Historic Preservation Act.  Government-to-government consultation with area Native American Tribes.  Coordination with Salt Lake City Department of Public Utilities per the memorandum of understanding for joint management of the municipal watershed.

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CHAPTER 5: LIST OF PREPARERS

Table 5-1 identifies the UWCNF and contractor personnel involved in preparation of this EA.

Table 5-1 List of preparers associated with this document. Name Position Contribution Forest Service Team Bekee Hotze District Ranger Project oversight. Project management; ID team Shawnee Hinman Project Manager/Winter Sports coordination. Pete Gomben Environmental Coordinator Project oversight and QA/QC review. Karen Hartman Wildlife Biologist Review of wildlife analysis. Tom Flanigan Archaeologist Review of heritage resources analysis. Stacey Weems Soil Scientist Review of watershed analysis. Review of analysis pertaining to fisheries Justin Robinson Fisheries Biologist and aquatic organisms. Charlie Condrat Hydrologist Review of watershed analysis. Brendan Hydrologist Review of watershed analysis. Waterman Dave Hatch Landscape Architect Review of scenic resources analysis. Michael Duncan Botanist Review of vegetation analysis. Cirrus Ecological Solutions, LC Team Project management, NEPA oversight, Scott Evans Project Manager and QA/QC review. NEPA oversight and QA/QC review. Neal Artz NEPA Specialist Preparation of recreation, safety, and scenic resources analyses. Eric Duffin Hydrologist Preparation of watershed analysis. Tim Royer Botanist and Wetland Specialist Preparation of vegetation analysis. Preparation of wildlife and transportation Matt Westover Wildlife Biologist analysis. Director, USU Archaeological Preparation of heritage resources Ken Cannon Services analysis. Document production and 508 Judy Seamons Document Production compliance.

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CHAPTER 6: REFERENCES

Ausseressus A. 2017. Personal communication with Eric Duffin, Cirrus Ecological Solutions. Calder, W. A., and L. L. Calder. 1994. Calliope Hummingbird. The Birds of North America. . Camfield, A. F., W. A. Calder, and L. L. Calder. 2013. Broad-tailed Hummingbird. The Birds of North America. . Craig, E. H., and T. H. Craig. 1984. Results of a helicopter survey of cliff nesting raptors in a deep canyon in southern Idaho. Raptor Research 18:20–25. Crowley A. 1992. Plant Communities of Albion Basin Wetlands Located in the Town of Alta, Little Cottonwood Canyon, Utah. Funded by The Friends of Alta and Alta Municipal Corporation, Alta Utah. eBird. 2017. eBird Explorer. . Forest Service 1995a. Inland Native Fish Strategy Environmental Assessment. Decision Notice and Finding of No Significant Impact. USDA Forest Service. Intermountain, Northern, and Pacific Northwest Regions. Forest Service 1995b. Landscape Aesthetics: A Handbook for Scenery Management. Agriculture Handbook Number 701. Forest Service. 1997. Final Environmental Impact Statement for the Alta Ski Area Master Development Plan Update. United States Department of Agriculture Wasatch-Cache National Forests. Salt Lake Ranger District. 6944 South 3000 East, Salt Lake City, Utah 84121. Forest Service. 2001. Built Environment Image Guide for the National Forests and Grasslands. USDA- Forest Service. FS-710. Forest Service. 2003. Revised Forest Plan Wasatch-Cache National Forest. US Department of Agriculture, Forest Service, Intermountain Region, Wasatch-Cache National Forest. February 2003. Forest Service. 2004. Guide to Effective Monitoring of Aquatic and Riparian Resources. USDA Forest Service, Rocky Mountain Research Station. General Technical Report RMRS-GTR-121. March 2004. Forest Service. 2005. Wasatch-Cache National Forest Noxious Weed Strategy. US Department of Agriculture, Forest Service, Intermountain Region, Wasatch-Cache National Forest. January 2005. Forest Service. 2006a. Watershed Conservation Practices Handbook. Rocky Mountain Region (Region 2). Denver, Colorado. FHS 2509.25. Forest Service. 2006b. Wasatch-Cache National Forest Noxious Weed Treatment Program. US Department of Agriculture, Forest Service, Intermountain Region, Wasatch-Cache National Forest. September 2006. Forest Service. 2011. Field Report: Alta Ski Area, Collins Gulch Culvert Failure. Prepared for District Ranger, Salt Lake Ranger District. Prepared by Paul Flood, Soil Scientist, Wasatch Cache National Forest. July 14, 2011.

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Forest Service 2012a. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. FS-990a. April 2012. http://www.fs.fed.us/biology/resources/pubs/watershed/FS_National_Core_BMPs_April2012.pdf Forest Service. 2012b. Accessibility Guidebook for Ski Areas Operating on Public Lands – 2012 Update. USDA-Forest Service. FS-703. Forest Service 2012c. Alta Ski Resort Supplement to the Forest Service Built Environment Image Guide (FS-710) Rocky Mountain Province. Forest Service. 2013a. Environmental Assessment: Snowbird Gad Valley Improvements. UWCNF. March. Forest Service. 2013b. Decision Memo for Alta Ski Area 2013 Summer Projects. UWCNF. July. Forest Service. 2015. Decision Memo for Alta Corkscrew Project. UWCNF. May. Forest Service. 2016. Intermountain Region (R4) Threatened, Endangered, Proposed, and, Sensitive Species Known/Suspected Distribution by Forest. USFS, Salt Lake City, UT. Forest Service. 2017a. Biological assessment for the Alta Master Development Plan Improvement Projects. USDA Forest Service, Salt Lake City, UT. Forest Service. 2017b. Biological evaluation for the Alta Master Development Plan Improvement Projects. USDA Forest Service, Salt Lake City, UT. Furniss, M.J., S. Flanagan, and B. McFadin. 2000. Hydrologically-connected roads: an indicator of the influence of roads on chronic sedimentation, surface water hydrology, and exposure to toxic chemicals. USDA Forest Service, Stream Systems Technology Center, Stream Notes, July, 2000. Fort Collins, CO. FWS (U.S. Fish and Wildlife Service). 2016. National Wetlands Inventory Version 2 data. U.S. Department of the Interior, Fish and Wildlife Service, Washington, D.C. http://www.fws.gov/wetlands/. FWS. 2017a. List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project. United States Department of the Interior, Fish and Wildlife Service, West Valley City, UT. FWS. 2017b. White-nose Syndrom.org: A coordinated response to the devastating bat disease. . Accessed 1 Jan 2017. Guzy, M. J., and P. E. Lowther. 2012. Black-throated Gray Warbler. 2The Birds of North America. . Gyug, L. W., R. C. Dobbs, T. E. Martin, and C. J. Conway. 2012. Williamson’s Sapsucker. The Birds of North America. . Hahn, T. P. 1996. Cassin’s Finch. The Birds of North America. . Harper K.T., and M.S. Petersen. 1990. Natural history of Little Cottonwood Canyon, Utah. The Bulletin of the Ecological Society of America 71(2): 381-386 Harsch M.A., and J. Hille Ris Lambers. 2016. Climate warming and seasonal precipitation change interact to limit species distribution shifts across western North America. PLoS One 11(7) doi:10.1371/journal.pone.0159184. Healy, S., and W. Calder. 2006. Rufous Hummingbird. The Birds of North America2. .

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Heinemeyer, K., and J. R. Squires. 2014. Wolverine – Winter Recreation Research Project: Investigating the Interactions between Wolverines and Winter Recreation, 2014 Progress Report. IUCN. 2017. Corynorhinus townsendii. The IUCN Redlist. . Accessed 1 Jan 2017. Jensen, S. 1993. Soil and Hydrology of Albion Basin Wetlands Located in the Town of Alta, Little Cottonwood Canyon, Utah. Written for Region VIII Environmental Protection Agency and The Town of Alta. Written by Seven F. Jensen, M.P.A. Environmental Planning Coordinator, Salt Lake County Commission Staff. Johnson, R. E. 2002. Black rosy-finch. The Birds of North America. . Accessed 1 Jan 2016. Kochert, M. N., K. Steenhof, C. L. Mcintyre, and E. H. Craig. 2002. Golden Eagle. The Birds of North America. . Kriger, K. M., and J.-M. Hero. 2009. Chytridiomycosis, amphibian extinctions, and lessons for the prevention of future panzootics. EcoHealth 6:6–10. Kunz, T. H., and R. A. Martin. 1982. Plecotus townsendii. Mammalian Species 175:6. Leonard, D. L. J. 2001. American Three-toed Woodpecker( Picoides dorsalis). The Birds of North America. . Linkhart, B. D., and D. A. Mccallum. 2013. Flammulated Owl (Psiloscops flammeolus). The Birds of North America. . Luce, R. J., and D. Keinath. 2007. Spotted Bat ( Euderma maculatum ): A Technical Conservation Assessment. USDA Forest Service, Rocky Mountain Region. NRCS. (Natural Resource Conservation Service). 2016. National Water and Climate Center. SNOTEL site #766. Available online at: http://wcc.sc.egov.usda.gov/nwcc/site?sitenum=766. Accessed December 2016. NRCS. 2017. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Soil Survey Geographic (SSURGO) Database for Summit Area, Utah, and Parts of Summit, Salt Lake and Wasatch Counties, Utah. Available online. Accessed March 9, 2017. NatureServe. 2014a. Northern Goshawk. An Online Encyclopedia of Life. . NatureServe. 2014b. Bonneville Cutthroat Trout. An Online Encyclopedia of Life. . NatureServe. 2017. NatureServe Explorer. An online encyclopedia of life. Available online at: http://explorer.natureserve.org/index.htm. Accessed July 2017. Olson, C. R., and T. E. Martin. 1999. Virginia’s Warbler. The Birds of North America. . Parish, J. R., F. P. Howe, and R. E. Norvell. 2002. Utah Partners in Flight Avian Conservation Strategy. Utah Division of Wildlife Resources, Publication Number 02-27ec, Salt Lake City, UT. Parmesan C., and G. Yohe. 2003. A globally coherent fingerprint of climate change impacts across natural systems. Nature 421:37-42. Priday, J., and B. Luce. 1999. New distributional records for spotted bat (Euderma maculatum) in Wyoming. Great Basin Naturalist 59:97–101.

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Raleigh, R.G., T. Hickman, R.C. Solomon, and P.C. Nelson. 1984. Habitat suitability information: Rainbow trout. U.S. Fish and Wildlife Service. FWS/OBS-82/10/60. Rotenberry, J. T., M. A. Patten, and K. L. Preston. 2012. Brewer’s Sparrow (Spizella breweri). The Birds of North America. . Sage Environmental. 2016. Oil Spill Prevention, Control and Countermeasure Plan (SPCC Plan). Prepared for Alta Ski Area, Alta, Utah. Prepared by Sage Environmental. Salt Lake City Department of Public Utilities. 1999. Salt Lake City Watershed Management Plan. Salt Lake County. 1989. Wasatch Canyons Master Plan. Salt Lake County Department of Public Works Planning Division. September 1989. 106 p. plus appendices. SHPO. 2016. Determination of Significance and Effect. Utah Historic Preservation Office. Sep. 21. Sedgwick, J. A. 2000. Willow Flycatcher. The Birds of North America. . Squires, J. R., and R. T. Reynolds. 1997. Northern Goshawk (Accipiter gentilis). The Birds of North America. . State of Utah. 2016. Utah Administrative Code Rule R317-2. Standards of Quality for Waters of the State. As in effect October 1, 2016. Available by download from: http://www.rules.utah.gov/publicat/code/r317/r317-002.htm. Steenhof, K. 2013. Prairie Falcon. The Birds of North America. . Town of Alta. 2005. 2005 Town of Alta General Plan, revised 2013 and 2016. UDWR. 2005. BOREAL TOAD (BUFO BOREAS BOREAS) CONSERVATION PLAN. Utah Division of Wildlife Resources, Publication Number 05-37, Salt Lake City, UT. UDWR. 2007. Bufo cognatus. Utah Division of Wildlife Resources. USU Archaeological Services. 2015. Class III Cultural Resource Inventory for the Alta Ski Area 2015 Master Development Plan Project, Salt Lake County, Utah, USFS Report Number UWC-15- 1529. October. USU Archaeological Services. 2016a. Class III Cultural Resource Inventory for the Alta Ski Area Supreme Big Dipper Borrow Site, Supreme Devil’s Castle Road Extension, and the Summer Trail Work Projects, Salt Lake County, Utah, USFS Report Number UWC-16-1576. November. USU Archaeological Services. 2016b. Class III Cultural Resource Inventory for the Alta Ski Lifts Project, Salt Lake County, Utah, USFS Report Number UWC-16-1575. December. USU Archaeological Services. 2016c. Class III Cultural Resource Inventory for the Alta Lower Mountain 2016 Projects, Salt Lake County, Utah, USFS Report Number UWC-16-1571. July. USU Archaeological Services. 2016d. Class III Cultural Resource Inventory for the Snowbird Zipline Tour Project, Salt Lake County, Utah, USFS Report Number UWC-17-1616. October. USU Archaeological Services. 2016e. Class III Cultural Resource Inventory for the Alta Snowmaking Loops Project (UWC-16-1572), Salt Lake County, Utah, USFS Report Number UWC-16-1572. July. DWQ. (Utah Division of Water Quality). 2002. Total Maximum Daily Load for Dissolved Zinc in Little Cottonwood Creek. Prepared for Utah Division of Water Quality by Shepherd Miller, 3801 Automation Way, Suite 100, Fort Collins, Colorado.

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DWQ. 2014. Utah’s Draft 2014 Integrated Report. Salt Lake City, Utah. Utah Department of Environmental Quality. Available by download from: https://deq.utah.gov/ProgramsServices/programs/water/monitoring- reporting/assessment/currentIR2014.htm UNPS (Utah Native Plant Society). 2017. Utah Rare Plant Guide. Available online at: http://www.utahrareplants.org/rpg_species.html. Accessed July 2017. Vierling, K. T., V. A. Saab, and B. W. Tobalske. 2014. Lewis’s Woodpecker (Melanerpes lewis). The Birds of North America. . Weckstein, D., D. Kroodsma, and R. Faucett. 2002. Fox sparrow. The Birds of North America. Welsh, S.L., N.D. Atwood, S. Goodrich, and L.C. Higgins. 2015. A Utah Flora, 5th Edition. Brigham Young University. Provo, Utah. Welsh, S.L., N.D. Atwood, S. Goodrich, and L.C. Higgins. 2015. A Utah Flora, 5th Edition. Brigham Young University. Provo, Utah. White, C. M., N. J. Clum, T. J. Cade, and W. G. Hunt. 2002. Peregrine Falcon. The Birds of North America. . Woodward, L. J. Harvey, K. Donaldson, J Shiozaki, G. Leishman, and J. Broderick. 1974. Soil Survey of Salt Lake Area, Utah. United States Department of Agriculture, Soil Conservation Service, In Cooperation with Utah Agricultural Experiment Station.

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APPENDIX A – MITIGATON MEASURES

Mitigation measures identified through this analysis include the following: WAT-1: Implement the BMPs listed in Table A-1. WAT-2: Obtain appropriate COE, Utah Division of Water Rights, Salt Lake County Health Department, and Salt Lake City Department of Public Utilities permits and authorizations prior to disturbing wetlands or altering stream channels. WAT-3: Mitigate wetland and stream channel impacts in accordance with the permits and authorizations noted above and avoid any net loss of wetlands. VEG-1: Delineate the boundaries of nearby rockcress draba populations on Sugarloaf Mountain using pin flags prior to construction of the Gazex system. Avoid any activity near the delineated boundary. VEG-2: Monitor and treat noxious and non-native invasive plant infestations at all areas disturbed by the proposed action for a period of at least three years following construction. VEG-3: Provide educational signage or other material to the public about minimizing disturbances in alpine ecosystems and the need to protect them by staying on trails or on snow cover when that is not possible. WIL-1: Construction and refueling helicopters operating during the nesting season (April–June) must approach, and depart, cliff areas from behind and above the cliffs to avoid flushing nesting falcons. WIL-2: Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no more than 10 days prior to commencing work. If no nests are found, project activities may proceed. If nests are found, contact the Forest Service permit administrator. CUL-1: A qualified archaeologist will monitor all surface disturbing activities during all ground- disturbing activities associated with expansion of the Albion parking lot to avoid potential effects on the historic Alta Townsite. SCE-1: Acid etch the exploder tubes and gas storage units to blend with the natural background. REC-1: Alta will continue to operate lifts at speeds that are appropriate for the conditional capacity of the terrain, regardless of the design capacity of the lifts.

Table A-1. Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name AQECO-2: Operations in  Coordinate stream channel, shoreline, lake, pond, and wetland activities with Aquatic appropriate Federal, State, County, and City agencies. Ecosystems  Incorporate Clean Water Act (CWA) 404 permit requirements and other Federal, State, and local permits or requirements into the project design and plan.  Locate access and staging areas near the project site but outside of work area boundaries, AMZs, wetlands, and sensitive soil areas.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table A-1 (cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name  Refuel and service equipment only in designated staging areas.  Schedule construction or maintenance operations in waterbodies to occur in the least critical periods to avoid or minimize adverse effects to sensitive aquatic and aquatic-dependent species that live in or near the waterbody.  Promptly install and appropriately maintain spill prevention and containment measures.  Conduct operations during dry periods.  Return clean flows to channel or waterbody downstream of the activity. FAC-2: Facility  Obtain Clean Water Act (CWA) 402 stormwater discharge permit coverage Construction and from the appropriate State agency or the U.S. Environmental Protection Stormwater Agency (EPA) when more than 1 acre of land will be disturbed through Control construction activities.  Control, collect, detain, treat, and disperse stormwater runoff from the site. FAC-6: Hazardous  Manage the use, storage, discharge, or disposal of pollutants and hazardous Materials or toxic substances generated by the facility in compliance with applicable regulations and requirements.  Respond to hazardous materials releases or spills using the established site- specific contingency plan for incidental releases and the Emergency Response Plan for larger releases.  Ensure that hazardous spill kits are adequately stocked with necessary supplies and are maintained in accessible locations. FAC-9: Pipelines, Transmission Facilities, and  Co-locate pipelines and transmission lines with roads or their rights-of-way Rights-of-Way where practicable.  Require suitable and regular inspections, testing, and leak detection systems to identify and mitigate pipeline deformities and leaks. FAC-10: Facility Site Reclamation.  Remove unneeded structures.  Establish effective ground cover on disturbed sites to avoid or minimize accelerated erosion and soil loss. REC-10: Ski Runs and  Avoid wetlands and riparian areas when locating ski runs and lifts wherever Lifts practicable.  Locate ski runs and lifts on stable geology and soils to minimize risk of slope failures.  Use yarding equipment suitable to the steepness of the terrain to avoid or minimize adverse effects to soil and water quality.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table A-1 (cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name  Clear and construct ski runs and lift lines in sections to limit the area of exposed disturbed soil at any one time.  Minimize grading or re-contouring of hill slopes to maintain intact soil horizons and infiltrative properties.  Cut stumps flush with soil surface or grind in place instead of grubbing when clearing trees from ski runs wherever practicable.  Use low-pressure construction and maintenance equipment whenever practicable to reduce surface impact on steep slopes.  Stockpile biologically active topsoil removed during excavation for use in reclamation. Store stockpiled topsoil separately from other vegetative slash, soil, or rock and protect from wind and water erosion, unnecessary compaction, and contaminants.  Use suitable measures to direct overland flow on slopes into areas with intact soil horizons to encourage infiltration and disconnect overland flow from waterbodies.  Prohibit traffic on disturbed areas during periods of excessive soil moisture, precipitation, or runoff.  Perform additional revegetation or erosion control as needed to protect water quality and soil integrity. REC-12: Ski Area  Avoid wetlands and riparian areas to the extent practicable when locating ski Facilities area facilities.  Locate ski area facilities on stable geology and soils to minimize risk of slope failures.  Avoid contaminating return water with chemicals or other pollutants.  Use applicable practices of BMP Road-2 (Road Location and Design), BMP Road-3 (Road Construction and Reconstruction), BMP Road-4 (Road Operations and Maintenance), BMP Road-8 (Snow Storage and Removal), and BMP Road-9 (Parking Sites and Staging Areas) for designing, constructing, maintaining, and operating roads and parking areas at ski area facilities. ROAD-3: Road Construction and  Do not place such materials on slopes with a risk of excessive erosion, Reconstruction sediment delivery to waterbodies, mass failure, or within the AMZ.  Do not permit sidecasting within the AMZ, avoid or minimize excavated materials from entering waterbodies or AMZs. ROAD-7: Stream Crossings  Design the crossing to pass a normal range of flows for the site.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table A-1 (cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name  Use suitable measures to avoid or minimize culvert plugging from transported bedload and debris.  Construct at or near natural elevation of the streambed to avoid or minimize potential flooding upstream of the crossing and erosion below the outlet. ROAD-8: Snow Removal  Develop a snow removal plan for roads plowed for recreation, and Storage administrative, or other access to avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources.  Store snow in clearly delineated pre-approved areas where snowmelt runoff will not cause erosion or deliver snow, road de-icers, or traction-enhancing materials directly into surface waters. ROAD-9: Parking and  Use applicable practices of BMP Fac-2 (Facility Construction and Staging Areas Stormwater Control) for stormwater management and erosion control when designing, constructing, reconstructing, or maintaining parking or staging areas.  Use and maintain suitable measures to collect and contain oil and grease in larger parking lots with high use and where drainage discharges directly to streams. ROAD-10: Equipment Refueling and  Use suitable measures to avoid spilling fuels, lubricants, cleaners, and other Servicing. chemicals during handling and transporting.  Remove service residues, used oil, and other hazardous or undesirable materials from NFS land and properly dispose them as needed during and after completion of the project.  Report spills and initiate suitable cleanup action in accordance with applicable State and Federal laws, rules, and regulations. VEG-1: Vegetation  Evaluate and field verify site conditions in the project area to design a Management transportation plan associated with the mechanical vegetation treatments to Planning avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources. VEG-2: Erosion Prevention and Control  Maintain the natural drainage pattern of the area wherever practicable.  Control, collect, detain, treat, and disperse stormwater runoff from disturbed areas.  Divert surface runoff around bare areas with appropriate energy dissipation and sediment filters.  Stabilize steep excavated slopes.

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Environmental Assessment: Alta Master Development Plan Improvement Projects

Table A-1 (cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name REC-12: Ski Area  Use applicable practices of BMP Road-3 (Road Construction and Facilities Reconstruction), BMP Road-4 (Road Operations and Maintenance), BMP Road-8 (Snow Storage and Removal), and BMP Road-9 (Parking Sites and Staging Areas) for designing, constructing, maintaining, and operating roads and parking areas at ski area facilities.

1Selected from the National Best Management Practices for Water Quality Management on National Forest System Lands (Forest Service 2012a).

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DRAFT DECISION NOTICE AND FINDING OF NO SIGNIFICANT IMPACT

ALTA SKI LIFTS MASTER DEVELOPMENT PLAN IMPROVEMENT PROJECTS

USDA-Forest Service Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest, Salt Lake City, Utah

INTRODUCTION This document details my decision regarding a proposal from Alta Ski Lifts (Alta) to implement several improvement projects included in their accepted master development plan (MDP). In accordance with the National Environmental Policy Act (NEPA) and this agency’s regulations on its implementation, the potential environmental impacts of this proposal were assessed and documented in an environmental assessment (EA) released concurrently with this draft decision. The EA is incorporated herein by reference. BACKGROUND AND HISTORY Alta operates under a special use permit (SUP) issued by the Forest Service. The first permit was issued in 1939, making Alta one of the oldest ski areas in the U.S. The current SUP was issued in 2002 and is administered by the Uinta-Wasatch-Cache National Forest (UWCNF). It has a term of 40 years. All proposed projects fall within the current SUP boundary.

The project area is defined as Alta’s approximately 1,800-acre SUP area. It is generally bounded by State Route 210 (SR 210) on the north, the ridgeline separating Big and Little Cottonwood canyons on the east, the Salt Lake County/Utah County line on the south, and Snowbird Ski and Summer Resort on the west. Access is from the Salt Lake Valley, about 13 miles up SR 210. Elevations range from 8,530 feet to 11,051 feet, and exposures are generally north. The project area is in the UWCNF’s Central Wasatch Management Area.

We accepted Alta’s MDP update March 14, 2013. However, acceptance of the MDP does not authorize implementation of the plan. Authorization occurs following NEPA review of projects that the resort wishes to implement within the next 5 years. In order to begin this process, Alta submitted a proposal on December 5, 2015, to implement a selection of projects from their accepted MDP, collectively referred to as the Master Development Plan Improvement Projects. DECISION My decision is to authorize all projects under Alternative 2 – Proposed Action, as described in EA section 2.4 and shown on the attached map. They include the following:

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1. Albion/Wildcat base parking improvements. 2. Tram from Germania Pass to Mt. Baldy. 3. Gazex or other equivalent technologies to replace artillery and Avalaunchers. 4. Sunnyside lift replacement. 5. Wildcat lift replacement. 6. Flora lift construction from bottom of Sugarbowl to the top of Collins lift. 7. Supreme summer ski run work. 8. Alf’s restaurant building addition. 9. Watson Shelter building addition. 10. Equipment storage facility construction. As part of my decision, I am requiring all design criteria and mitigation measures listed in EA section 2.5 and Appendix A, respectively, to be incorporated in project design and implementation. This includes the best management practices (BMPs) for watershed protection listed in EA Table 3-6. These required design criteria and mitigation measures are included as an attachment to this decision. I am also requiring Alta to continue working closely the UWCNF permit administrator to monitor and evaluate project implementation and mitigation effectiveness. This is an ongoing aspect of the UWCNF’s administration of the SUP. Beyond that, we undertake the Forest Service’s National BMP Monitoring program, providing a more structured format for monitoring and reporting. DECISION RATIONALE My decision is based on the analysis in the EA and supporting project record, which documents a thorough review of relevant information, consideration of divergent views, and acknowledgement of any incomplete or unavailable information. The analysis identifies the techniques and methodology used, considers current and accurate science, and references cited scientific resources. The analyses include a summary of the credible evidence relevant to evaluating reasonably foreseeable impacts. Within that framework, my decision focused on two factors: how well the alternatives (1) met the purpose and need for action and (2) addressed the main environmental issues identified through scoping, comment on the proposed action, and internal, interdisciplinary review. Purpose and Need EA section 1.5 outlines the purpose and need for the proposed action, and Alta’s project-specific rationales are provided in EA section 2.4. All of the authorized projects are logical and practical expansions of existing resort infrastructure, which increases the value of the commitment of National Forest System resources to date. Similarly, all authorized projects reflect the cooperative effort by the UWCNF and Alta to provide the public with access to high-quality recreational activities on the National Forest and benefit the local economy. The only other alternative considered was the no-action alternative. It would not achieve these purposes because it would resolve none of the stated needs. I believe that collectively the projects comprised by the proposed action effectively resolve those needs and are consistent with national, regional, and Forest- level policies and plans regarding ski area development. Main Environmental Issues The other major factor in reaching my decision was how effectively the alternatives addressed the main environmental concerns raised during scoping, comment on the proposed action, and internal, interdisciplinary review. Comments from the public and other agencies identifying environmental issues were included in our internal review process to determine the scope of the analysis. Concerns associated with seven resource areas were identified through this process and were analyzed in depth in the EA. These were: soil, water, and watershed resources; vegetation; wildlife; cultural resources; scenic resources; recreation; and safety.

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Several potential concerns raised during our review were not carried into detailed analysis for various reasons. Growth-related concerns were not analyzed in depth because the intent of the proposed action, as outlined in EA section 1.5, is to replace outdated equipment, upgrade service facilities, and take advantage of new technology. The proposed action does not open any new terrain; rather it updates the infrastructure serving existing terrain. The new lifts are not designed to add capacity. The Flora lift would replace East Baldy Traverse’s transfer function, not provide ski access. The Mt. Baldy tram would have a very low capacity and would serve primarily to transport ski patrol personnel. Public use would involve primarily those expert skiers who currently hike Mt. Baldy. The Wildcat and Sunnyside lift replacements would have somewhat higher capacities than the existing lifts, but increasing skier capacity is not the rationale for the replacement. As outlined in EA sections 2.4.3.1 and 2.4.3.2, the upgrades are to replace old, less reliable lift systems, provide redundant capacity when other lifts are down, and meet the current skier market’s desire for high-speed lifts. EA sections 3.5.3.2 and 3.5.3.3 describe Alta’s well-established program of maintaining low skier density by adjusting the operating speeds of their lifts and rarely operating them at design capacity. As discussed in EA sections 2.4.6.1 and 2.4.6.2, the proposed additions to Alf’s restaurant and Watson Shelter are mostly to replace space lost to new retail functions – another adaptation to changing skier demands. In short, the intent of the proposed action is not to increase visitation but to maintain numbers by meeting the needs and expectations of today’s skier market and changing patterns of skier use at Alta. Overall ski area capacity would not change appreciably, and the cap on new parking would remain in place. As a result, this EA focuses on the resource impacts of infrastructural development under the proposed action and alternatives, and not the impact of more visitors to Alta. As a result, impacts in the following areas were not addressed further in the EA: 1. Air Quality 2. Transportation and Parking 3. Utilities 4. Socio-economics I find that the EA adequately addressed all specific environmental issues relating to each of the seven resource categories. Chapter 3 of the EA documented that no significant impacts (as defined under NEPA; see Finding of No Significant Impact below) would occur on any of the resources of concern if the proposed action were implemented as described in the EA. In regard to these specific resources of concern, based on the analysis found in the EA I have concluded that, with required design criteria and BMPs in place:  The risk of erosion and sedimentation will be low, and no appreciable water quality impacts on streams in the project area will occur. This is largely due to the successful disturbed site restoration program that Alta has developed in conjunction with the UWCNF and Salt Lake City Department of Public Utilities (SLCDPU) over the years. The ski area’s spill prevention and containment protocols also meet applicable regulatory requirements for the protection of water quality. Maintaining that successful program is a condition of this authorization. (EA sections 3.4.1.3 and 3.4.1.5)  Impacts on wetlands and stream channels will be minimized by BMPs that maintain proper functioning of wetlands and channel stability. Any unavoidable impacts on wetlands and riparian areas, specifically the impacts on 0.23 acres of wetlands associated with construction of the bottom terminal of the Flora lift, will be mitigated in accordance with applicable local regulations and U.S. Army Corps of Engineers permitting under Section 404 of the Clean Water Act. (EA sections 3.4.1.3 and 3.4.1.5). No net loss of wetlands will occur, in accordance with Forest Plan direction.

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 There will be no impacts on threatened and endangered plant species as none occur in the project area. Effects on Forest Service sensitive plant species will be negligible and consistent with applicable regulatory and management direction as long as the design criteria listed in EA section 2.5 and the riparian area BMPs listed in Appendix A are followed. (EA sections 3.4.2.3 and 3.4.2.5)  Any impacts on threatened and endangered wildlife species as none occur in the project area. Effects on Forest Service sensitive species, birds of conservation concern, and big game species will be negligible and consistent with the regulatory and management direction applicable to each of those classes of wildlife. (EA sections 3.4.3.3 and 3.4.3.5)  No adverse impacts on the historic Alta Townsite will occur, and no other historic properties or Native American Tribal issues were identified in the project area. (EA sections 3.5.1.3 and 3.5.1.5)  Impacts on scenic resources, including those of the Mt. Baldy tram, will be mitigated and consistent with the landscape character theme and the scenic integrity objectives assigned to the permit area in the Forest Plan. (EA sections 3.5.2.5 and 3.5.2.7)  Higher capacity lifts will not result in crowding on trails because lift operating speed is managed by Alta to maintain the uncrowded conditions sought by their visitors. While the Mt. Baldy tram may reduce the novelty of hiking to ski Baldy, that option will remain, and there is ample hike-to terrain in the Central Wasatch. The lower tram terminal will not impair skier circulation on Germania Pass because the terminal will be off to the side of the pass and because management of skier flows using signage, rope lines, and other methods is standard ski area practice. (EA sections 3.5.3.3 and 3.5.3.5)  The Mt. Baldy tram will not pose a safety risk, beyond the inherent risk of skiing, because people already ski the chutes; Alta manages high-risk conditions with signage, rope lines, and closures; and people who change their minds once they get to the top of Baldy will now have the option of taking the tram down. As to the potential for sympathetic avalanche releases in Wolverine Cirque triggered by Gazex deployment on Patsey Marley, the new technology will not increase the risk of this unlikely event beyond that of the currently used artillery and helicopter bombing. (EA section 3.5.4.3) OTHER ALTERNATIVES CONSIDERED As discussed in EA sections 2.2 and 2.3, one alternative other than the selected alternative was analyzed in depth, the no-action alternative. No-Action Alternative Analysis of the no-action scenario provides a baseline for assessing the impacts of the proposed action. In this case, the no-action alternative would allow for continuation of ongoing resort operations. EA Chapter 3 summarizes the environmental effects of ongoing resort operations. The no-action alternative was not selected because it does not address the stated purpose and need for action, as discussed above. PUBLIC INVOLVEMENT The UWCNF issued a public scoping notice summarizing Alta’s proposed improvement projects (the proposed action) and inviting comments regarding the scope of the associated NEPA review. The improvement projects included in the proposed action were described in detail in the Description of the Proposed Action: Alta MDP Improvements Projects, which accompanied the scoping notice. The scoping notice was mailed to the agencies, organizations, and individuals on the UWCNF mailing list. The notice was also posted on the UWCNF website and made available on CD or in hard-copy form to anyone requesting it.

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The scoping period formally began on April 26, 2016, when the UWCNF’s legal notice was published in the Salt Lake Tribune (Newspaper of Record), and closed on May 26, 2016. Responses were received from 1 agency, 3 organizations, and 123 individuals. The scoping notice and responses are included in the project record. In accordance with the Forest Service’s Pre-Decisional Administrative Review Process (36 CFR 218), the UWCNF issued a Notice of Opportunity to Comment on the proposed action. The full-text preliminary EA was released for review and comment. The Notice of Opportunity to Comment was mailed to the agencies, organizations, and individuals on the UWCNF mailing list. It was also posted on the UWCNF project website and made available on CD or in hard-copy form to anyone requesting it. The 30-day comment period began on October 20, 2017, when a legal notice was published in the Salt Lake Tribune, and closed on November 20, 2017. A total of 214 responses were received, including two from agencies, three from organization, and 209 from individuals. A report was prepared listing the name, address, response number, and comment topics for each response, then responding how each comment would be addressed in this NEPA process. The Notice of Opportunity to Comment, all responses, and the report are included in the project record. I have reviewed this public input in conjunction with the EA, supporting documentation, and discussions with my staff. The noted scoping report and response-to-comments report address all comments in detail, but three major concerns identified in public comments warrant mention here. My consideration of those concerns is addressed as follows:

1. The overall impact of increasing visitation and use of Little Cottonwood Canyon. Specific issues spanned from water quality to traffic to impacts on flora and fauna. However, as noted above (see Main Environmental Issues, concerns not carried into detailed analysis), this proposed action is neither intended nor expected to notably increase canyon visitation. Parking limits remain in place, infrastructure and operating procedures are in place to accommodate ski area visitors with minimal impact, and no new ski terrain is being added. The EA effectively addresses the direct, indirect, and cumulative environmental effects of the proposed development. The larger issue of increasing canyon use results from rapid growth in the Wasatch Front population. The mission of the Forest Service is to sustain the health, diversity, and productivity of the nation’s forests and grasslands to meet the needs of present and future generations. One of the most important products that the UWCNF provides is quality recreational opportunities. Another is clean drinking water for neighboring metropolitan areas within Salt Lake Valley. Recognizing the importance of both, the UWCNF’s strategy is to balance provision of recreational amenities and opportunities with natural and financial resources. 2. Wetland impacts. Wetland impacts. The unforeseen wetland impacts of the Supreme lift replacement last summer raised concerns from local residents, the SLCDPU, the Salt Lake County Health Department, and other concerned citizens and organizations. In response, we were diligent in reviewing this proposed action to carefully identify wetlands, ensure that project design minimized potential impacts on them, and identify mitigation to offset any unavoidable adverse impacts. While the Flora lift project will affect a small wetland area, I believe that the EA describes this impact as clearly and accurately as possible, documents our efforts to find a feasible alternative location, and establishes the requirement for appropriate mitigation, as I am requiring in this decision. Accordingly, I am confident that the Forest Service is meeting its obligations regarding wetland protection. 3. Visual and environmental impact of the Mt. Baldy tram. Visual impact of the Mt. Baldy tram. Most of the comments received were regarding the tram. Members of the public questioned the need for the tram, discussed visual and environmental impacts resulting from the tram, and preferred to remove this project from the overall EA. Alta is a ski area and the Forest Plan

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provides clear direction for the management of scenic resources at UWCNF ski areas. The landscape character theme established by the Forest Plan for developed recreation areas states that “recreation amenities are the main attraction for people and why they come to an area.” In siting and planning construction of the lift, Alta has made practical efforts to reduce its visual and environmental impact, placing the upper terminal at a location below the peak and summit ridgeline, proposing minimal infrastructure for the terminal, and committing to using materials and colors that blend with the setting. Because the tram has limited capacity and will primarily be used for transporting ski patrol, winter use of the tram is not expected to impact vegetation more than what currently occurs from skiers hiking to the top of Mt. Baldy. In addition, summer use of the tram is not approved in my decision. Therefore impact’s resulting from summer use will not occur. As a result, I believe the project will be consistent with Forest Plan direction. FINDING OF NO SIGNIFICANT IMPACT As the responsible official, I am evaluating the effects of the selected alternative, the proposed action, relative to the definition of significance established by the Council on Environmental Quality Regulations (40 CFR 1508.13). I have reviewed and considered the EA and documentation included in the project record, and I have determined that the selected alternative will not have a significant effect on the quality of the human environment. As a result, no environmental impact statement will be prepared. My rationale for this finding is as follows, organized according to the CEQ definition of significance cited above. Context The selected alternative would implement project activities that are of limited scope, affecting only the immediate area around the proposed project sites. Some effects (i.e., visual impacts) extend beyond the Alta SUP area, but only to a distance of a few miles. Construction of the authorized infrastructure would be completed within a short timeframe, but its use would extend into the foreseeable future. Intensity Intensity is a measure of the severity, extent, or quantity of effects, based on information from the effects analysis in this EA and the references in the project record. The effects of this project have been appropriately and thoroughly considered in an analysis that is responsive to concerns and issues raised by the public and our interdisciplinary team. The agency has taken a hard look at the environmental effects using relevant scientific information and knowledge of site-specific conditions gained from field visits. My finding of no significant impact is based on the context of the project and intensity of effects using these 10 factors identified in 40 CFR 1508.27(b): 1. Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. Some effects associated with the selected alternative are adverse but not significant. My decision that these impacts are not significant is not biased or offset by the minor beneficial effects of some of the elements of the selected alternative. 2. The degree to which the selected alternative affects public health or safety. The EA identified no potential impacts on public health or safety. 3. Unique characteristics of the geographic area such as the proximity to historical or cultural resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. The analysis indicated no parklands, prime farmlands, wild and scenic rivers, or ecologically critical areas within selected alternative’s area of potential effect.

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The selected alternative will impact 0.23 acres of wetlands in the project area. That impact will be fully mitigated, in compliance with appropriate permits and authorizations. There will be not net loss of wetlands. Preservation Office (SHPO) concurs that no historic properties, including the historic Alta Townsite, would be affected. No other unique characteristics of the geographic area were identified. 4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. There is no known scientific controversy over the impacts of this project. As discussed above, the EA adequately addresses the controversial issues raised through scoping and comment on the proposed action. 5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. All elements of the selected alternative are common for ski resorts across the country and on the UWCNF, and similar actions have already been implemented at Alta. The potential effects described in the EA for this project are reasonable and do not constitute highly uncertain, unique, or unknown risks. 6. The degree to which the action may establish precedent for future actions with significant effects or represents a decision in principle about a future consideration. As noted above, all elements of the selected alternative are common for ski resorts, and similar actions have already been implemented in Little Cottonwood Canyon within the ski areas. My decision will not establish a precedent for future actions with significant effects. 7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. An analysis of cumulative effects was conducted for each resource area of concern, and no significant cumulative effects were identified, as disclosed in the EA (Chapter 3). 8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. As stated above, EA section 3.5.1 notes that the Utah SHPO has concurred that no historic properties, including the historic Alta Townsite, would be affected. No loss or destruction of significant scientific, cultural, or historical resources was identified. 9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. As indicated in EA sections 3.4.2 and 3.4.3, no federally listed plants are known to occur in the permit area, and no listed wildlife species would be affected. 10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. No such laws or requirements will be violated by the selected alternative (see following section). Any required approvals from other local, state, and federal regulatory agencies will be obtained prior to implementing the authorized projects.

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FINDINGS REQUIRED BY OTHER LAWS AND REGULATIONS The selected alternative meets requirements for all applicable laws and regulations, including the following: Endangered Species Act: No federally listed plants are known to occur in the permit area (EA section 3.4.2.2), and no listed wildlife species would be affected (EA section 3.4.3.2). Clean Water Act: The selected alternative is consistent with the Clean Water Act (EA section 3.4.1.3). Safe Drinking Water Act: The selected alternative is consistent with the Safe Drinking Water Act (EA section 3.4.1.3). Persons with Physical Challenges: With the required design criteria in place, including item 16 in EA section 2.5, the selected alternative will maintain accessibility for persons with physical challenges at Alta. Executive Orders 11988 and 11990 – Protection of Floodplains and Wetlands: The selected alternative will impact 0.23 acres of wetlands in the project area. That impact will be fully mitigated, in compliance with appropriate permits and authorizations. (EA sections 3.4.1.3 and 3.4.1.5). Executive Order 13186 – Protection of Migratory Birds: The selected alternative will not result in taking of migratory birds or their parts (EA section 3.4.3.2). Executive Order 12898 – Environmental Justice: The selected alternative will not have a disproportionately high or adverse effect on minority or low-income populations. Prime Farmland, Rangeland, and Forest Land: The selected alternative does not include any use of prime farmland or rangelands, and the term “prime forest land” does not apply to National Forest System lands. Under the selected alternative, National Forest System lands will be managed with sensitivity to the effects on neighboring lands. OPPORTUNITY TO OBJECT This project is subject to the objection process described in 36 CFR 218, subparts A and B. Only persons or organizations who have submitted specific written comments during a public comment period are eligible to file an objection (see 36 CFR 218.5). If an objection is submitted on behalf of a number of individuals or organizations, each individual or organization listed must meet the eligibility requirement of having previously submitted specific written comments. Names and addresses of objectors will become part of the public record.

Incorporation of documents by reference in the objection is permitted only as provided for at 36 CFR 218.8(b). Minimum content requirements of an objection (36 CFR 218.8) include:

1. Objector’s name and address with a telephone number if available; with signature or other verification of authorship supplied upon request; 2. Identification of the lead objector when multiple names are listed, along with verification upon request; 3. Name of project, responsible official, national forest/ranger district of project, and 4. Sufficient narrative description of those aspects of the proposed project objected to, specific issues related to the project, and suggested remedies that would resolve the objection.

Written objections, including any attachments, must be sent via regular mail, fax, email, hand-delivered, or express delivered to:

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Objection Reviewing Officer USDA-Forest Service Intermountain Region 324 25th Street Ogden, UT 84401

Objections must be filed within 45 days following the publication date of the legal notice in The Salt Lake Tribune. Hours for submitting hand-delivered objections are: 8 a.m. to 4:30 p.m., Monday through Friday, excluding holidays. Electronic objections must be submitted in a format such as an email message, .pdf, .txt, .rtf, .doc, or .docx to [email protected]. Faxed objections should be sent to (801) 625-5277. Objectors are responsible for ensuring that their objection is received in a timely manner (36 CFR 218.10).

The publication date of this legal notice in The Salt Lake Tribune, which is the newspaper of record, is the exclusive means for calculating the start of the 45-day objection period. Persons wishing to object should not rely on information provided by any other source. Objections must be received or postmarked by the end of this 45-day objection period. Extensions of the objection period are not permitted.

When the objection-filing period has ended and responses have been made to all objections by the reviewing officer, the responsible official may make a final decision on the proposed project. The reviewing officer shall issue a written response to objectors within 45 days following the end of this objection-filing period. When no timely objections are filed, a decision can be made on the fifth business day following the close of the filing period. Implementation may begin immediately after the decision is made. IMPLEMENTATION If no objection is filed, a final decision can be made on, but not before, the fifth business day following the end of the objection-filing period. Implementation may begin immediately after the final decision is signed. If an objection is filed, a 45-day objection resolution period will begin, and a final decision will be issued at the end of that period. The objection-reviewing officer may authorize a 30-day extension. A decision may be signed once all concerns and recommendations of the objection-reviewing officer have been addressed. Implementation may begin immediately after the decision is signed. CONTACT The project documents are available for review at the project website under the “Decision” tab: https://www.fs.usda.gov/project/?project=48903.

For further information about the project, including documents and maps, or about the objection process, contact Polly Bergseng at (801)733-2686.

David C. Whittekiend Date Forest Supervisor, Uinta-Wasatch-Cache National Forest

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In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA's TARGET Center at (202) 720- 2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected]. USDA is an equal opportunity provider, employer, and lender.

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Overview of the Proposed Action

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REQUIRED DESIGN CRITERIA AND MITIGATION MEASURES

Design Criteria

Erosion Control 1. Prior to construction, Alta will prepare a Storm Water Pollution Prevention Plan (SWPPP) that will apply to all authorized projects. The SWPPP is a condition of the Utah Pollutant Discharge Elimination System General Permit and will include appropriate BMPs for erosion control, sediment control, site stabilization, operational controls, and provisions for maintenance and inspection. The UWCNF may request review of SWPPPs. 2. The SWPPP will include appropriate BMPs from National Best Management Practices for Water-Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide (Forest Service 2012a). Pertinent watershed BMPs are listed in Appendix A. Vegetation Management 3. Soil disturbance will be minimized, and existing topsoil will be conserved for replacement. 4. Where possible, native vegetation will be retained. 5. In cleared and graded areas, mechanized equipment may be used to fell and remove trees. When possible, trees will be removed over snow to protect the ground surface. Disposal will be in accordance with applicable Forest Service permit requirements. 6. Slash created by tree removal will be disposed of either through utilization, burning, chipping, mastication, lopping and scattering, or removal from the site within a specified timeframe. Disposal will be in accordance with applicable Forest Service and state permit requirements. 7. Alta will follow Forest Service policy (FSM 2070) and use genetically appropriate native materials for rehabilitation and restoration. A qualified Forest Service botanist will be involved in development, review, and/or approval of plant materials selected for use in site rehabilitation and restoration. 8. Any areas of native vegetation that would be disturbed and have not been previously surveyed for special-status plants will be surveyed prior to construction. Results will be reported to the Forest Service permit administrator, and appropriate measures to mitigate impacts will be implemented. 9. All construction equipment and vehicles used will be cleaned and certified free of noxious weeds and their seeds prior to entrance onto the UWCNF. This restriction will include equipment and vehicles intended for both on- and off-road use, whether they are owned, leased, or borrowed by either contractors or subcontractors. 10. Any fill material proposed for the project, including any topsoil, will come from an on-site or in- canyon location. 11. Any straw bales, chips, or other imported mulch used in conjunction with the proposed action will come from a certified weed-free source. Wildlife Protection 12. Construction and refueling helicopters operating during the nesting season (April–June) must approach, and depart, cliff areas from behind and above the cliffs to avoid flushing nesting falcons.

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13. Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no more than 10 days prior to commencing work. If no nests are found, project activities may proceed. If nests are found, contact the Forest Service permit administrator. Scenic Integrity 14. Permanent structures will be designed and built in compliance with the Built Environment Image Guide for the National Forests and Grasslands (Forest Service 2001, FS-710). Ensuring that architectural style, building materials, size, and color are consistent and meet the adopted scenery objectives. Compliance will be confirmed through Forest Service engineering review prior to construction. 15. The edges of cleared ski runs will be feathered to appear more like natural openings in forest cover, flowing with the topography and blending with the natural vegetation. Accessibility 16. All buildings will be designed and constructed in accordance with the Accessibility Guidebook for Ski Areas Operating on Public Lands – 2012 Update (Forest Service 2012b). Compliance will be confirmed through Forest Service engineering review prior to construction. Undiscovered Heritage Resources 17. If any previously unidentified prehistoric or historic cultural resources are identified or encountered at any time during construction, efforts shall be made to protect the resource(s) until the Forest Service Permit Administrator is notified and the Forest Service fulfills its consultation requirements, including consultation with the appropriate Tribal representatives. 18. If unmarked human remains are encountered at any time during construction, all work in the vicinity of the find shall cease, with the remains covered and protected in place, and the Forest Service permit administrator notified immediately to begin proper notification and consultation procedures with the Utah State Historic Preservation Office, Native American Tribes, and other local officials as needed (e.g., county coroner) to determine to what time period and ethnic group the skeletal material may be ascribed and the appropriate treatment. 19. If any previously unidentified Traditional Cultural Places or sacred sites are identified or encountered at any time during construction, efforts shall be made to protect the resource until the Forest Service permit administrator is notified and the Forest Service fulfills its consultation requirements, including consultation with the appropriate Tribal representatives. Wetland Resources 20. Placement of lift towers in wetland areas will be avoided, the amount of wetland area disturbed will be avoided and minimized. Disturbances will be mitigated when avoidance is not practical. 21. Trench breakers will be used when snowmaking or other utility lines cross sloped wetland areas. Trench breakers will be placed at the lower wetland boundary so that groundwater is not drained through the trench and out of the wetland. 22. Any tree removal from wetlands will be done either over the snow or after the ground has frozen to protect soil resources. 23. When constructing buildings and lift terminals, equipment will not operate in adjacent wetlands and stream channels.

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Mitigation Measures Mitigation measures identified through this analysis include the following: WAT-1: Implement the BMPs listed in Table A-1. WAT-2: Obtain appropriate COE, Utah Division of Water Rights, Salt Lake County Health Department, and Salt Lake City Department of Public Utilities permits and authorizations prior to disturbing wetlands or altering stream channels. WAT-3: Mitigate wetland and stream channel impacts in accordance with the permits and authorizations noted above and avoid any net loss of wetlands. VEG-1: Delineate the boundaries of nearby rockcress draba populations on Sugarloaf Mountain using pin flags prior to construction of the Gazex system. Avoid any activity near the delineated boundary. VEG-2: Monitor and treat noxious and non-native invasive plant infestations at all areas disturbed by the proposed action for a period of at least three years following construction. VEG-3: Provide educational signage or other material to the public about minimizing disturbances in alpine ecosystems and the need to protect them by staying on trails or on snow cover when that is not possible. WIL-1: Construction and refueling helicopters operating during the nesting season (April–June) must approach, and depart, cliff areas from behind and above the cliffs to avoid flushing nesting falcons. WIL-2: Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no more than 10 days prior to commencing work. If no nests are found, project activities may proceed. If nests are found, contact the Forest Service permit administrator. CUL-1: A qualified archaeologist will monitor all surface disturbing activities during all ground- disturbing activities associated with expansion of the Albion parking lot to avoid potential effects on the historic Alta Townsite. SCE-1: Acid etch the exploder tubes and gas storage units to blend with the natural background. REC-1: Alta will continue to operate lifts at speeds that are appropriate for the conditional capacity of the terrain, regardless of the design capacity of the lifts.

Table A-1. Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name AQECO-2: Operations in  Coordinate stream channel, shoreline, lake, pond, and wetland activities with Aquatic Ecosystems appropriate Federal, State, County, and City agencies.  Incorporate Clean Water Act (CWA) 404 permit requirements and other Federal, State, and local permits or requirements into the project design and plan.  Locate access and staging areas near the project site but outside of work area boundaries, AMZs, wetlands, and sensitive soil areas.  Refuel and service equipment only in designated staging areas.

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Table A-1 (Cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name  Schedule construction or maintenance operations in waterbodies to occur in the least critical periods to avoid or minimize adverse effects to sensitive aquatic and aquatic-dependent species that live in or near the waterbody.  Promptly install and appropriately maintain spill prevention and containment measures.  Conduct operations during dry periods.  Return clean flows to channel or waterbody downstream of the activity. FAC-2: Facility  Obtain Clean Water Act (CWA) 402 stormwater discharge permit coverage Construction and from the appropriate State agency or the U.S. Environmental Protection Stormwater Control Agency (EPA) when more than 1 acre of land will be disturbed through construction activities.  Control, collect, detain, treat, and disperse stormwater runoff from the site. FAC-6: Hazardous  Manage the use, storage, discharge, or disposal of pollutants and hazardous Materials or toxic substances generated by the facility in compliance with applicable regulations and requirements.  Respond to hazardous materials releases or spills using the established site- specific contingency plan for incidental releases and the Emergency Response Plan for larger releases.  Ensure that hazardous spill kits are adequately stocked with necessary supplies and are maintained in accessible locations. FAC-9: Pipelines,  Co-locate pipelines and transmission lines with roads or their rights-of-way Transmission Facilities, where practicable. and Rights-of-Way  Require suitable and regular inspections, testing, and leak detection systems to identify and mitigate pipeline deformities and leaks. FAC-10: Facility Site Reclamation.  Remove unneeded structures.  Establish effective ground cover on disturbed sites to avoid or minimize accelerated erosion and soil loss. REC-10: Ski Runs and  Avoid wetlands and riparian areas when locating ski runs and lifts wherever Lifts practicable.  Locate ski runs and lifts on stable geology and soils to minimize risk of slope failures.  Use yarding equipment suitable to the steepness of the terrain to avoid or minimize adverse effects to soil and water quality.  Clear and construct ski runs and lift lines in sections to limit the area of exposed disturbed soil at any one time.

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Table A-1 (Cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name  Minimize grading or re-contouring of hill slopes to maintain intact soil horizons and infiltrative properties.  Cut stumps flush with soil surface or grind in place instead of grubbing when clearing trees from ski runs wherever practicable.  Use low-pressure construction and maintenance equipment whenever practicable to reduce surface impact on steep slopes.  Stockpile biologically active topsoil removed during excavation for use in reclamation. Store stockpiled topsoil separately from other vegetative slash, soil, or rock and protect from wind and water erosion, unnecessary compaction, and contaminants.  Use suitable measures to direct overland flow on slopes into areas with intact soil horizons to encourage infiltration and disconnect overland flow from waterbodies.  Prohibit traffic on disturbed areas during periods of excessive soil moisture, precipitation, or runoff.  Perform additional revegetation or erosion control as needed to protect water quality and soil integrity. REC-12: Ski Area  Avoid wetlands and riparian areas to the extent practicable when locating ski Facilities area facilities.  Locate ski area facilities on stable geology and soils to minimize risk of slope failures.  Avoid contaminating return water with chemicals or other pollutants.  Use applicable practices of BMP Road-2 (Road Location and Design), BMP Road-3 (Road Construction and Reconstruction), BMP Road-4 (Road Operations and Maintenance), BMP Road-8 (Snow Storage and Removal), and BMP Road-9 (Parking Sites and Staging Areas) for designing, constructing, maintaining, and operating roads and parking areas at ski area facilities. ROAD-3: Road  Do not place such materials on slopes with a risk of excessive erosion, Construction and sediment delivery to waterbodies, mass failure, or within the AMZ. Reconstruction  Do not permit sidecasting within the AMZ, avoid or minimize excavated materials from entering waterbodies or AMZs. ROAD-7: Stream  Design the crossing to pass a normal range of flows for the site. Crossings  Use suitable measures to avoid or minimize culvert plugging from transported bedload and debris.  Construct at or near natural elevation of the streambed to avoid or minimize potential flooding upstream of the crossing and erosion below the outlet.

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Table A-1 (Cont’d). Best Management Practices that would be followed under the proposed action.1 FS National Core BMP Practice Description Code and Name ROAD-8: Snow Removal  Develop a snow removal plan for roads plowed for recreation, and Storage administrative, or other access to avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources.  Store snow in clearly delineated pre-approved areas where snowmelt runoff will not cause erosion or deliver snow, road de-icers, or traction-enhancing materials directly into surface waters. ROAD-9: Parking and  Use applicable practices of BMP Fac-2 (Facility Construction and Staging Areas Stormwater Control) for stormwater management and erosion control when designing, constructing, reconstructing, or maintaining parking or staging areas.  Use and maintain suitable measures to collect and contain oil and grease in larger parking lots with high use and where drainage discharges directly to streams. ROAD-10: Equipment  Use suitable measures to avoid spilling fuels, lubricants, cleaners, and other Refueling and Servicing. chemicals during handling and transporting.  Remove service residues, used oil, and other hazardous or undesirable materials from NFS land and properly dispose them as needed during and after completion of the project.  Report spills and initiate suitable cleanup action in accordance with applicable State and Federal laws, rules, and regulations. VEG-1: Vegetation  Evaluate and field verify site conditions in the project area to design a Management Planning transportation plan associated with the mechanical vegetation treatments to avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources. VEG-2: Erosion Prevention and Control  Maintain the natural drainage pattern of the area wherever practicable.  Control, collect, detain, treat, and disperse stormwater runoff from disturbed areas.  Divert surface runoff around bare areas with appropriate energy dissipation and sediment filters.  Stabilize steep excavated slopes. REC-12: Ski Area  Use applicable practices of BMP Road-3 (Road Construction and Facilities Reconstruction), BMP Road-4 (Road Operations and Maintenance), BMP Road-8 (Snow Storage and Removal), and BMP Road-9 (Parking Sites and Staging Areas) for designing, constructing, maintaining, and operating roads and parking areas at ski area facilities.

1Selected from the National Best Management Practices for Water Quality Management on National Forest System Lands (Forest Service 2012a).

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RESPONSE TO COMMENTS ON PROPOSED ACTION: ALTA SKI LIFTS MASTER DEVELOPMENT PLAN IMPROVEMENT PROJECTS

March 2, 2018 INTRODUCTION The Uinta-Wasatch-Cache National Forest (UWCNF) is preparing an Environmental Assessment (EA) addressing Alta Ski Lifts Master Development Plan Improvement Projects. In accordance with the Forest Service’s Pre-Decisional Administrative Review Process (36 CFR 218), the UWCNF issued a Notice of Opportunity to Comment on the proposed action. The full-text preliminary EA was released for review and comment. The Notice of Opportunity to Comment was mailed to the agencies, organizations, and individuals on the UWCNF mailing list. It was also posted on the UWCNF project website and made available on CD or in hard-copy form to anyone requesting it.

The 30-day comment period began on October 20, 2017, when a legal notice was published in the Salt Lake Tribune, and closed on November 20, 2017. A total of 214 responses were received, including two from agencies, four from organizations, and 208 from individuals. The Notice of Opportunity to Comment and all responses are included in the project record. This report identifies respondents, lists and categorizes individual comments, and provides agency responses regarding the disposition of those comments in the EA process. PROCESSING OF COMMENTS Table 1 identifies each respondent, noting the ID code assigned, name and address, and the heading under which each individual comment is addressed in this report. ID codes indicate whether the respondent was an agency, organization, or individual (A, O, and I, respectively) and the number of the respondent within that category. In the body of the report, this code is followed by a number indicating the sequence of individual comments within a given response (i.e., A2-6 identifies the sixth comment in a response from the second agency letter.

Table 1. Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Jim Bradley Government Center Process-Proposed Action-Baldy Tram, 2001 S State Street, Suite N2200 Resources-Wildlife-Pika, Resources- Salt Lake County A1 Salt Lake City, UT 84114 Scenic Resources-Baldy Tram, Council Resources-Recreation-Baldy Tram, Opposition to Baldy Tram Nelson, Patrick 1530 South West Temple Process-Proposed Action- Salt Lake City, UT 84115 Albion/Wildcat Base Parking, A2 SLC Dept. Public Equipment Storage Facility, and Utilities Miscellaneous; Alternatives-Flora Lift;

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Process-Monitoring; Process-Role of Other Agencies; Resources-Soil,

Water, and Watershed Resources- Water Quality and Wetlands. Clancy, Jen PO Box 8126 Process-Purpose and Need- Alta, UT 84092 Albion/Wildcat Base Parking, Flora Friends of Alta Lift; Process-Proposed Action-Baldy Tram, Alf’s Restaurant Building Addition; Process-Issues Not Addressed-Canyon Carrying Capacity, Summer Use; Process-Alternatives- Baldy Tram, Flora Lift; Process-Role of Other Agencies; Resources-Soil, O1 Water, and Watershed Resources- Restoration, Wetlands; Resources- Vegetation-Timing, Baldy Tram, Other Projects; Resources-Scenic Resources- Baldy Tram, Gazex Installations, Mitigation; Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Baldy Tram-Opposition to Other Projects, Support of Baldy Tram. DeBirk, Robert [email protected] Process-Purpose and Need- Albion/Wildcat Base Parking , Baldy Save Our Canyons Tram, Flora Lift; Proposed Action- Baldy Tram; Process-Issues Not Addressed- Transportation and Parking; Process-Alternatives-Flora Lift; Process-Cumulative Effects; Process-Adequacy of Analysis; Resources-Soil, Water, and Watershed- O2 Wetlands, Supreme Summer Ski Run Work; Resources-Vegetation-Baldy Tram, Gazex Installations, Other Projects; Resources-Wildlife-Baldy Tram, Gazex, and Alpine Habitat, and Pika; Resources-Scenic Resources- Baldy Tram, Gazex Installations; Resources-Recreation-Gazex Installations; Oppositions to Baldy Tram. Hubbell, David B. 808 East South Temple Comments Expressing General O3 Salt Lake City, UT 84102 Opinions Regarding the Proposed Lear & Lear, LLP Action-Opposition to Proposed Action McCarvill, William 3607 Golden Hills Ave Comments Expressing General O4 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Sierra Club Action-Opposition to Baldy Tram

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Adams, Chris Salt Lake City, UT Process-Purpose and Need-Baldy Tram, Flora Lift; Resources-Scenic I1 Resources-Baldy Tram; Resources- Recreation-Baldy Tram Adler, Peter 574 E 9th Ave Comments Expressing General I2 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Allen, Beth 3050 S Lake Cir Comments Expressing General I3 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Alling, Danielle 653 S 800 E Comments Expressing General I4 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action Anderson, Perrine 1444 S 1400 E Process-Issues Not Addressed- Salt Lake City, UT 84105 Transportation and Parking, Comments I5 Expressing General Opinions Regarding the Proposed Action- Opposition to Proposed Action Andrenyak, David 19495 S 2100 E Resources-Scenic Resources-Baldy I6 Salt Lake City, UT 84108 Tram, Resources-Safety-Baldy Tram Annoni, Pat 7022 S 300 E Comments Expressing General I7* Midvale, UT 84047 Opinions Regarding the Proposed Action-Opposition to Proposed Action Barcikowski, 942 E Lowell Ave Comments Expressing General I8 Elliott Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action Barker, Christine 2600 E 9800 S Comments Expressing General I9 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Barrell, Keith 1590 E Evergreen Ln Comments Expressing General I10 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Behle, Brian 1013 S 1500 E Comments Expressing General I11 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Bercaw, John 1716 E Harrison Ave Comments Expressing General I12 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Boardman-Fowler, 8546 S Top of the World Cir Comments Expressing General I13 Kelly Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Bolton, Joe 830 S 1200 E Comments Expressing General I14 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action Bossart, Philip 4608 S Park Hill Dr Comments Expressing General I15 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Bourke, Margaret 8615 S Albion Basin Rd Process-Purpose and Need-Sunnyside Alta, UT 84092-8083 Lift Replacement, Albion Lift Upgrade, Alf’s Restaurant Building Addition; Process-Proposed Action-Baldy Tram, Alf’s Restaurant Building Addition, Miscellaneous; Process-Issues Not I16 Addressed-Increased Visitors, Employee Housing; Lake Flora Restoration; Process-Cumulative Effects; Resources-Safety- Albion/Wildcat Base Parking, Albion and Sunnyside Lifts. Bourke, Roger Box 8083 Process-Purpose and Need-Baldy Alta, UT 84092 Tram, Sunnyside Lift Replacement, Flora Lift, Alf’s Restaurant Building Addition; Process-Proposed Action- Alf’s Restaurant Building Addition; Process-Issues Not Addressed- I17 Employee Housing; Process- Alternatives-Baldy Tram; Resources- Soil, Water, and Watershed Resources- Restoration; Resources-Wildlife- Moose; Resources-Recreation-Baldy Tram; Resources-Safety- Albion and Sunnyside Lifts. Bowman, Jane 3566 S Neffs Circle Comments Expressing General I18 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Breiwick, Katie 1849 S 500 E Comments Expressing General I19 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Brister, Bob 220 S Elizabeth St, #12 Comments Expressing General I20 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Brough, Tiffin 841 S Washington St Comments Expressing General Salt Lake City, UT 84101 Opinions Regarding the Proposed I21 Action-Opposition to Proposed Action; Process-Alternatives-Albion/Wildcat Base Parking

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Brown, Eileen 747 N Richland Dr Comments Expressing General I22 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Brown, Kathleen 747 N Richland Dr Comments Expressing General I23 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Brown, Michael 747 N Richland Dr Comments Expressing General I24 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Bunce, Eric 2778 E 7350 S Comments Expressing General I25 Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Burton, Jan Ellen 1340 E Gilmer Dr Process-Issues Not Addressed- Salt Lake City, UT 84105 Transportation and Parking, Resources- Wildlife-Pika, Comments Expressing I26 General Opinions Regarding the Proposed Action-Opposition to Baldy Tram. Campanelli, Process-Purpose and Need-Sunnyside Michael Lift Replacement, Flora Lift, Supreme Summer Ski Run Work, Watson Shelter Addition, Lake Flora Restoration; Process-Proposed Action- Equipment Storage Facility; Process- Issues Not Addressed-Transportation I27 and Parking; Process-Alternatives- Flora lift; Resources-Wildlife-Moose; Resources-Recreation-Baldy Tram, Wildcat Replacement; Resources- Safety-Gazex Installations; Comments Expressing General Opinions Regarding the Proposed Action- Support for Baldy Tram Cannon, Mike 853 E Wilmington Ave Apt. 102 Comments Expressing General I28 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Carrigan, Bill 8091 S Mountain Oaks Cir Comments Expressing General I29 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Carroll, David Salt Lake City, UT Process-Purpose and Need- Albion/Wildcat Base Parking, Baldy Tram; Process-Alternatives- I30 Albion/Wildcat Base Parking; Resources-Scenic Resources-Baldy Tram, Gazex Installations; Resources- Safety-Gazex Installations

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Carty, Robert 741 E 600 N Comments Expressing General I31 Layton, UT 84041 Opinions Regarding the Proposed Action-Opposition to Proposed Action Christmas, Holly 456 E Westminster Ave Comments Expressing General I32 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Church, Linda 1016 E Perrywill Ave Comments Expressing General I33 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Concannon, 2778 E 7350 S Comments Expressing General I34 Jacqueline Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Crimmel, Henry 1395 Edvalson St Comments Expressing General I35 Ogden, UT 84408 Opinions Regarding the Proposed Action-Opposition to Proposed Action Cutting, Elizabeth 1800 Homestake Rd, Unit 359 Comments Expressing General I36 Park City, UT 84060 Opinions Regarding the Proposed Action-Opposition to Proposed Action Cutting, Will 1046 S 800 E Comments Expressing General I37 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Daniels, Nicholas 914 W 600 S Comments Expressing General I38 Salt Lake City, UT 84104 Opinions Regarding the Proposed Action-Opposition to Proposed Action Davidson, Matt 683 W 2300 N Comments Expressing General I39 West Bountiful, UT 84087 Opinions Regarding the Proposed Action-Opposition to Proposed Action Derezotes, Tami 3669 E Oakview Dr Comments Expressing General I40 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Devries, Michael 9659 S Princess Cv Comments Expressing General I41 South Jordan, UT 84095 Opinions Regarding the Proposed Action-Opposition to Proposed Action Dorias, Michael 635 Dalton Dr Comments Expressing General I42 Pleasant Grove, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Duff, Victoria 86 B St Apt 8 Comments Expressing General I43 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Dunn, William 1171 W Country Ridge Dr Comments Expressing General I44 South Jordan, UT 84095 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Ellison, Suzie 7859 S Nantucket Dr Comments Expressing General I45 Cottonwood, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Farhang, Arash 4466 S Parkview Dr. Comments Expressing General I46 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Farley, Anthony 3045 S 900 E Comments Expressing General I47 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Field, Tony 2467 E Granite Pl Comments Expressing General I48 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Filgo, Shelly 11721 S Highland Oaks Cir Comments Expressing General I49 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Fiorella, Richard 222 D St Comments Expressing General I50 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Fisher, Kelley 3045 S 900 E Comments Expressing General I51 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Fox, Jason 2636 S Filmore St Comments Expressing General I52 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Fuller, Gary 2014 E Princeton Ave Comments Expressing General I53 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Gagnon, David 2627 S McClelland St Comments Expressing General I54 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Gaia, Jennifer 910 Wild Rose Dr Comments Expressing General Francis, UT 84036 Opinions Regarding the Proposed I55 Action-Opposition to Proposed Action, Opposition to Baldy Tram Gardiner, Mark 374 E Garfield Ave Comments Expressing General I56 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Gass, Leila Tucson, AZ Comments Expressing General I57 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Geesaman Rabke, 823 E 1st Ave Comments Expressing General I58 Erin Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Gilbert, Nathan 1913 S West Temple Comments Expressing General I59 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Gilmore, Roland 1169 Pinebrush Dr Comments Expressing General I60 Park City, UT 84098 Opinions Regarding the Proposed Action-Opposition to Proposed Action Golden, Luke 1150 E Garfield Ave Comments Expressing General I61 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Gray, William 666 E 9th Ave Process-Cumulative Effects, Comments Salt Lake City, UT 84103 Expressing General Opinions I62 Regarding the Proposed Action- Opposition to Baldy Tram Gregersen, Richard 2552 S Douglas St Comments Expressing General I63 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Hager, Jon 11760 S 1300 W Comments Expressing General I64 Riverton, UT 84065 Opinions Regarding the Proposed Action-Opposition to Proposed Action Hamilton, Bruce 1350 W Walnut Dr Comments Expressing General I65 Salt Lake City, UT 84116 Opinions Regarding the Proposed Action-Opposition to Proposed Action Hanson, Nancy 8268 S Maio Dr Process-Purpose and Need-Baldy Sandy, UT 84093 Tram; Process- Purpose and Need- Baldy Tram, Miscellaneous; Issues Not Address- Transportation and Parking; Process-Alternatives-Albion/Wildcat I66 Base Parking; Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Proposed Action, Opposition to Baldy Tram-Opposition to Other Projects Hanson, Nicholas 8268 S Maio Dr Resources-Scenic Resources-Baldy Sandy, UT 84093 Tram, Comments Expressing General I67 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Hendershoft, James 2835 S Lakeview Dr Comments Expressing General I68 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Hendrick, John 131 W 400 N Comments Expressing General I69 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Hitchcock, Katie 4432 S Camille St Comments Expressing General I70 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Hong, Jenny 2272 Lakeline Dr Process-Proposed Action-Baldy Tram, Salt Lake City, UT 84109 Comments Expressing General I71 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Hunt, Steve 8775 S Oak Valley Dr Comments Expressing General I72 Sandy, UT 84093 Opinions Regarding the Proposed Action-Opposition to Proposed Action Iltis, Dave 1124 4th Ave Process-Proposed Action- Salt Lake City, UT 84103 Miscellaneous; Process-Issues Not Addressed-Summer Use; Resources- Soil, Water, and Watershed Resources- I73 Restoration; Resources-Scenic Resources-Dark Skies, Comments Expressing General Opinions Regarding the Proposed Action- Opposition to Baldy Tram Ingebretsen, Hailey 2136 E Vimont Ave Comments Expressing General I74 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Jacobs, Spencer 7288 S Marinda Way Comments Expressing General I75 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Jansson, Caroline Comments Expressing General I76 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Jensen, Benjamin 2031 E 2700 S #2 Comments Expressing General I77 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Jensen, Karlene 2600 S Elizabeth St Comments Expressing General I78 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Johnson, Evan 1170 S 800 E Comments Expressing General I79 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Johnson, Michael 7263 S 1440 E Comments Expressing General I80 Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Johnson, Mike PO Box 520172 Comments Expressing General I81 Salt Lake City, UT 84152 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Johnson, Sue 2133 S Berkeley St Comments Expressing General I82 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Kachi, Yukio 1278 E 1300 S Comments Expressing General I83 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Kano, Shandi Resources-Scenic Resources-Baldy Tram; Resources-Safety-Baldy Tram; I84 Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Baldy Tram Klepper, Scott Process-Issues Not Addressed- I85 Transportation and Parking; Resources- Safety-Baldy Tram Knoblock, John 4475 S Zarahemla Dr Process-Adequacy of Analysis; Millcreek, UT 84124 Resources-Scenic Resources-Baldy Tram; Resources-Safety-Baldy Tram; Comments Expressing General I86 Opinions Regarding the Proposed Action-Support for Proposed Action, Support for Baldy Tram, Support for Other Projects Koistal, Derek 182 E Kelsey Ave Comments Expressing General I87 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Korpi, Andrew 9743 S 1210 E Comments Expressing General I88 Sandy UT 84094 Opinions Regarding the Proposed Action-Opposition to Proposed Action Kraan, Eric 3663 E Capstone Ave Comments Expressing General I89 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Kraus, Lynne 2407 E 7745 S Resources-Soil, Water, and Watershed Cottonwood Heights, UT 84121 Resources-Baldy Tram; Comments I90 Expressing General Opinions Regarding the Proposed Action- Opposition to Baldy Tram Krause, Doug 824 S 400 W, Ste B115 Comments Expressing General I91 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action I92 Krause, Eric Process-Purpose and Need-Baldy Tram Kumar, Naresh 2140 S Nowell Cir Comments Expressing General I93 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Kumpfer, Karol 5215 E Pioneer Fork Rd Comments Expressing General I94 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lambson, Mia 734 E Loveland Ave Comments Expressing General I95 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Layco, Gambrelli 540 Upper Evergreen Dr Comments Expressing General I96 Park City, UT 84098 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Le, Trung 4401 W Sand Trap Cir Comments Expressing General I97 South Jordan, UT 84009 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lee, Dale 2897 E Water Vista Way Comments Expressing General I98 Sandy, UT 84093 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Lee, Linda 1462 E Valley Ridge Dr Comments Expressing General I99 Sandy, UT 84093 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lee, Phil 1420 E Redondo Ave Comments Expressing General I100 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lefebvre, Liz Process-Purpose and Need-Baldy Tram, Comments Expressing General I101 Opinions Regarding the Proposed Action-Opposition to Baldy Tram LeRiviere, Ben 439 E Redondo Ave Comments Expressing General I102 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Leven, Brody 830 S Jefferson St #W201 Comments Expressing General I103 Salt Lake City, UT 84101 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lloyd, Georgann 1432 E Shoshone Ave Comments Expressing General I104 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action London, Aaron 640 S 600 E Comments Expressing General I105 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action Louie, Ken 2209 E Raintree Cir Comments Expressing General I106 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Lyons, Robyn 830 S 1200 E Comments Expressing General I107 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Macfarlane, Robert 549 E Outlook Cv Resources-Recreation-Baldy Tram, Draper, UT 84020 Comments Expressing General I108 Opinions Regarding the Proposed Action-Opposition to Proposed Action, Opposition to Baldy Tram Mackay, Ashley 1156 E Murray Holladay Rd Comments Expressing General I109 Salt Lake City, UT 84117 Opinions Regarding the Proposed Action-Opposition to Proposed Action Mahoney, Chris 8822 S. Blue Jay Ln. Comments Expressing General I110 Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Martin, Andrew 1207 Whileaway Rd. E Process-Proposed Action-Baldy Tram, Park City, UT 84098 Process-Issues Not Addressed- Transportation and Parking, Comments I111 Expressing General Opinions Regarding the Proposed Action- Opposition to Baldy Tram McAllister, Josh 1863 S Foothill Dr Comments Expressing General I112 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action McCarthy, 7058 Stagecoach Dr Comments Expressing General I113 Whitney Park City, UT 84098 Opinions Regarding the Proposed Action-Opposition to Proposed Action McGuffey, Lee 2385 E 2100 S Comments Expressing General I114 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action McKasy, Meaghan 2618 S 900 E Comments Expressing General I115 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Middleton, Andrew 230E E Broadway, 510 Comments Expressing General I116 Salt Lake City, UT 84111 Opinions Regarding the Proposed Action-Opposition to Proposed Action Miles, Larry 2825 E Willow Hills Dr Comments Expressing General I117 Sandy, UT 84093 Opinions Regarding the Proposed Action-Opposition to Proposed Action Millgram, Elijah 4221 S Marquis Way Comments Expressing General I118 Holladay, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Mills, Joan 7791 Buckboard Dr Comments Expressing General I119 Park City, UT 84098 Opinions Regarding the Proposed Action-Opposition to Proposed Action Miterko, Noah 995 S Lake St Process-Purpose and Need-Baldy I120 Salt Lake City, UT 84105 Tram; Process-Issues Not Addressed- Canyon Carrying Capacity, Transportation and Parking

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Monson, Traci 2013 S 2500 E #A Comments Expressing General I121 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Moores, Tamara 1941 S Lincoln St Comments Expressing General I122 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Moslander, Joe 6096 S 2230 E Comments Expressing General I123 Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Murray, Clark 8466 S 2315 W Comments Expressing General I124 West Jordan, UT 84088 Opinions Regarding the Proposed Action-Opposition to Proposed Action Newmark, William 591 N Wall St Comments Expressing General I125 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Nichols, Gary 3495 W 8245 S Comments Expressing General I126 West Jordan, UT 84088 Opinions Regarding the Proposed Action-Opposition to Proposed Action Nicholson, 5313 S Cobble Creek Rd. Comments Expressing General I127 Elizabeth Holladay, UT 84117 Opinions Regarding the Proposed Action-Opposition to Proposed Action Novak, Peter 2193 E Laird Way, Suite 5000 Comments Expressing General I128 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Owen, Hannah 1517 E Harvard Ave Comments Expressing General I129 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Owens-Liston, Peta 4842 E Skycrest Cir Comments Expressing General I130 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Paasch, Kelly 2192 E Westminster Ave Comments Expressing General I131 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Paasch, Kelly Process-Purpose and Need-Baldy I132 (Captain) Tram, Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Baldy Tram Padgett, Wayne 1455 Sherman Avenue Process-Purpose and Need-Baldy I133A and B Salt Lake City, UT 84105 Tram; Process- Adequacy of Analysis; Resources-Vegetation-Baldy Tram, Other Projects. Paget, Emmy 832 E Elgin Ave Comments Expressing General I134 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Painter, Matt 1483 E Shane Cir Comments Expressing General I135 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Pease, David 4714 Idlewild Rd Comments Expressing General I136 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Peterson, Matt 635 J St Comments Expressing General I137 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Peterson, Mike 7912 S Oakledge Rd Comments Expressing General I138 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Proos, Eric 2939 Lucky John Dr, Apt 2 Comments Expressing General I139 Park City, UT 84060 Opinions Regarding the Proposed Action-Opposition to Proposed Action Ramras, Zachary 277 N St Comments Expressing General I140 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Rasmuson, David 124 S University St Comments Expressing General I141 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Raspollini, Cristina 729 E 18th Ave Comments Expressing General I142 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Refer, Alex 235 E Burton Ave. Comments Expressing General I143 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Richardson, Willis PO Box 520 Comments Expressing General I144 Oakley, UT 84055 Opinions Regarding the Proposed Action-Opposition to Proposed Action Rosenberg, Neil 1009 S Military Dr Comments Expressing General I145 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Ryan, Sydney 1090 S Lake St Comments Expressing General I146 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Schanback, Warren 1123 E Sunset Dunes Way Comments Expressing General I147 Draper, UT 84020 Opinions Regarding the Proposed Action-Opposition to Proposed Action Scheer, David Ross Comments Expressing General I148 Opinions Regarding the Proposed Action-Opposition to Baldy Tram

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Schleenbaker, 1245 E Ridgedale Ln Comments Expressing General I149 Bradley Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Schmidt, Alex 175 O St Comments Expressing General I150 Salt Lake City, UT 84101 Opinions Regarding the Proposed Action-Opposition to Proposed Action Scott, Sarah 1841 S Paschal Cir Comments Expressing General I151 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Scowcroft, 6775 S Olivet Dr Comments Expressing General I152 Geoffrey Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Shannon, Mike 1252 E Roosevelt Ave Comments Expressing General I153 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Simpson, Scott 3692 S 1300 E Comments Expressing General I154 Millcreek, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Sloan, Eden 2036 E Princeton Ave Comments Expressing General I155 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Sperry, Grant 407 E Emerson Ave Comments Expressing General I156 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Stapley, Alicia 8775 S Oak Valley Dr Comments Expressing General I157 Sandy, UT 84093 Opinions Regarding the Proposed Action-Opposition to Proposed Action Steenblik, Daniel 3224 E Westview Cir Comments Expressing General I158 Millcreek, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Stephens, Tom 4408 S Adonis Dr Comments Expressing General I159 Millcreek, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Stevens, Jeffrey 485 K St Comments Expressing General I160 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Strohacker, Eric 3648 E Spruce Dr Comments Expressing General I161 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Tedesco, Anna 750 E South Temple Comments Expressing General I162 Salt Lake City, UT 84102 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Thompson, James 3801 Viking Rd Comments Expressing General I163 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Thueson, Con 1230 Canyon Crest Dr Comments Expressing General I164 Bountiful, UT 84010 Opinions Regarding the Proposed Action-Opposition to Proposed Action Tolman, Douglas 743 E Logan Ave Comments Expressing General I165 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Trujillo, Anna 2617 S Highland Dr. Comments Expressing General I166 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Voros, Vicki 1146 E Castlecreek Cir Resources-Wildlife-Moose, Comments Salt Lake City, UT 84117 Expressing General Opinions I167 Regarding the Proposed Action- Opposition to Proposed Action Waddel, Taylor 4202 N 400 W Comments Expressing General I168 Lehi, UT 84043 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wade, Ian 4504 W Kestrel Ridge Rd Comments Expressing General I169 South Jordan, UT 84009 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wagner, Lori 208 E Edith Ave Comments Expressing General I170 Salt Lake City, UT 84111 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wagner, Michaela 327 E Hubbard Ave Comments Expressing General I171 Salt Lake City, UT 84111 Opinions Regarding the Proposed Action-Opposition to Proposed Action Walker, Diane 1466 S 400 E Comments Expressing General I172 Salt Lake City, UT 84115 Opinions Regarding the Proposed Action-Opposition to Proposed Action Walker, Robert 2442 E Granite Hills Cir Comments Expressing General I173 Sandy, UT 84092 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wallentine, Craig 2731 Gallivan Loop Comments Expressing General I174 Park City, UT 84060 Opinions Regarding the Proposed Action-Opposition to Proposed Action Weinman, Richard 1920 Cooke Dr Comments Expressing General I175 Park City, UT 84060 Opinions Regarding the Proposed Action-Opposition to Proposed Action Welch, Shannon 10463 S Columbine Cir Comments Expressing General I176 Sandy, UT 84094 Opinions Regarding the Proposed Action-Opposition to Proposed Action

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Westrick, Darian 585 E 2nd Ave, Apt. 2 Comments Expressing General I177 Salt Lake City, UT 84103 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wetzel, Sara 3566 E Lone Brook Ln Comments Expressing General I178 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action White, Andy 5690 Pheasant Lane, Process-Purpose and Need-Baldy I179 Holladay, UT 84121 Tram, Flora Lift. Williams, Kyle 863 E Ramona Ave Comments Expressing General I180 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Winter, Adrienne 811 E Browning Ave. Comments Expressing General I181 Salt Lake City, UT 84105 Opinions Regarding the Proposed Action-Opposition to Proposed Action Wise, Tess 2335 E Stringham Ave Comments Expressing General I182 Salt Lake City, UT 84109 Opinions Regarding the Proposed Action-Opposition to Proposed Action Woeste, John 1904 S Texas St Comments Expressing General I183 Salt Lake City, UT 84108 Opinions Regarding the Proposed Action-Opposition to Proposed Action Woolley, Tasha 1988 S 1100 E Unit 202 Comments Expressing General I184 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Yingling, Jessica 8822 S Blue Jay Ln Comments Expressing General I185 Cottonwood Heights, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Zaccheo, Michael 4367 S Carol Jane Dr Comments Expressing General I186 Salt Lake City, UT 84124 Opinions Regarding the Proposed Action-Opposition to Proposed Action Zdilla, Eric 5193 S Cobble Creek Rd, 5D Comments Expressing General I187 Murray, UT 84117 Opinions Regarding the Proposed Action-Opposition to Proposed Action Zeerip, Zeppelin 2237 S 600 E Comments Expressing General I188 Salt Lake City, UT 84106 Opinions Regarding the Proposed Action-Opposition to Proposed Action Zufelt, Kalina 7817 South Deer Creek Road Comments Expressing General I189 Salt Lake City, UT 84121 Opinions Regarding the Proposed Action-Opposition to Proposed Action Bachorowski, [email protected] Process-Purpose and Need I190 Chris I191 Beacco, Mary [email protected] Resources-Safety-Baldy Tram

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Curley, David 19 Beebe Road Comments Expressing General I192 Quincy, MA Opinions Regarding the Proposed Action-Opposition to Baldy Tram Drew, Anita and [email protected] Comments Expressing General I193 John Opinions Regarding the Proposed Action-Support for Proposed Action Duncan, Steven 1125 Brickyard Rd. #1606 Process-Purpose and Need-Baldy Salt Lake City, UT Tram, Process-Proposed Action-Baldy I194 Tram, Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Baldy Tram Harris, Norman W. 1200 Hillview Drive Process-Proposed Action-Baldy Tram, III (2 emails, same Menlo Park, CA 94025 Comments Expressing General I195 letter with different Opinions Regarding the Proposed recipients) Action-Opposition to Baldy Tram Hildebrand, [email protected] Process-Purpose and Need-Baldy Tram I196 Zachary Keller, Jemina 2910 South Cascade Way Comments Expressing General I197 Millcreek, UT 84109 Opinions Regarding the Proposed Action-Support for Baldy Tram Nelson, Fraser 230 East Broadway #709 Comments Expressing General I198 Salt Lake City, UT 84111 Opinions Regarding the Proposed Action-Opposition to Baldy Tram Nischalke, Mark [email protected] Process-Issues Not Addressed-Skiers- I199 Only Restriction Pace, Stephen 181 B Street Process-Purpose and Need- Salt Lake City, UT 84103 Albion/Wildcat Base Parking, I200 Comments Expressing General Opinions Regarding the Proposed Action-Opposition to Baldy Tram Sanderson, Allen 1744 South 1900 East Process-Proposed Action- Salt Lake City, UT 84108 Albion/Wildcat Base Parking, Gazex Installations; Process-Alternatives; I201 Process-Alternatives-Baldy Tram; Resources-Scenic Resources-Baldy Tram Semerad, Gretchen Holladay, UT Resources-Scenic Resources-Baldy I202 Tram Serr, Deven [email protected] Process-Purpose and Need-Supreme Summer Ski Run Work, Lake Flora Restoration; Process-Proposed Action- I203 Albion/Wildcat Base Parking, Equipment Storage Facility; Process- Alternatives-Baldy Tram; Comments Expressing General Opinions

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Table 1 (cont’d). Respondents and comment categories received during notice and opportunity to comment period. ID Code Name Address Where Addressed in this Report Regarding the Proposed Action- Opposition to Baldy Tram, Support for Other Projects Verzella, Lisa 2951 S Judith St Resources-Vegetation-Baldy Tram, I204 Salt Lake City, UT 84106 Resources-Wildlife-Pika White, Kevin [email protected] Comments Expressing General Opinions Regarding the Proposed I205 Action-Opposition to Proposed Action, Opposition to Baldy Tram Whittaker, Chad Salt Lake City, UT 84108 Comments Expressing General Opinions Regarding the Proposed I206 Action-Opposition to Baldy Tram- Opposition to Other Projects

I207 Woeste, John 1904 S. Texas Street Process-Purpose and Need-Baldy Tram Salt Lake City, UT 84108 Wolf, Margaret [email protected] Process-Proposed Action- Miscellaneous, Resources-Recreation- Wildcat Replacement, Comments I208 Expressing General Opinions Regarding the Proposed Action- Support for Baldy Tram, Support for Other Projects

The comments received addressed aspects of this National Environmental Policy Act (NEPA) process, resource-specific concerns, and opinions regarding the proposed action or elements of it. Given the limited number of comments received, all are included in this report. Each comment is quoted, in italics, under the appropriate topic or resource area, followed by an agency response indicating how it is being considered in this NEPA review. Similar comments were grouped where appropriate, followed by a single response. Comments that simply expressed opinions were not responded to but will be considered by the Responsible Official in formulating a decision regarding the proposed action. RESULTS

PROCESS

Purpose and Need Alta's plan and the master plan proposal for a shopping center at the top of the canyon do not address the real issues of canyon congestion, user dismay and pollution. (I190-1) Response: EA section 1.5 outlines the purpose and need for this proposed action, which centers on making more efficient and safe use of the resources within the permit area by replacing outdated equipment, upgrading service facilities, and taking advantage of new technology. As discussed below under Issues Not Addressed, ski area visitation, canyon carrying capacity, and traffic and parking would not be notably affected by this proposed action but are larger issues, stemming primarily from rapid population growth on the Wasatch Front. Maintaining functional ski areas is part of the WCNF 2003

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Revised Forest Plan (Forest Plan), and it helps accommodate growing recreational demand and minimize the environmental problems cited in the comment by concentrating use in defined, relatively small areas and providing parking, restrooms, and other essential services. This EA does not consider a shopping center as that was not included in Alta Ski Lifts’ (ASL) proposal. Albion/Wildcat Base Parking I think the intrusion into riparian meadow areas is a significant impact that should trump the weak argument for parking expansion. This seems all the more reasonable when one considers this as the head of the watershed. (I30-2) [Albion/Wildcat Base Parking:] I would also argue that the current traffic congestion comes with direct impacts like congestion and pollution and indirect effects like the detritus from brake pads and tire wear. It's all cumulative and it's all environmentally degrading. (I30-3) I fail to understand the rationale for adding lift capacity to an area that is already grid- locked with traffic and lacking a reliable parking and mass transit approach for much of the ski season. (I200-1) If transit is enhanced to accommodate more people, then are these spaces and the additional pavement really necessary? (O1-6) Far from moderating congestion in Little Cottonwood Canyon, Alta’s increase in parking spaces is more likely to exacerbate the problem. (O2-6) Response: EA section 2.4.1.1 describes the rationale for this project, which includes a necessary rebalancing of capacity between the lots, visitor safety and convenience, and replacement of capacity lost to past and anticipated transit improvements. There would be not net gain in parking capacity. Project impacts on riparian resources are documented in EA section 3.4.1.3, as are design criteria and mitigation to protect water quality from potential traffic and parking effects. See also Issues Not Addressed – Transportation and Parking below. Baldy Tram I understand there are legitimate avalanche control questions to be addressed, but am not convinced that this will be solved by a tram. (I1-1) I have heard that Alta is proposing to build a Tram to the top of baldy with the excuse that it is for safety reasons. The "safety factor" is completely unwarranted. (I101-1) Perhaps when UDOT takes the howitzer out of service there might be a stronger rational for rethinking primary avalanche control, but I would argue that Alta has successfully managed avalanche control in this area without the alleged benefits of the tram. (I30-4) The "Project Rationale" section on page 17 of the Environmental Assessment does not offer a sufficient rationale for the tram. (I92-1) May I first say as an avalanche professional, as is typical with these building requests, there is really no safety or financial benefit for adding a tram to baldy for the purpose of avalanche mitigation. With it’s exposed nature hand charge routes up baldy are relatively simple to keep safe— much more so than many of their other routes. Second, avalanchers are extremely safe and affordable—a fraction of the cost of a new tram. (I132-1) Avalanche control, while perhaps easier with the new system, is not absolutely critical as it apparently has been effective as it is currently conducted. (I133-5)

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The Baldy Tram also has sketchy supporting logic. The chutes are not stable often enough to justify the visual and ecological impacts of such an addition. Devil’s Castle has a number of Gasex [sic] proposals. It makes more sense to add a few of this on Baldy and would also allow the retirement the Howitzer and Avalaunchers. (I179-2) The Mt Baldy tram is couched in the frame of “snow safety” but is simply a veiled bid for ski area expansion. Such expansion is an unsightly and unnecessary intrusion of infrastructure and the required roadways to access the terminals. (I66-2) There is no justifiable reason to approve a Baldy Tram, and Alta's excuse that the tram would allow ski patrol to more quickly access avalanche terrain is laughable. As soon as the tram is completed they will surely announce plans to allow the public to enjoy their new investment. (I120-2) I don't think Alta should get permission to build the proposed tram. Their rationale for 'avalanche control' rings hollow; I believe the primary purpose is to find a way to charge a high fee to transport skiers in the tram to more terrain. It isn't worth the potential damage to the existing landscape. (I196-1) I am writing to express my objection to the proposed tram to Mt Baldy. There are alternative methods of avalanche control available and I believe this is just being used as an excuse for Alta to place a lift at an unacceptable location. (I194-1) I am writing to state my opposition to Alta's proposed plan to place a tram to the top of Mount Baldy. The need for avalanche control can be done without a tram, as it has been done for years. While the supply of ammunition is running low, the supply with last years. This will allow for other solutions to be implemented. I would be in favor of Gas-X stations. A tram would cause entirely unacceptable visual damage to the natural landscape. (I207-1) Response: EA sections 2.4.2.1 and 2.6 have been expanded to flesh out the rationale for this project. Key points of that rationale are:  There is increasing pressure industry wide to replace artillery-type methods (e.g., Howitzers and Avalaunchers) for various reasons, including public and operator safety.  Mt. Baldy poses extensive avalanche-control issues involving a significant proportion of the ski area’s most popular terrain. If artillery-type methods could no longer be employed, and no alternative was available, this key terrain would frequently be closed.  For safety reasons, artillery-type control methods can only be used when Alta and Snowbird are closed to the public. Alternative technologies, including the proposed tram, can be employed during the operating day, shortening and reducing the frequency of closures.  The full range of alternatives was considered before the tram option was finalized. See response regarding potential future development below under Proposed Action – Baldy Tram and under Scenic Resources. (I179-2) The proffered reasons or logical basis for the tram, that it would reduce dependency on the Howitzer and Avalaunchers, as well as skier access do not justify a permanent alteration of the NFS land. The tram could not be used when there are high winds, which is often part of the cause for the need to do avalanche control work, and there are very few runs or lines for skiers to access from the top of Baldy. (I92-2) Response: As noted in EA section 2.4.2.1, one consideration in selecting the proposed top terminal location was protection from the prevailing westerly wind. The expanded project rationale also notes that

21 the 23 distinct avalanche starting zones on Mt. Baldy affect is significant amount of key ski terrain and that remotely controlled systems would not be practical given the number of starting zones. Alta’s justification of building a tram up Baldy for the purpose of avalanche control fails to include any in-depth analysis of the effectiveness of the techniques they intend to employ. (O2-10) Alta fails to provide, and the Forest Service failed to demand, any additional information regarding Alta’s plan for effectively employing ski compaction as a successful method of avalanche control; rather, less a technique for mitigation, the ski compaction argument, when unpacked, appears to be a ploy intended to do nothing more than justify a costly tram to the summit of one of our state’s most prominent peaks. (O2-11) The rationale for the Mt Baldy tram includes a statement that skier compaction is an effective means of avalanche control (p 22). While that statement is true, elsewhere the document states that this lift would rarely be open to skiers as it is primarily for snow safety, hence the skier compaction would rarely come into play. (I17-2) Response: The use of hand charges, ski cutting, and skier compaction by ski patrol to control avalanches is a well-established practice at Alta and most other ski areas in the world. Further analysis is not required to assess its efficacy. As to skier compaction, this process can involve ski patrollers on their control routes or public skiers. It does not imply or require high levels of skier traffic. As discussed in EA section 3.5.3, public use of Mt. Baldy’s diverse ski terrain has occurred to date and would continue in the future under this proposal. Skier compaction would continue to be stabilizing factor under either scenario. Allowing additional pressures on fragile high alpine ecosystems at a time of such drastic climate change is irresponsible, particularly when the development is of an unnecessary tram to impose an unneeded avalanche mitigation regime when an effective one has already been in place for decades. (O2-12) Response: The preceding responses address the project rationale, and the EA addresses its potential environmental effects. The Responsible Official will consider this information in formulating a decision. Sunnyside Lift Replacement Redundancy concerns lead to the rationale for an updated Wildcat lift, and make sense for the Albion base area to also have two lifts. (I16-3) Response: ASL’s proposal has been revised to retain the Albion lift for redundant capacity. In addition, a unique lift at the base of the ski area, with beginner skiers, would lead to greater confusion, longer lines and more empty chairs/cabriolet/gondolas, as skiers will have even more difficulty navigating the system than they do now. (I17-5) Response: EA section 2.4.3.1provides the rationale and description of the Sunnyside replacement lift. Its higher capacity would reduce lift lines, and detachable lifts are easier for beginners and non-skiers to use. Out-of-base capacity from the Albion base area should improve with this lift replacement. Part of the rationale is to allow summer use. Does this constitute a commitment by ASL to operate this lift in the summer? If that commitment is paired with closing the summer road (FS road 028) to private vehicles, this would be a welcome change to Alta. (I17-7) I am all for eliminating the never running eye sore of a lift Albion. And if Sunnyside can get an upgrade on mostly existing foundations and towers, I am all for it. Especially if this means it will run the in the summer reducing traffic on the summer road. (I27-5)

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Response: The project rationale and description in EA section 2.4.3 include summer use of the Sunnyside replacement lift. This does not necessarily constitute a commitment, but it indicates ASL’s intent. Closure of the summer road is outside the scope of this analysis and decision. Albion Lift Upgrade Similar rationales dictate upgrading Albion to a newer higher capacity lift, resulting in lift redundancy with Sunnyside, greater reliability, and increased skier comfort. (I16-5) Response: ASL’s original proposal called for removing the Albion lift and upgrading Sunnyside to provide sufficient capacity and increased reliability. The ski area subsequently decided to leave Albion in place to provide redundant capacity in the event that the new Sunnyside lift was out of operation. The Albion lift in its current configuration would serve that purpose. Flora Lift Based on movement away from fixed-grip lifts we have concerns regarding the planning of the Flora lift and it being a viable solution for the issues related to snowcat time and snow safety which it seeks to solve. The proposal for the Flora lift needs additional refining before approval. (O1-22) If the East Baldy traverse is unpleasant due to wind and blowing snow, it seems that a lift in this area would also be heavily affected by wind and therefore potentially closed frequently. (O2-32) I also do not think Alta should add the Flora lift and close the EBT as I do not see East Baldy being open very often for skiing, and even getting skied that much when it is open. Yes, the EBT can be painful on some days, but it is more efficient than taking a lift back to the top of Germania pass. (I1-4) East Baldy is described as an expert ski run and the rationale for eliminating East Baldy Traverse (EBT) is to extend that expert ski run, but the extension, i.e., below EBT is not expert, so the extension rationale is meaningless. The reason East Baldy is not skied is that it is rarely open, not because of the interruption due to the EBT. (I17-9) That said, the elimination of a groomed EBT will likely result in a more favorable skier experience since that is frequently an uncomfortable traverse to use. (I17-10) I find most of Alta’s development plan reasonable, but am unconvinced the rational for the Flora Lift is valid. Being a frequent skier for many years, I have not noted the East Baldy Travers closed “often” and I don’t find it “more often than not, unpleasant because of wind and blowing snow.” I imagine there are hard statistics available to explore this…I’m surprised to hear the traverse cuts “an expert” run (that I’ve seldom seen used as it has not been open often in the past) in half as everything below the T is less than expert and I don’t know how far down you have to consider that run to make the T be at the midpoint… Using it to access the Collins side seems a bit counter productive. Why would I ride up Sugarloaf to drop down to Flora it get up to Collins instead of continuing down from the bottom of Sugarloaf and taking the rope over to Collins. I might get another high country run, but lift line and ride times may make it a longer venture than going around the bottom. (I179-1) The EBT is a control and maintenance nightmare. As a skier though I see it equally a nightmare to ride Sugarloaf, get 10 turns then stand in line again and ride Flora to get the same place you used to be able to get to with a quick traverse. (I27-9) Response: The rationale for the Flora lift was spelled out in the scoping notice and the for-comment EA. The same conditions that result in closure of EBT could result in closure of the proposed lift, but the lift

23 would not require the clearing and grooming necessary to maintain the traverse, and the lift would be less susceptible to avalanche risk than the traverse. Congestion in Devil’s Elbow and the low speed of the transfer tow are the main constraints to skiing to the bottom of Sugarloaf and across to the Wildcat base when the traverse is closed. The heavy use of the EBT when conditions allow supports the need for a high-elevation connection between the two sides of the ski area. The project rationale in EA section 2.4.4 has been revised to note that the traverse crosses the bottom of the East Baldy run. Supreme Summer Ski Run Work I do not understand the need or the action proposed. There is an access road to the top of Supreme. (I27-12) Supreme terrain work. This is vague, what work exactly? Im schepitcal [sic] of and terrain work, that’s what snow-cats are for. (I203-9) Response: As discussed in EA section 2.4.5.1, the purpose of these projects is to create groomed ski runs in the Supreme pod, thus providing more reliable routes down, particularly for less advanced skiers. The access road is narrow and does not fulfill this need. The proposed work is described in EA section 2.4.5. Alf’s Restaurant Building Addition Additional space at Alf’s should be devoted to dining, not retail. (I17-12) I suggest we wait to see how the new lift line will be worked in that vicinity before approving additions to Alf’s in this area. (I16-16) Response: As discussed in EA section 2.4.6.1, the rationale for this project is to provide sufficient space for all services provided at Alf’s, including food service. The Supreme lift installation is complete and, as discussed in EA sections 1.4 and 2.4.6.1, required a minor revision of the addition footprint to maintain a 50-foot buffer from a culverted channel. Sufficient space for improved skier circulation remains. Watson Shelter Addition I agree that building is too small to support the skier traffic it sees on a day to day basis. The additions environmental impact seems reasonable. I just wonder if there is enough space being added? (I27-14) Response: EA section 2.4.6.2 outlines the project and its rationale, reflecting ASL’s view of anticipated space needs. Lake Flora Restoration I think it is in the lift company's best interest to secure water for snow making. (I27-16) Lake restoration at the top of Glory Hole. Yes, more lakes are better. (I203-13 Response: The scoping notice for this project discussed ASL’s snowmaking water scenario and their need to secure additional water storage. Issues associated with the Lake Flora proposal lead to its being dropped from this proposed action but retained in the ski area’s Master Development Plan (MDP) pending review of storage alternatives and appropriate review and approval of the most desirable option.

Proposed Action Albion/Wildcat Base Parking One of the current issues with the Snowpine parking is the complete lack of any separation between the parking and SR210. On busy weekends there is no road just a chaotic mess of parking that in many cases would prevent emergency vehicles to pass through. The redesign fails to address this issue. In fact, the redesign in all likelihood exacerbate the situation. Further, the EA lacks any consultation with UDOT on the

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redesign. The parking MUST be fully separated from SR210. There should be a single point of access like there is for the WildCat parking lot. (I201-1) Response: The design for the project is conceptual at this point, as appropriate for this phase of the planning process. This issue will be considered in final design of the parking lot improvement, and Utah Department of Transportation (UDOT) will be an active participant in the process. Note also that the preliminary design of this project has been revised to add a small expansion to the uphill side of the existing Albion lot, increasing flexibility to provide separation from SR 210. See EA sections 1.4 and 2.4.1. SLCDPU requests that UWCNF provide supporting numbers that the EA references as there are no maps showing parking stall counts provided in the EA. (A2-2) Response: Parking stalls are not delineated with striping at Alta or most ski areas for a number of practical reasons (e.g., snow cover, snow plowing, etc.). The parking figures in ASL’s proposal were derived by reviewing past aerial photo coverage of the parking lots, overlaying areas subsequently allocated to public transit, and counting the actual number of parking places eliminated. This is an ongoing process involving Alta and the UWCNF, and documentation is available in the project record. …it is possible to make this a gravel area that may even grow grasses on it in the summer to eliminate heat island issues caused by blacktop? (I203-2) Response: Gravel parking lots at ski areas make snow removal difficult and allow contaminants from vehicles to seep into the ground. As a result, paving is generally considered the best option. Baldy Tram Further, I'm concerned that should the United States Forest Service grant Alta's request for the Tram, there are no provisions to stop Alta Ski Lifts from further developing the summit of Mt. Baldy. (A1-3) Save Our Canyons is significantly concerned that additional infrastructure (warming huts, bathrooms, etc) will be required once a tram is built to Baldy and that the tram represents merely the first step in developing this summit. (O2-14) In addition, given the terrain, the only real need for a tram is to transport customers to a future restaurant/conference center. Alta’s reported response to this question by Save Our Canyons was concerning: “Baldy’s summit is private land. We can do as we want on the peak and we refuse to limit ourselves by saying there will be no additional development to Baldy’s summit.” (I66-3) As much as I love Snowbird too, I love the two resorts for different reasons and don't think they should be the same. I am an architect, who would be seemingly for more development, but I agree with the sentiment that once the tram is in place, it could lead to more unnecessary development on undeveloped land. I have seen the changes to resorts to Snowbird and Park City in recent years, and am dismayed to think that Alta could follow suit. (I71-2) That would see [sic] like the real objective it [sic] to transport skiers and increase Alta's uphill capacity and to set them up for future development on Mt Baldy. (I111-1) I realize that this proposal is within the existing area boundaries and I am not opposed to all improvements within those boundaries. However Alta has refused to agree to no more development on Mt Baldy in the future. Like a conference center or restaurant. (I111-4) When Carl Fisher of Save our Canyons asked Alta representatives if they would commit to not placing any additional structures on the peak, they would not and we need do is look a bit to the West at Hidden Peak to know what resorts really aspire to do. (I194-3)

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Response: ASL’s Mt. Baldy proposal includes only construction of a tram crossing National Forest System (NFS) land. The UWCNF accepted the proposal because, as outlined in the EA and the response above under Purpose and Need – Baldy Tram, it addresses a legitimate public need. Beyond that, ASL owns private land on Mt. Baldy. While government entities including Salt Lake County and the Town of Alta have regulatory roles in development of private land, the Forest Service’s role is limited. The Responsible Official will consider the potential for future development supported by the tram in formulating a decision. Alta Ski Lifts responded that the tram may operate during summer months at some point in the future. Also, that Alta was holding open the possibility of future infrastructure on Baldy following the construction of the tram. Both of these answers should have required the Forest Service to analyze potential summer impacts to wildlife and botanic communities. (O2-13) Once a tram is built, requests for summer access are eminent and turning folks away would be unlikely unless approval is conditioned on winter use. We are very concerned that increased access will have devastating impacts on the sensitive plants. For this reason, if approved we ask the USFS to restrict the tram to winter use only. (O1-13) We request that any approval be only for winter use and would like further discussion regarding what can be done to assure the public that there will be no additional development. (O1-16) Regardless of this proposal’s status, we request the USFS, ASL Ski Area, and Snowbird should work together with other stakeholders to reduce impacts to the top of Mt Baldy from skiers, snowboarders, and hikers through trail design and education. (O1-18) Response: Summer use of the lift has not been proposed or addressed in this EA and would require a separate proposal and analysis if ASL wished to pursue it. See preceding response regarding additional future development, and see EA section 3.4.2.3 regarding potential impacts of winter use on alpine vegetation. Further, while the EA states that the Baldy Tram is 340 feet off the summit, it should clearly state that these are linear feet, which they are – we checked. Otherwise the implication, one that it appears the EA is trying to perpetuate is that the tram is 340 elevation feet off the summit, which is not the case. This is a significant different and should be clearly stated. A difference of 340 linear feet means the tram will be featured prominently on the ridgeline. (O2-9) Response: EA sections 2.4.2.1 and 3.5.2.5 have been corrected to indicate that the site is 340 horizontal feet and 90 vertical feet below the summit of Mt. Baldy. The viewshed analysis documented in the EA was based on the correct location, so the conclusions remain the same. As conditions allow, we hope that skiers are allowed to access the peak by hiking and are not restricted to only accessing the top via the tram. (O1-11) Response: Hike-to access to Mt. Baldy would be managed as it has been in the past. It would be opened once avalanche control efforts were complete. If part of Mt. Baldy is within Snowbird’s terrain, avalanche control work now must be coordinated between the two ski areas, the USFS, and UDOT. Would the proposed tram would [sic] change that interplay, or eliminate the need for the Howitzer or Avalaunchers currently in used [sic] for either or both ski areas? (I16-14) Response: Avalanche-control activities in upper Little Cottonwood Canyon have historically been coordinated among these entities and would continue to be. As indicated in EA section 2.4.2.1, the Peruvian Ridge gun and building would remain in place as the building belongs to the Utah Department

26 of Transportation and the gun is used to control side paths across the canyon that threaten SR 210. No other changes in avalanche control operations are proposed. And further, I respectfully recommend that the Forest Service establishes a permanent natural area encompassing Mt. Baldy that bans forever more any man made structures of any type. (I195-2) Response: The Forest Plan established management priorities for the NFS lands on the Forest. The land around Mt. Baldy is to be managed for developed recreation, and man-made structures are an integral aspect of that use. There is also a substantial amount of private land on and around Mt. Baldy where the Forest Service has no authority to oversee development. Gazex Installations The EA is deficient in that it lacks specific details on the exact number of devices that would be needed. Because of the lack of details the number of out buildings can not be determined. I.e each location "would have four to eight exploders. An 8 foot by 8 foot gas storage unit would be need for every four exploders." (I201-5) Further, the EA is deficient in how the gas lines going from any potential out buildings would be permanently installed and buried. The terrain is in general solid rock or a boulder fields that are subject to movement. Burying the lines will required extensive excavation thus creating a visual impact that during the summer months is otherwise a natural undisturbed area. (I201-7 dup) The EA is deficient in that it should have included greater details and alternatives such as seasonal installation of the gas lines. (I201-8) Response: The specific Gazex installations have not been designed yet, as appropriate at this phase of the planning process. Enough detail was provided to allow analysis identifying any significant environmental effects. Text has been added to EA section 2.4.2.2 describing installation of the gas lines in shallow, hand-excavated trenches. Alf’s Restaurant Building Addition During a meeting on 11/14 with Mike Maughan (General Manager, Alta Ski Area) and Bekee Hotze (District Ranger) to review Alta’s MDP, Mr. Maughan acknowledged the issues with the [Alf’s restaurant building addition] layout as presented and suggested it would be changed. (O1-27) …since this proposal involves culinary water and sewer, Alta would have to apply for a building permit with the Town of Alta and they have a stream setback ordinance that the ski area would have to comply with that would likely affect the proposed proposals location. For these reasons, the ski area should be asked to take some time to revise the proposal based on current conditions. (O1-28) To the extent any addition interfere further with stream beds, the construction [at Alf’s restaurant] should be modified. (I16-15) A recent letter from the University of Utah Department of Biology (attached) indicates that soil disturbance closer than 30 meters from a stream is detrimental to stream health. If the Alf’s restaurant expansion violates that setback, and it appears that it does, then it should be modified so that it remains at least 30 meters away. (I17-11) Response: EA sections 1.4 and 2.4.6.1 note that ASL has modified the Alf’s restaurant addition to maintain a 50-foot buffer between the building and the culverted intermittent channel south of the building. EA section 3.4.1.1 identifies the impact indicators used in this analysis, defining RHCAs and identifying the project-specific riparian management objectives to be achieved.

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Equipment Storage Facility The favored spot (11a) would have a greater impact on vegetation and bird habit than the alternate (11b). (I27-15) Equipment storage facility. Where? Yes if low profile and in a practical location. (I203- 12) Response: As indicated in EA section 2.4.6.3, ASL has opted for the site closer to the parking lot. Note also so that, as discussed in section 1.4 and 2.4.6.3, that location has been shifted back 30 feet from the parking lot to allow expansion of the lot on the uphill side. SLCDPU supports this [equipment storage facility] so long as it does not reduce the existing numbers of parking stalls overall, and adequate measures are taken during and after construction to prevent any increase in localized sedimentation or spill-risks to the Creek. (A2-20) Response: See preceding response. The structure would not impinge on the parking lot, and design criteria and BMPs to manage sedimentation and spill risks. Miscellaneous A balance between engineering costs and environmental review needs to be achieved. The bulk of project engineering should be at significant completion prior to construction season for more adequate review and approval. (A2-8) Response: The question of what level of project design and engineering should be completed before initiating NEPA review is a good one. While it may be unreasonable to require expensive, engineered plans for a project that may be altered as a result of the NEPA process, conceptual plans may not provide the detail necessary for sufficient NEPA review. The regulations governing the NEPA process help resolve this question. Key points are that NEPA reviews are to be completed early in the planning process (40 CFR 1501.1[a]), they are to focus on significant issues and deemphasize non-significant issues (1500.4[g]), and they are to be analytic rather than encyclopedic (1500.4[b]). Reflecting this direction, conceptual designs may provide sufficient detail for NEPA review, but if initial findings suggest possible significant impacts, additional design and engineering may be needed to identify and avoid such impacts. We try to achieve this balance. I submitted comments to the original plan, and incorporate those comments by reference here to the extent that the plan was not changed despite the comments made and the concerns raised there and by the 149 other commentors from May and June 2016. (I16-1) Response: No scoping comment was received from this commenter, but 127 agencies, organizations, and individuals did provide comments that were considered in refining the proposed action and establishing the scope of the EA. Among other things, the Lake Flora project and the Albion lift removal were dropped from the proposed action The Special Use Permit maps, as depicted in this document, continues to include areas of private lands and forest service lands. No rationale has been provided shy [sic] private lands are under the jurisdiction the forest service, and then under the special use permit operations of a permitee, even one managed as well as ASL. (I16-2) Response: The purpose of NEPA review is to identify and disclose significant environmental impacts of federal actions, and this proposed action has the potential to affect private as well as NFS lands. As a result, the maps generally indicate the ski area boundary rather than the special use permit boundary. I just wish [Alf’s restaurant building addition] was implemented at the same time as the lift. All the soil and vegetation around Alfs have been destroyed with the Supreme lift constriction [sic]. Now there will be re-vegetation efforts and just as any of those plants

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have the slightest fighting chance the area will be destroyed again for Alfs construction. (I27-13) Response: It is true that some efficiencies in site rehabilitation and other areas might have been gained if these two projects could have been done concurrently, but the disturbance footprint for Alf’s restaurant addition is quite small, particularly since its recent redesign (EA sections 1.4 and 2.4.6.1). Disturbance would be restricted to previously disturbed areas that currently support little vegetation. Overall, I feel the projected “improvements” are too many at one time to fully evaluate and comment on all. Was this the intent? (I66-1) Response: Reviewing groups of related projects in the same environmental review is a basic requirement of NEPA. The purpose is to make sure that impacts that may not be significant individually but may become significant when looked at as whole are identified. That is, in part, why we are offering three separate opportunities for public review in this EA process. Takeaways: 1. Do not interrupt/close current trails for construction. (I27-6) Could the ‘ski run improvements’ take into account how they will affect biking and hiking? Perhaps the roads could be graded with summer mountain biking and hiking in mind. (I73-3) Response: We try to keep trails open and functional as much as feasible during construction of ski area projects, but in some cases temporary closure is necessary in the interest of public safety. The only roads included in the proposed action are short spurs connecting to lift terminals, of little value for hiking or biking. I am not sure if this is in current plans, but I think as a request from all advanced Alta skiers is PLEASE DO NOT GROOM THE HIGH TRAVERSE. Access out to High Rustler and eagles nest is scary and challenging, granted the traverse itself is a bit of a rodeo and pretty scary sometimes itself, this first challenge of getting to these areas restricts abilities to access of advanced terrain to remain only for advanced skiers. (I208-5) Response: Improvements to the High Traverse are part of ASL’s MDP but not included in this proposed action.

Issues Not Addressed Increased Visitors The draft EA analyzes many areas in depth, but excluded from in-depth analysis air quality, transportation and parking, utilities, socio-economics and impacts of more visitors to ASL operations. (I16-8) Assuming there will be no more visitors or visitor impacts to the environment due to that “non-increase” of visitors is insincere. ASL terrain is and will continue to be effected despite parking being capped and thinking otherwise is outdated. Try to purchase food, use the restroom, find a table, or wait in the lift lines. Delays are not infrequent, this despite efficient operations from well trained employees. (I16-10) It is clear that there is an increase in the number of visitors hence the impact from that greater number and failing to evaluate that impact leads to an incomplete analysis. (I16- 11) Response: The purpose of the proposed action, outlined in EA section 1.5, is to replace outdated equipment, upgrade service facilities, and take advantage of new technology. The proposed action does not open any new terrain; it simply updates the infrastructure serving existing terrain. The intent is not to increase visitation but to maintain numbers by meeting the needs and expectations of today’s skier

29 market. The ski area’s capacity would not change appreciably. EA section 1.8.2 has been revised to flesh out this rationale in more detail. Based on these considerations, this issue is outside the scope of this analysis. Peak days at Alta and other ski areas are by definition crowded and therefore less enjoyable for most visitors, but this proposed action is not anticipated to increase peak day visitation. See also the following response. Properly identifying any actual increase in the number of visitors and their attendant impacts on the ski area will likely lead to a more complete analysis. Parking, or lack thereof, is no longer the lid on visitor impacts if [sic] once was. (I16-9) Response: See the preceding response regarding growth in visitation. In regard to parking, as per the Forest Plan, limiting parking in the canyons (including ski areas, summer use homes, developed and dispersed recreation sites) to 2000 levels was intended primarily for watershed protection. Furthermore, the Forest Plan permits modification of this limit to facilitate mass transit and/or for watershed protection. The Forest Plan parking limitation does not address “congestion,” which would be a UDOT/Federal Highway Administration (FHWA) issue, but does address visitor impacts on the environment, and is directly relevant to growth in visitor numbers and associated impacts. Salt Lake County’s 1989 Wasatch Canyons Master Plan (currently under revision) restricts parking on private lands at ski areas unless they “contribute to solving transportation problems and improve the physical environment.” Thus, the master plan addresses both congestion and environmental (watershed) issues, and is directly relevant to the commenter’s concern of visitor impacts on the environment. Beyond that, this issue is outside the scope of this analysis. Canyon Carrying Capacity To manage the natural resources in both summer and winter, we request the USFS provide further guidance on the carrying capacity or number of visitors to the canyons in order to maintain a quality recreation experience while also preserving the environment and ecosystem services which are of great value to our community. (O1-5) Little Cottonwood Canyon is already built to capacity and must be managed extremely carefully going forward. (I120-3) Response: The mission of the Forest Service is to sustain the health, diversity, and productivity of the nation’s forests and grasslands to meet the needs of present and future generations. One of the most important products that the UWCNF provides is quality recreational opportunities. Another is clean drinking water for neighboring metropolitan areas within Salt Lake Valley. Recognizing the importance of both, the UWCNF’s strategy is to balance provision of recreational amenities and opportunities with natural and financial resources. In terms of permitted ski areas, the UWCNF does not specify carrying capacity within permitted ski area boundaries because ski areas determine their own carrying capacity as part of their business models. Summer Use … efforts need to be made to better manage summer visitors before we love Albion Basin to death. (O1-20b) We request that the USFS conduct a summer carrying capacity study to better understand and be able to plan thoughtfully for summer recreation and natural resource protection in Albion Basin. (O1-20a) Regarding the plan itself, I find it disheartening that summer, and non-ski season impacts don’t seem to be considered. (I73-2)

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Response: See the preceding response. In terms of this proposed action, the only projects potentially affecting summer use of Albion Basin are the Albion parking lot expansion and the Sunnyside lift replacement. These projects together should mitigate the effects of growing summer use somewhat by reducing the number of cars using the summer road to access the basin – an indirect effect. This issue is outside the scope of this analysis. Transportation and Parking Save Our Canyons would like to see more attention given to accommodating public transit options both into the canyons and to the canyon mouth park and ride lots. (O2-5) More paving for parking runs counter to suggestions which have been made regarding improving public transit. (I26-1) Thus, while I am not against the proposal for an enlarged and safer Albion lot, connecting west up the hill towards the Snowpine. And I am for greater UTA accessibility. I cannot fully back this proposal because I think it fails to address major parking and safely issues. As a year-round resident I do not want to see construction disrupting the daily events all summer long when I feel that construction will be 'out- dated' and inefficient the second it is completed. Think bigger. (I27-1) … our canyons are already experiencing significant overuse/congestion. Parking changes discourages mass transit, and only exacerbates the conflict of excessive cars in the canyon. (I66-5a) further development of the Ski Resort including added lifts and more paved parking lots is not what this unique and special area needs. Nowadays Little Cottonwood Canyon (LCC) is traffic-choked and parking at trailheads and the resort is often not to be found. Unfortunately far too many vehicles have only 1-2 people in them with too few actually carpooling. And the city bus service is a joke most of the year. (I85-1) There is a huge transport problem in Little Cottonwood Canyon and increasing lift capacity without addressing that will make an already bad situation worse. (I111-2) Little Cottonwood Canyon cannot handle the traffic it currently experiences as is, and should not be subjected to more harm just to increase profits of Alta Ski Area. (I120-1) We need better transportation options, not more development. (I5-2) Response: The problems associated with increasing vehicular traffic in Little Cottonwood Canyon have been recognized for decades. In response, the UWCNF and Salt Lake County have limited parking in Little Cottonwood Canyon. The UWCNF has also been an active participant in all community efforts to improve transportation planning, increase transit, develop new transportation systems, and deal more effectively with this issue. However, in this case as in most others, it is very difficult to get people out of their cars, and the options are controversial and costly. The UWNCF, along with Utah Transit Authority (UTA) and Salt Lake City Department of Public Utilities (SLCDPU), is currently participating in the preparation of an Environmental Impact Statement being led by UDOT to evaluate potential transportation and mobility improvements in Little Cottonwood Canyon. Additionally, the UWCNF is collaborating with Salt Lake County to address Forest concerns and issues in the County’s revision of the 1989 Wasatch Canyons Master Plan. In the meantime, this proposed action reflects an appropriate commitment to traffic management by maintaining the cap on ski area parking, including adjustments to parking space to accommodate transit use in accordance with the Forest Plan. Beyond that, this larger issue is beyond the scope of this analysis. See also the preceding responses under Increased Visitation and Canyon Carrying Capacity.

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Employee Housing For ASL to contemplate larger operations, it is essential for additional housing to be provided and parking for those employees be added to prevent those employees using the parking areas for day skiers or existing residents and employees. (I16-7) The Watson Shelter additions should include more on-site employee housing as there is inadequate employee housing in LCC now and essentially none at Watson’s. (I17-13) Response: Like summer use of Albion Basin and traffic congestion in the canyon, employee housing at Alta is an ongoing issue. The ski area works to provide enough housing at Alta to maintain at least the minimum personnel necessary to open the mountain when the highway is closed and to provide for the needs of guests staying at the ski area. Given high real estate prices and Forest Service restrictions on developing employee housing on NFS land, this is a challenge. However, beyond a couple of lift personnel to staff the Baldy tram, this proposed action would not require new ski area employees and thus would not worsen this issue. As a result, this issue is outside the scope of this analysis. Lake Flora Restoration While restoring Lake Flora is not in the MDP currently, the area must be evaluated in its totality from water storage, and impacts on flora and fauna. If construction of new Flora lift has impacts on the flora and fauna in the vicinity of the former Lake Flora bed and tributaries, what effect will construction and maintenance of the lift have on those habitats? (I16-6) Response: EA sections 3.4.1, 3.4.2, and 3.4.3 address the potential effects of the Flora lift on watershed, vegetation, and wildlife resources, respectively. A topographic divide separates the two project areas, and no impacts on the Lake Flora area were identified. As explained in EA section 1.4, the Lake Flora project has been dropped from this proposed action. It remains in the ski area’s MDP but could not be implemented without NEPA review. Potential cumulative effects would be considered if such a review were initiated. Until that occurs, this issue is outside the scope of this analysis. Skiers-Only Restriction Alta is requesting permission for improvements on public land while they limit access to only one class of winter sports enthusiast, skiers. Any improvements made should be accessible and usable by all. (I199-1) Response: ASL’s ban on snowboards is a business decision within their authority to make and is outside the scope of this analysis.

Alternatives The EA lacks alternatives that should be investigated based not on the whims of the applicant but on what is best of the public lands. (I201-2) Response: It is difficult to respond to this comment because it does not identify specific alternatives. EA section 2.2 and 2.6, respectively, describe alternative development and alternatives considered but not carried into in-depth analysis. The alternatives considered were based primarily on scoping input. Albion/Wildcat Base Parking Build parking structures in multiple levels, limit individual driver access (This includes me, make me carpool, force me to find better solutions to traffic pressures, I will adapt) … (I21-2) The argument for enhancing public safety by eliminating the walk between Snowpine and the Albion base though perhaps legitimate only offers one alternative. Perhaps some

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other other possibilities like improved segregated pedestrian routing or a parking lot shuttle could be considered? (I30-1) Alternative means of assisting skiers to the existing Germania parking should be explored rather than enlarging Albion parking. (I66-5b) Response: EA section 2.4.1.1 explains the rationale for this parking project and describes the modified plans for the Albion lot. While a parking structure might alleviate some of the constraints addressed by the proposed project, it would generate a new set of scenic and other resource impacts and be extremely costly. The other alternatives indicated in the first and third comments would either not respond to the project purpose (e.g., facilitating access to the Wildcat lot) or are addressed in the response above under Process – Issues Not Addressed – Traffic and Parking. In regard to the second comment, under the revised plan for the Albion lot a bench would be created with fill along the lower edge of the Snowpine lot, the road down to the Albion lot, and part of the Albion lot. This bench would be covered with snow plowed from the lots and road and groomed, providing an area for visitors to put on their gear and ski down to the ticket office and lifts rather than carrying their gear and walking down the road. This revision is described in detail in EA section 2.4.1.1. Beyond that, the EA identifies no substantial adverse impacts of the proposed parking improvements, so no alternative is needed. Baldy Tram We also ask that other alternatives [to the Baldy tram], such as avalanche control work via the Snowbird side be continue to be considered in lieu of the tram. (O1-10) An alternative that was dismissed is controlling avalanches from the Snowbird side of Baldy (p34) on the basis that a ski area is responsible for snow safety within its own boundaries. But that does not (and should not) preclude Alta snow safety personal from reaching the top of Baldy using Snowbird lifts. (I17-4) Response: The other, more important reason for not conducting Mt. Baldy avalanche control efforts from Snowbird noted in revised EA section 2.6 is that it would still involve an extended hike through uncontrolled terrain. Beyond that, it would depend on the Snowbird tram being in operation, which is not always the case during and after storms. The Baldy tram would be less exposed to the prevailing winds that cause closure of the Snowbird tram (see response above under Process – Purpose and Need – Baldy Tram). GazEx or other equivalent technologies to replace artillery and avalauncher. This is the solution to avy control on places that are hard to access, cause serious issues for the public and are rec-curing almost every storm event. Put these on Baldy over a Tram. (I203-4) ..could Gazex be used in some locations while utilizing Avalaunchers in other locations. Could the Wildcat lift be extended further up the Baldy shoulder so to allow for specious "ski compaction" as well as easier access to Mt. Baldy for setting hand charges. (I201-3) Response: The shortcomings of Gazex and Avalaunchers are outlined in EA section 2.6. Wildcat could not be extended far enough to improve functional ski patrol access to Mt. Baldy and still serve its current function. The EA lacks details on the need for a multi person tram versus a smaller single chair system that would utilized ONLY to transport avalanche control employees. (I201-4) Response: Ski patrol access is the reason for the proposed tram, but improved public access when conditions allow is a desirable side effect, in terms of both safety (i.e., added skier compaction) and recreational opportunity.

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Flora Lift According to information gathered through our FOIA request, the lower terminal of the Flora lift appears to be clearly within in known wetland boundaries. The terminal appears to be clearly within the wetlands. Once full wetland delineations are conducted according to best practices, Alta should be required to do [sic] move the terminal away from the identified wetland areas and with a significant buffer to ensure no wetlands are impacted. (O2-31) We are concerned the wetland delineations done for Alta’s MPD were done as an afterthought in the final hours of drafting the EA instead of being an important consideration in designing the lift from the start, especially when wetlands were likely to be present. (O1-24) We recommend alternative locations [for the Flora lift] outside wetlands (maybe North, Northwest of the proposed location) should be considered in more depth and be ground- truthed at a time of year when proper wetland delineations are appropriate. (O1-25) Correspondence with Alta Ski Lifts indicates that there may be opportunities for siting the base terminal in a less impactful location, SLCDPU encourages this possibility. (A2- 13) Do not put new towers in swampland. (I27-7) Response: Wetland protection is a management priority for NFS lands in the Salt Lake City municipal watershed. As indicated in EA section 3.4.1.3, the Flora lift bottom terminal would affect 0.18 acre of wetland, and lift towers could affect 0.05 acre of wetland in the alignment, depending on their placement. In an effort to avoid wetland impacts, ASL completed a thorough review to identify an alternative, upland terminal location. As a result of skier-circulation patterns and topography in the area, no alternative site was identified. EA section 2.6 has been revised to document this review.

Cumulative Effects Further, the EA doesn’t address cumulative impacts from construction and maintenance which would likely take place in the off season. (O2-27) Response: Many if not most of the impacts identified in the EA would be associated with construction and maintenance. EA section 3.2 details construction-related disturbance by area and type, and that information is then used in the analysis of soil, water, and watershed resources (section 3.4.1); vegetation (section 3.4.2); wildlife (section 3.4.3); cultural resources (section 3.5.1); and scenic resources (section 3.5.2). The water quality, vegetation, and cultural resources sections specifically address the effects of maintenance activities. In NEPA terms, these are direct impacts, not cumulative impacts. This [Supreme lift replacement] dust, noise, congestion and degradation to the dirt roadway was significant. Flora and fauna were negatively impacted; moose and deer were rarely seen in the area, plants carried a coating of dust for much of the summer, likely affecting their photochemical processing and health. The chipper lot housed a huge amount of slash and felled trees for much of the summer. Hiking areas were reduction due to active construction areas. in addition, attritional [sic] trails were impacted or temporarily eliminated because access was cut off. (I16-18) However, despite conclusions that the new Supreme lift towers would avoid the Albion Fen, after approval with that condition, when the construction for the lift was designed, towers are in the fen. (I16-17) Using a categorical exclusion to permit construction on the wetlands of Albion Basin this past summer was inexcusable. (I62-1)

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Response: EA section 3.3 lists the cumulative actions considered in this analysis, and the Supreme lift replacement project is included. Each resource-specific analysis in Chapter 3 addresses relevant cumulative effects. Beyond that, the UWCNF and ASL are committed to environmental stewardship and sustainable recreation. We continue to work with partners and key stakeholders to address their concerns as they arise. We met numerous times last summer with interested parties regarding the wetlands in Albion Basin. Although not required by the Army Corp of Engineers, Alta provided 5:1 mitigation for wetland loss due to their towers. Beyond that, these comments are outside the scope of this analysis.

Monitoring For any and all of the construction processes associated with this MDP EA, including the construction of lift facilities, SLCDPU respectfully requests closer and more detailed oversight by the Uinta-Wasatch Cache National Forest Staff of the environmental review process. (A2-4) This request is made due to the unanticipated removal of wetlands during construction of the new Supreme Lift during summer 2017. (A2-5) Response: The Forest Service permit administrator and/or pertinent resource specialists will monitor implementation of any projects authorized based on this EA. See also the second response above under Cumulative Effects. UWCNF staff should perform an adequate level of field review of contractor's work, or at least to ground truth contractor's report in most environmentally sensitive locations. (A2- 9) Response: In accordance with Forest Service use of third-party contractors, the contractors engaged to assist in preparation of this EA work under the direction of the UWCNF, and we are responsible for their work. See also the second response above under Cumulative Effects.

Adequacy of Analysis From the Flora Lift, to the Albion parking lot, to the proposed Baldy Tram, the Environmental Analysis fails to show the specifics of its analysis. (O2-1) Alta should be prepared to show, and the USFS should require, specific coordinates for every single project. (O2-2) …throughout the Environmental Analysis findings are made without the proper explanation or justification of the process for arriving at the findings. (O2-3) Repeatedly the MPD Environmental Assessment fails to show its work, leaving the results in question, the methods difficult to analyze, and the findings possibly arbitrary and capricious. (O2-4) Response: Without specific examples, it is difficult to respond to these comments. Overall, we believe the EA reflects the requirements of NEPA and Forest Service regulations guiding its implementation. These include the stipulation that NEPA analyses are to focus on significant issues and deemphasize non- significant issues (40 CFR 1500.4[g]) and be analytic rather than encyclopedic (1500.4[b]). The EA appears to have been completed in the most thorough and professional manner and I congratulate all who were involved in its research, completion and review. (I86-1) Response: We appreciate your comment. Finally, any impacts to alpine ecosystems in the Wasatch Mountains should be considered irreversible and irretrievable – they cannot be regained. As such, they should

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be analyzed through an Environmental Impact Statement rather than an Environmental Assessment. The proper tool should be used when analyzing such impacts. (I133-7) The proposed tram will inflict a significant impact upon users from many surrounding ridges, the roadway and various locations in the Central Wasatch and beyond. We suggest a full EIS process in which the Forest Service conducts a complete visual analysis from key observation points. (O2-24) Response: The EA identifies no irreversible and irretrievable impacts on alpine ecosystems, and it addresses the visual impact of the Baldy tram in accordance with established Forest Service protocols, as documented in section 3.5.2. Based on this EA, the Responsible Official will determine whether any identified impacts are significant and, on that basis, whether an Environmental Impact Statement (EIS) should be prepared. The 2003 Alta MDP Plan Revision (1-09 - 1-13) cite impacts to wildlife migratory patterns, degradation to watershed and impacts to plant life/introduction of invasive species as issues of concern during construction of Watson Shelter. These impacts and potential negative outcomes are a persisting issue that should be addressed before rendering a decision on Alta’s proposal. (O2-34) Response: This reference appears to be to the 2003 EA addressing ASL’s MDP revision, specifically the pages listing all the issues to be addressed in that EA, not just those relevant to Watson’s Shelter. Section 1.8 of the current EA describes a similar process for determining the scope this analysis as well as similar results. Differences in the issues addressed in the two analyses reflect differences in the proposed actions and the associated concerns raised through scoping and internal, interdisciplinary review. Specifically, the 2003 EA addressed removal of the old Watson Shelter and replacement with a new 4,000 square-foot, two-to-three-story skier-service facility, while the current proposal is much smaller – enclosing 550 square feet under that building’s existing deck and adding 1,000 square feet of new elevated deck. This EA does address impacts of the project on wildlife (migratory patterns are not an issue at this site), watershed resources, and vegetation, including invasive species.

Role of Other Agencies In general, the following comments apply to all proposed projects: 1) Please ensure that ground disturbance is limited, and that restoration of disturbed lands is conducted to avoid sedimentation, invasive species introduction, and overall watershed degradation. 2) Please ensure appropriate permits are identified and obtained from the Salt Lake County Health Department (SLCHD), Salt Lake County Planning and Development Services, and SLCDPU. Other agencies are specifically noted where appropriate below. 3) Where water resources are desired for proposed projects or otherwise impacted, please coordinate with SLCDPU to ensure compliance with Salt Lake City's Watershed Ordinance § 17.040, as well as with SLCDPU's surplus water permits. 4) Where sanitary facilities are proposed, please coordinate with SLCDPU and the SLCHD to ensure compliance with the Salt Lake County Health Regulation #14 (SLCDPU and SLCHD have joint authority) as well as Salt Lake County Health Regulation #13. 5) Please identify where proposed projects are contiguous with or might impact/cross adjoining lands that are not managed by the UWCNF. (A2-1) In addition to review by the USFS, all projects MUST be subject to review and approval by the following jurisdictional entities as needed: Salt Lake City, Salt Lake County’s

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Valley Health Department, and the Town of Alta. Approval of Alta Ski Area’s MDP does not guarantee individual project approvals from other jurisdictional agencies; this should be clearly stated in the conditions of any approval and monitored by the USFS. (O1-1) Response: It is important to keep in mind the purpose of NEPA review, which is to promote informed decision-making by federal agencies by making “detailed information concerning significant environmental impacts” available to both agency decision-makers and the public. Minimizing ground disturbance and disturbed-site rehabilitation are standard project design criteria for ski areas permitted by the UWCNF. EA section 1.9 identifies all the cited permits and authorizations as requirements for project implementation. Obtaining these permits and authorizations is ASL’s responsibility. EA Figure 2-1 has been updated to more clearly show non-NFS land and the locations of proposed projects. All areas found to be wetlands by US Army Corps of Engineers (ACOE) approved delineations must be avoided for ground disturbance, regardless of ACOE permit approval. ACOE approval does not constitute SLCDPU & SLCHD approval for wetland removal. This ensures compliance with local regulations SLCHD Regulation #14, as well as continued support of the health of the headwaters of the Salt Lake Valley's culinary water supply. SLCHD Regulation is not a zoning ordinance, it is a public health and safety protection via the protection of the culinary source water zones. (A2-7) On the map supplied within the EA, the bottom terminal appears to be in wetlands, please ensure that this lift is not constructed within wetlands in order to comply with local SL County Health Regulation #14. (A2-12) Response: As discussed in EA section 3.4.1.3, the only potentially affected wetlands, confirmed using COE criteria, are at the site of the proposed Flora lift bottom terminal. As noted previously (see response above under Alternatives – Flora Lift), no alternative, upland site could be identified that met the purpose and need for the lift. As a result, the project could affect up to 0.23 acre of wetland. Watershed protection remains a UWCNF management priority, and the Responsible Official will consider this impact in deciding whether to authorize this project. Any lift construction should adhere to a pre-designed Storm Water Pollution Prevention Plan created prior to construction. Regular and consistent inspections by UWCNF staff with Utah Registered Stormwater Inspector certification or equivalent should be required. If UWCNF staff does not have time, please consider entering into a partnership with either SLCDPU or SL County which both have RSI certified staff. (A2-10) Response: EA section 2.5 identifies design criteria that would guide planning and implementation of the proposed action. The first of these is the requirement for a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP process would be completed in accordance with all requirements of the Utah Construction General Permit, including a certified inspector and inspections every 2 weeks during construction season, then after precipitation events, until revegetation is established and the site was stabilized. The Forest Service would monitor compliance. SLCDPU requests that all lifts have full secondary containment for the diesel tanks associated with the drive terminal of the lift. Past spills have resulted in several hundred gallon leaks from lifts within protected watershed. (A2-11) Response: In accordance with federal and state regulations, all fuel tanks for ski-lift main and back-up drives include full secondary containment capacity. SLCDPU requests a review of projected water use within the expanded [Alf’s restaurant] facilities that take into consideration the higher use via expansion. (A2-17)

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SLCDPU requests a review of projected water use within the [Watson’s Shelter] facilities that take into consideration the higher use via expansion. (A2-19) Response: Planning of these expansions has not advanced to the point that these projections can be made, but ASL will provide them when available. State Division of Drinking Water-registered systems serving both sites, which include springs, storage tanks, and backup supplies from the Town of Alta in the case of Alf’s, are anticipated to be sufficient. Water use would continue to be monitored, with payments made accordingly to SLCPDU.

RESOURCES

Soil, Water, and Watershed Resources Water Quality Prior to any substantial movement of earth in this area [Supreme Summer Ski Run Work], especially if any overburden piles are used to fill in the gullies, SLCDPU requests soil analysis to ensure that this project does not facilitate any movement of heavy metals or associated pollutants into the water supply. (A2-15) Response: The fill material imported from the Big Dipper run (EA section 2.4.5.1) is not an overburden pile (mine waste or tailings). It is a naturally occurring topographic rise that divides the Big Dipper run and creates a bottleneck. The erosion-control mitigation measures and Best Management Practices (BMPs) described in EA section 2.5 and in Appendix A include practices that would minimize or eliminate soil erosion and movement of soil away from disturbed areas during and after construction. Additionally, SLCDPU respectfully requests that if this [Albion parking lot expansion] project is implemented, that Alta Ski Lifts minimize parking lot impact on water quality through incorporation of stormwater mitigation, including but not limited to implementation of oil/water separators, bio swales, snouts, etc., which would minimize the impact that this large expansion of hardened surfaces would have on fragile riparian corridors. (A2-3) Response: The project description in EA section 2.4.1.1 has been updated to note that the oil/water separator and pollution control measures already in place in the Albion parking lot will be retained or rebuilt as necessary as part of the parking lot expansion. Design criteria, mitigation measures and construction BMPs will also be implemented to minimize impacts on water quality (EA section 2.5 and Appendix A). Restoration Another condition of approval must be that all disturbance areas must be restored with native vegetation following best practices. Alta Ski Area generally complies with this best practice but it should still be clearly listed as a condition of approval and should be closely monitored by the USFS. As of late, the Alta Ski Area has enhanced its restoration efforts by skimming and storing the top soil and vegetation to be saved and replaced when work is completed. We encourage the ski area to continue with this technique. (O1- 4) Alta has done much with moving the mountain over the years. Unfortunately, in many of the areas where ski runs have been redone, it seems like the vegetation hasn’t responded well in the summer. (I73-4) Response: If the proposed action is authorized, implementation of design criteria and mitigation measures, including those described in EA section 2.5 and Appendix A, will be a condition of approval. Those design criteria include revegetation of disturbed sites using native plant materials. As indicated in

38 the first comment, most restoration projects at Alta have been successful, especially when topsoil can be salvaged and reapplied after the disturbance. Successful response to restoration efforts in alpine ecosystems often requires more time because of harsh growing conditions. Alta and the UWCNF have demonstrated a commitment to the long-term attainment of restoration goals appropriate to the setting. The proposed action would permanently lose soil productivity on about 2.2 acres due to paving (Table 2-1, p 34) and is generally dismissed because it increases the covered area by 6.4%. This can be (and should be) mitigated by removing impermeable surface on an equivalent area elsewhere, for instance in the Wildcat lot. (I17-1) Response: EA Table 2-1 describes the projected loss in soil productivity due to soil compaction, paving, and building footprints in the project area. These impacts are addressed in detail in EA section 3.4.1.3, and mitigation measures are prescribed to mitigate additional runoff that might occur as a result of the change in impermeable area. There is no federal, state, or county regulation requiring removal of impermeable surfaces to result in no net change of impermeable area. The space at Wildcat lot from which parking spaces have been shifted is allocated to transit use. Wetlands As a condition of Alta’s MDP approval, we request that no wetlands are destroyed to preserve the ecosystem functions they support and that the USFS require updated site inspections for flora prior to any ground disturbance. (O1-2) All areas proposed for ground disturbance to undergo more thorough wetland delineations. (A2-6) The USFS should require accurate wetlands delineations in accordance with best practices before any further approval of the Flora project. (O2-30) SLCDPU is not comfortable with this characterization of "normal conditions" and requests that future delineations are done under "normal conditions" given that this may change the actual size of delineated wetlands. (A2-14) Response: EA section 3.4.1.2 has been modified to describe the multi-step process used to identify and quantify the potential wetland impacts of the proposed action. The final step was using the three criteria defined in the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountain, Valleys, and Coast Region, Version 2, to confirm the presence of wetlands. Although this last step was conducted outside of the growing season, it verified that the lower terminal of the proposed Flora lift would affect a wetland. The potential wetland areas in the footprints of other projects failed to meet the hydric soil criterion. Hydric soils form over time in response to prolonged inundation or alternating saturated/unsaturated conditions. Once formed, they persist and are evident regardless of the time of year the survey is done (2006 NRCS Field Indicators of Hydric Soils in the United States – A Guide for Identifying and Delineating Hydric Soils, Version 6.0). As to the Flora lift bottom terminal, virtually the whole area of potential disturbance was identified as wetland, so completing the field verification during the growing season could not have resulted in a more conservative result. As to additional plant surveys if implementation of any authorized projects is delayed, the UWCNF will determine the need for any additional review in accordance with our NEPA regulations (Forest Service Handbook 1909.15, section 11.23). Baldy Tram In addition, it [Mt. Baldy tram] would be detrimental to the watershed. (I90-2) Response: The watershed impacts of the Mt. Baldy tram are addressed in EA section 3.4.1.3 and would be minor.

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Supreme Summer Ski Run Work The stated impact of this project is 9.2 acres of excavated terrain with the erosion hazard listed for each affiliated project listed as “severe.” The Supreme work will impact 1.57 acres of RHCA aquatic features and 347 feet of stream. Such work as is being considered here will significantly scar a sensitive alpine ecosystem susceptible to changes in land use and climate. (O2-33) Response: The impacts of the Supreme Summer Ski Run Work are discussed in EA section 3.4.1.3. Those impacts would occur in a previously disturbed area (i.e., adjacent to an existing road and on a steep hill slope where ongoing erosion has created the gullies that the project would be filling). The 1.57 acres of disturbance would involve upland habitat in an RHCA defined by distance from a channel, not “aquatic features.” The 347 feet of intermittent stream channel are located at the downslope end of the disturbance footprint and would not be filled or relocated. After recontouring, the then-filled erosion gullies would be seeded with appropriate species, and erosion control measures would be implemented. Rather than creating a significant scar, this project would decrease the amount of erosion taking place within the project footprint and improve water quality.

Vegetation Timing …there could be many years between data collection for this draft EA and an actual project being initiated. Sensitive plant species presence or absence should be validated based on current conditions to assure the public that sensitive plants won’t be destroyed. (O1-3) Response: NEPA does not specify a timeframe for which analysis, including surveys, is considered valid. In practice, the UWCNF may complete changed-condition reports or supplemental reports prior to project implementation if they feel that the NEPA analysis has become dated (Forest Service Handbook 1909.15, section 11.23). Those reports and associated surveys would verify whether presence/absence has changed and determine if any newly listed threatened, endangered, or Forest sensitive species would be impacted. Based on these reports, we would determine whether the original project authorization held or a new NEPA review and decision were required. A change in the proposed action would require new analysis and review. Baldy Tram The environmental analysis wrongly states that the avalanche mitigation control program for which the tram is supposedly being built will have no impact on either botanic species or wildlife because during the winter months, plants will be dormant and snow covered while wildlife will either have entered hibernation or have adopted a subnivean/subterranean lifestyle. (O2-20 duplicate) The environmental assessments assertion that operation of the tram to transport skiers to the summit is unlikely to impact the alpine ecosystem since “that use would occur when plants were dormant and snow covered, and wildlife were absent, hibernating or had adopted subnivean or subterranean lifestyles” ignores the impacts of construction and resulting habitat loss, and refuses to acknowledge recent scholarship into the impacts of climate change and snow compaction in high alpine areas. (O2-21 duplicate) There is widespread acceptance in academic papers that mechanical grading of alpine landscapes is at least in the short term, destructive of habitats (Wipf et al., 2005; Mosimann 1985; Rolondo et al. 2007; and Delgardo et al., 2007). (I133-1)

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Research indicates that temperatures below prepared ski runs can reach -10°C, while those under undisturbed snow rarely fall below freezing point; this results in those species with insufficient capacity to withstand prolonged cold temperatures being unable to survive (Rixen et al., 2004 in Wipf et al., 2005). While it is often stated that the simple occurrence of snow on top of vegetation protects it from impacts, this research seems to contradict this. (I133-2) In addition, it is certain that construction will impact at least some of the alpine vegetation. Mosimann (1985) reports that where re-seeding has taken place at altitudes higher than 2,200 m. (7,215 ft), the re-establishment of a vegetative cover hardly ever occurs and plant re-colonization is rare. Research show that newly created ski runs, or pistes, have a lower level of vegetation cover and high proportion of bare ground resulting in higher levels of surface run-off and subsequent erosion, reduced fertility and biodiversity (Wipf et al., 2005). While the direct impacts to alpine vegetation through construction may be somewhat limited, the indirect effects from snow compaction at the upper terminal as well as through skier use will occur over a much broader area. (I133- 3) Additionally, while winter does imply snow, there is also a great deal of wind scouring that occurs on Mt Baldy and it’s an uninformed assumption to say there will always be snow cover protecting the plants, surface soils, and wildlife. Based on personal experience hiking Mt Baldy in the winter, when you have hundreds of people in hard ski boots walking the same path the protective snowpack wears away quite quickly; the snow layer that was there for the first person is not present by the time the hundredth person walks the same path. (O1-14) This portion of National Forest land has previously seen only minor impacts from summer hikers, is highly intact, and currently as resilient as most alpine ecosystems can be in these mountains under the existing ecosystem stresses. The plant communities, while not unique in the Wasatch Mountains, are extremely limited. This expansion, while apparently minor, adds to the loss of these important ecosystems of the peaks of the Wasatch Mountains and will result in significant cumulative impacts. (I133-4) Plant species abound in these delicate ecosystems as well. Though many are not unique to the Wasatch Mountains, they are exceptionally rare in their dispersal. (I204-2) Response: The Baldy tram project does not include the construction of ski runs. Skiing would continue to occur where it does now, in the chutes and other undeveloped, “off piste” areas. Therefore, the cited studies of ski run impacts have limited application. The EA discloses the impacts of the proposed action, including both construction of the tram and subsequent skier use, on special-status plants and the alpine ecosystem. The difficulty of revegetating disturbed sites are noted. Section 3.4.2.2 has been updated to reflect that the snowpack on the summit of Mt. Baldy may be scoured by wind or reduced by skier traffic. Both of those scenarios, and use of the area by summer hikers, occur under current management and have resulted in the existing conditions described in the EA. The updated analysis addresses the fact that skier traffic on Mt. Baldy will likely increase. See also the response below under Wildlife – American Pika. If approved, we recommend this part of the criteria for approval include surface stabilization/protection where individuals leave the tram and include environmental education to limit disturbance. (O1-15) Response: The UWCNF requires the ski area to implement design criteria and mitigation measures, including BMPs, on disturbed areas as described in section 2.5 of the EA. An additional mitigation measure has been added to the EA (section 3.4.2.5) addressing environmental education.

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Per a meeting with Alta and the USFS on Oct. 31, 2017, Alta claims that summer use of a Baldy Tram may occur in the future. The EA analysis for the Baldy Tram fails to include any review of summer impacts on wildlife or botanic communities. (O2-16a duplicate) A major concern of ours is the potential for this to be a means of summer access. There is great potential for the highly specialized alpine vegetation on top of Mt Baldy to be negatively impacted from higher use of the area. (O1-12) Response: Summer use of the Baldy tram has not been proposed or addressed in this EA and would require a separate proposal and analysis if ASL wished to pursue it. Note that the summit of Mt. Baldy is already a popular summer hiking destination, especially by hikers accessing it from the Snowbird tram. Gazex Installations Installation of additional Gazex and avalanche mitigation tools will permanently impact high alpine wildlife and botanic communities which are already at increasing risk due to climate change. (O2-26 duplicate) Response: The impacts of Gazex installations on vegetation are discussed in the EA section 3.4.2.3. It is important to note that no new avalanche starting zones would be affected; only the means of delivering energy to the same zones will change. Artillery-type explosives result in more damage to the soil surface and vegetation than either Gazex or hand charges. Climate change is discussed as part of the baseline condition for alpine ecosystems in EA section 3.4.2.2, and section 3.4.2.3 has been revised with additional discussion of both the differential effects of avalanche-control technologies and the potential interaction of climate change with the impacts of the alternatives on alpine ecosystems. Other Projects As with the proposed tram to the top of Mount Baldy, this new Flora Lift would impact areas that previously had little to no disturbance. While I am not as intimately familiar with this area as I am with Mount Baldy, this new construction would again impact and reduce the resilience of ecosystems that are limited in distribution and likely to be most affected by climate change. (I133-6) Response: EA section 3.4.2.3 addresses the potential effects of the Flora lift on vegetation and alpine ecosystems. A discussion of climate change has been added to that section. Adding parking to the Albion Basin will have direct impact to neighboring flora as well as mitigation to protect wetland and riparian areas below the lot. (O2-7) Response: The impacts of the Albion parking lot expansion on vegetation and wetland/riparian areas are identified in EA sections 3.4.2.3 and 3.4.1.3, respectively. No special-status plants are present within the disturbance area. The project would not affect wetlands as none are present, but it would affect 72 linear feet of intermittent stream channel and 55 linear feet of perennial stream channel. Construction site best practices must be employed [for Wildcat lift replacement] if approved. (O1-21) Construction site best practices must be employed [for Supreme summer ski run work]. (O1-26) [Sunnyside lift replacement:] That being said, we request all best practices and care be taken to limit disturbances of both rehabilitated and undisturbed high alpine habitat. (O2-28) [Wildcat lift replacement:] That being said we request all best practices and care be taken to limit disturbances of high alpine habitat. (O2-29)

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Response: The design criteria, mitigation measures, and BMPs described in the EA (see section 2.5 and Appendix A) would be implemented at all project locations.

Wildlife Baldy Tram, Gazex, and Alpine Habitat The environmental analysis wrongly states that the avalanche mitigation control program for which the tram is supposedly being built will have no impact on either botanic species or wildlife because during the winter months, plants will be dormant and snow covered while wildlife will either have entered hibernation or have adopted a subnivean/subterranean lifestyle. (O2-20 duplicate) The environmental assessments assertion that operation of the tram to transport skiers to the summit is unlikely to impact the alpine ecosystem since “that use would occur when plants were dormant and snow covered, and wildlife were absent, hibernating or had adopted subnivean or subterranean lifestyles” ignores the impacts of construction and resulting habitat loss, and refuses to acknowledge recent scholarship into the impacts of climate change and snow compaction in high alpine areas. (O2-21 duplicate) Response: See the responses above regarding impacts on alpine vegetation and the interaction with climate change, and the response below regarding impacts on pika. The EA discloses the impacts of the alternatives on the alpine ecosystem, and section 3.4.2.2 have been updated to reflect that the snowpack on the summit of Mt. Baldy may be scoured by wind or reduced by skier traffic. Both of those scenarios, and use of the area by summer hikers, occur under current management and have resulted in the existing conditions described in the EA. Beyond that, the Baldy tram project does not include the construction of ski runs. Skiing would continue to occur where it does now, in the chutes and other undeveloped, “off piste” areas. Therefore, the cited studies of ski run impacts have limited application. The updated analysis addresses the fact that skier traffic on Mt. Baldy would likely increase. See EA sections 3.4.2.3 and 3.5.3.3. Per a meeting with Alta and the USFS on Oct. 31, 2017, Alta claims that summer use of a Baldy Tram may occur in the future. The EA analysis for the Baldy Tram fails to include any review of summer impacts on wildlife or botanic communities. (O2-16a duplicate) Response: Summer use of the Baldy tram has not been proposed or addressed in this EA and would require a separate proposal and analysis if ASL wished to pursue it. Note that the summit of Mt. Baldy is a popular summer hiking destination, especially by hikers accessing it from the Snowbird tram. Installation of additional Gazex and avalanche mitigation tools will permanently impact high alpine wildlife and botanic communities which are already at increasing risk due to climate change. (O2-26 duplicate) Response: The impacts of Gazex installations on wildlife are discussed in the EA section 3.4.3.3. It is important to note that no new avalanche starting zones would be affected; only the means of delivering force to the same zones will change. Climate change is discussed as part of the baseline condition for alpine ecosystems in EA section 3.4.2.2, and section 3.4.2.3 has been revised with additional discussion of climate change and its potential interaction with the impacts of the alternatives on alpine ecosystems. See also the response above under Vegetation – Gazex Installations. Pika Given the absence of the American Pika being mentioned in the Environmental Assessment, a further review and study of the impacts of additional development of high alpine summits in the Wasatch is warranted. (A1-5)

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The proposed Baldy Tram is squarely located within pika habit elevation range and there could be direct impacts on pika habitat or suitable pika habitat. (O2-15) Given the area of construction, including buffers, the Baldy Tram stands to significantly displace and/or affect pika behavior. (O2-16b) Pika burrows occur in talus / boulder slopes and ground disturbing activities in such areas could not only degrade or remove suitable habitat but could result in the direct loss of individual pikas. Surrounding areas with native plant communities adjacent to suitable habitat would be potential foraging areas for pika and again ground disturbing activities in those areas could result in direct negative effects or loss of foraging habitat and have indirect effects on foraging behavior, habitat use, mating behavior, etc. (O2- 17) The compaction that occurs as part of avalanche mitigation also causes the collapse of tunnels which pika rely on for food, storage and navigation. (O2-18) An analysis should be conducted of the distribution of potentially suitable pika habitat in the project area and surrounding areas. (O2-19) I previously counted Pika in Big Cottonwood Canyon, and I did not see this species listed as a potential resident. I was also concerned that the likely destruction of areas occupied by the Boreal Frog did not appear to be addressed very seriously. Maybe they can live within the larger area, but they would not be a sensitive species if their territory was not being reduced. (I26-3) These development threats to the high alpine reaches of the Wasatch … degrade the home of threatened species such as the American Pika which are highly vulnerable to change on high elevation, isolated mountaintops. (I204-1) Response: In 2010, the U.S. Fish and Wildlife service determined that listing of the American pika was not warranted, following a listing petition based on global warming. The pika is not a Forest Service sensitive or focal species. Accordingly, there is no requirement to address project impacts on the pika. Without a legal requirement for analysis, the NEPA question is whether there could still be a significant impact on the species. The Utah Division of Wildlife Resource’s Wildlife Action Plan (2015-2020) addresses the pika, noting that its Utah status is “apparently secure” and its National status is “secure.” The plan states that “Surveys in Utah since 2008 have documented high occupancy rates and reconfirmed pika presence in all historically documented mountain ranges. The range includes high mountainous area of western North America including the Rocky Mountains, Great Basin ranges, Sierra Nevada Mountains, and Cascade Mountains. In Utah, pikas are found in most mountains and high plateaus.” Based on this information, further analysis is not necessary to conclude that this proposed action would not result in a significant impact on the pika. The boreal toad, a Forest Service sensitive species, is addressed in the EA. See section 3.4.3. Moose The base of this lift [Flora] is a favorite summer habitat for moose and construction is potentially damaging to that environment. Apparently this effect has not been evaluated, but should be prior to final approval of this lift. (I17-8) I also see moose frequently in the meadow there [sic] the proposed bottom terminal would be. Would this construction scare the moose off permanently? Would it destroy the habit they love? (I27-10) I often saw moose in the early morning where a restaurant and ski lift now stand. I haven’t seen a moose there since. (I167-2)

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Response: Moose are a common species in upper Little Cottonwood Canyon, with abundant habitat and a healthy population. While construction would cause moose to leave a localized area, they typically return once the level of activity returns to normal. Temporary displacement of a few individuals does not warrant analysis in the EA.

Scenic Resources Baldy Tram Alta’s development of the Baldy Tram should take into consideration the wishes of neighboring jurisdictions. The Town of Alta’s General Plan (2005) states that “The views of major natural features should be protected”. (O2-22) Response: What the cited plan actually says is “Development proposals should consider the views of major natural features and surroundings” (p. 8). Siting the terminal below the ridgeline, coupled with the EA’s thorough analysis of the proposed tram’s impact on scenic resources, demonstrates that consideration. The viewshed analysis conducted as part of the MPD’s EA is insufficient. Not enough information is included in the assessment regarding the parameters set by the USFS analysis. That the Baldy Tram would be viewed from SR 210, from the town of Alta, Mount Superior, and the Twin Peaks Wilderness should be enough reason to dismiss the project. (O2-23) We believe in preserving as much of a natural setting as we can atop this iconic mountaintop and certainly the cable lines, tram, and top terminal will be visible from Hwy 210 near Our Lady of the Snows – the draft EA doesn’t account for all perspectives but focuses only on areas where they can say there is no visual impact such as the base of Collins lift. We ask that additional perspectives from the top of the wildcat lift, Hwy 210 near our Lady of the Snows, and the top of Flagstaff peak be considered. (O1-8) Response: EA sections 3.5.2.1 – 3.5.2.3 document the issue, indicators, and methodology used in this analysis. The EA provides references to the Scenery Management System, the Forest Plan, the Built Environment Image Guide, and other guiding documents so that readers may consult them for more information. A basic concept in this established methodology is that impacts are assessed from places where people congregate, particularly people sensitive to the types of impacts anticipated. That is the reason for selecting SR 210 and the Wildcat and Albion base areas as the key viewpoints. Mt. Superior was also discussed as a sensitive viewpoint, and Albion Basin has been added as a viewpoint. Flagstaff Mountain was not included as it is not in the wilderness and not a place where people congregate. EA section 3.5.2.5 states that the top terminal of the Baldy tram would be visible from SR 210 through the Town of Alta, including the section below Our Lady of the Snows, and from the upper portions Wildcat and Collins pods, as well as from Mt. Superior. In short, the analysis concludes that the terminal would in fact be visible from all key viewpoints, including those suggested in the comments, except the two base areas. Those views would be consistent with management direction for the area, in accordance with the cited methods and scenic integrity objectives. The proposed Baldly Tram, with its potential to be viewed from nearby peaks across the Wasatch, would degrade one of the qualities identified as being of the highest importance to residents of Salt Lake County. (A1-2) This new lift will permanently degrade the appearance of an iconic peak, both for inbounds skiers and those in the back country who will have to look at this building in addition to the one on top of Hidden Peak. (I1-2)

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This tram construction will have a negative impact on the scenic beauty of the Wasatch area. (I6-2) The biggest downside of the tram is visual in that it would put an ugly man made intrusion where one doesn't currently exist. I think this really goes way beyond improvements within the resort because the result is a visual intrusion that will be visible from pretty much anywhere at the head of the canyon. (I30-5) Furthermore, installations in a resort should be made in such a way to minimize the visual and environmental impact. Putting lift towers not only on top of a ridgeline but also atop a high peak does not hold up with this. Mount Baldy is a very pretty summit, both in winter as well as summer, and a tram would NOT improve that in any way. (I67- 2) A tram on baldy would make the LCC ridgeline look ridiculous.(I84-1) The ridgeline along Devil' s Castle and Patsy Marley is a popular hike during the summer months. Though the ridgeline is in view of developed areas for many people it is a wild experience. The EA lacks details on how the summer view shed would be protected with this development along the ridgeline. (I201-6) The EA should include a viewshed analysis to provide a better idea of the impacts of the tram and Gazex units. The written description and pictures do not provide enough information on how these facilities will look and how they will change the views from and around the resort. I request that a viewshed analysis be added to the EA for the analysis of impacts to scenic resources, especially considering the controversial nature of the tram. (I202-2) I am concerned that the extent of development, particularly the tram to Mt. Baldy and installation of Gazex on Sugarloaf Mountain, East Devils Castle, and Patsey Marley, is unnecessary and does not fit the management direction in the 2003 Forest Plan .. The management direction requires development to be designed with a high level of attention to scenic quality. In addition, it states that the dominance of the built environment should decline on mountainsides and new development on ridgelines should be minimal. (I202- 1) Response: EA section 3.5.2 identifies and discloses the scenic effects of the proposed action in accordance with established Forest Service protocols. It identifies the limited area from which the upper terminal of the Baldy tram would be visible, clarifies that the terminal would not be on the summit but lower on the slope in a site screened from most directions by topography, identifies additional design criteria and mitigation (e.g., color requirements), then concludes that it would be consistent with the landscape character one would expect in a developed ski area and with the UWCNF Forest Plan’s management direction. The viewshed analysis completed for the top terminal of the Baldy tram was posted on the UWCNF website at http://www.fs.fed.us/sopa/forest-level.php?110419. See response below regarding scenic effects of the proposed Gazex installations. Given the location of the top station of the proposed tram, I do not believe that a significant ridgeline viewshed impairment will occur. We certainly have many other visible lift-lines in our mountains, and as the lift will have no intermediate towers and a minimal top station I do not see a significant viewshed problem. (I86-3) Response: The analysis documented in the EA supports this conclusion. Gazex Installations While we can appreciate the enhanced snow safety aspects of new technologies like GazEx and o’BellX, the placement of these manmade structures detracts greatly from the

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natural beauty of area. Preference should be granted to less visible systems and every effort should be made to camouflage the units. (O1-19) The systems do have environmental impacts particularly on the vegetation in this alpine/sub-alpine locality - not to mention that the equipment is truly an eyesore. (I30-7) This will have a tremendous impact on both aesthetics and year-round recreation uses within the ski area special use permit (i.e Devil’s Castle). (O2-25 duplicate) Response: EA section 3.5.2 documents the projected scenic effects of the proposed Gazex installations. Section 3.4.2 addresses their impacts on vegetation, a reduction compared to the avalanche control methods currently used at the ski area. To summarize, the Gazex installations would be distant from key viewpoints, small, and colored to blend with the background. They would be consistent with expectations of what one would see at a developed ski area and thus with Forest Plan management direction. Mitigation We want to encourage the USFS and Alta Ski Area to continue to find ways to minimize impacts from manmade structures to the skyline. (O1-9) … consider design elements to help the building blend in with the natural surroundings and not detract from the area’s open space feel as much as possible. (O1-29) Response: No manmade structures on the skyline are proposed. As discussed in EA section 3.5.2, structures at the ski area must incorporate materials, siting, and design criteria that help them blend with the natural landscape, consistent with Forest Plan management direction for the area. Section 3.5.2.7 discusses mitigation of scenic impacts. Dark Skies Dark Skies - with the planned addition of new buildings in the Albion lot, added parking lots, roads, and lifts, how will this plan affect the wonderful Dark Skies that Alta has (or had) in the summer? Over the years, the quality of star gazing has dramatically decreased in Alta, much of which is due to increased lighting in the ski area facilities (Cat House, Wildcat Parking Lot, Offices, etc). (I73-5) Response: The International Dark-Sky Association has designated three dark sky parks in Utah, and Alta is not included. Unfortunately, more light-intensive development at Alta, coupled with the sky glow from the nearby Wasatch Front metropolitan corridor, makes truly dark skies at Alta a thing of the past. Beyond that, maintaining dark skies is not a Forest Service objective for ski area management. Nevertheless, this proposed action would entail minimal new lighting.

Recreation Baldy Tram Baldy has always been a place where a little bit of labor spent climbing paid off with relative solitude and extraordinary backcountry style runs. Crowding this summit with 150 people per hour will take away from this experience so many generations have enjoyed. (A1-4) Hiking to ski the Baldy chutes is part of the classic “Alta experience” that is often mentioned, and these turns should be earned by those who want to access it. (I1-3) Response: This is one of the recreational impacts specifically addressed in EA section 3.5.3. To summarize, the conclusion is that improved avalanche control would increase the number of days the peak was open, and providing lift access would increase the number of skiers taking advantage of open days. In combination, these effects would detract significantly from the experience of those who have

47 enjoyed a rare and unique experience hiking the peak in the past. This would be offset by more skiers having the opportunity to ski Baldy’s extreme terrain. The Central Wasatch provides abundant backcountry opportunities to hike and ski expert terrain, but this particular one is inside the special use permit boundary of a developed ski area. Furthermore, the loading/waiting lines for this tram would likely present congestion with skiers moving across Germania Pass and those waiting to load the tram to access Mt. Baldy runs, when open. (I17-3) I do worry about congestion on Germania pass with Collins unloading, the ski patrol building footprint, now tram loading and potentially Flora lift unloading. (I27-3) Lastly, on a previous note this seems like it would over congest the Germania pass area with all the loading, unloading and ski patrol building. (I27-11) Response: This is another issue specifically addressed in EA section 3.5.3, which identifies four factors that would limit the potential for circulation issues: the siting of the bottom tram terminal south of most other routes on or off Germania Pass; the fact that the tram will often not be open to public use, so no maze will be necessary; the low capacity of the tram will not require a large maze; and managing such circulation issues are a routine aspect of ski area operations. Permanent structures also detract from the experience of users outside the resort boundary due to noise and visual impacts. (I108-4) Response: As discussed above in responses under Scenic Resources, the proposed developments would be consistent with what people in the area currently see and expect to see at a developed ski area. While none of the proposed developments would be particularly noisy, the same conclusion holds for noise impacts. Gazex Installations [Gazex installations] will have a tremendous impact on both aesthetics and year-round recreation uses within the ski area special use permit (i.e Devil’s Castle). (O2-25 duplicate) Response: See the preceding response regarding the scenic impact of the proposed Gazex installations. No notable impact on recreation is anticipated. Wildcat Replacement …keep in mind Alta is unique because of its vast terrain and limited uphill capacity. Many skiers come to Alta because of that reason. Doubling the uphill capacity of Wildcat may overload that area and ruin the experience for all. I have known resorts that have put in new lifts improving reliability and shortening ride time, while maintaining the same uphill capacity. (I27-8) For the Wildcat detachable chairlift proposal, I would like to suggest perhaps implementing a lift with similar riders per minute capabilities of the current Wildcat. I am aware that the two-seater current chair is getting outdated and in need of replacement, but maybe replacing it with a fixed grip quad or triple would be a suitable alternative. I say this because the wildcat shoulder is already an incredibly popular area to ski, and gets tracked out quickly with the current Wildcat capacity. If a detach quad was installed, this would also alter the integrity of the famed hidden powder stashes on the Wildcat shoulder. (I208-3) Response: The potential impact of lift upgrades, including Wildcat lift, on skier density is the first issue addressed in EA section 3.5.3. The conclusion is that the upgrades are proposed more to improve reliability and safety, to provide redundant capacity when key lifts are down, and to meet expectations for

48 high-speed lifts in today’s skier market than to accommodate more people. Alta would continue to match lift operating speeds to on-mountain conditions to maintain uncrowded conditions.

Safety Baldy Tram I am concerned that the tram will also be used to transport skiers to an area that is now visited in the winter by advanced skiers with good off-piste skills. (I6-1) Skiing baldy is for the elite - and I don't mean that in a boys' club kind of manor [sic]. If a tram is up there, even though some may caution that it is for experts only, we all know that the wrong people will be up there causing delays, congestion and confusion. You know they will be injuring themselves and putting others at risk with their skill set. No one is going to stop the under-qualified from being up there and we all need to admit that we know it. (I84-2) Mount Baldy in winter is the same. Its Chutes are some of the most challenging resort skiing one will find in the USA and building a lift to bring ever more people there will only result in people getting severly [sic] hurt and/or killed. Some things like Baldy Chutes must be earned by hiking up the boot-pack trail. If you are not physically able to do the 40+ minute hump, then you most certainly don't belong there. (I85-2) That tram would be a set up for disaster! The terrain is very difficult! I can't imagine the number of injuries that would result if Joe average skier could ride a lift to access such extreme terrain! (I191-1) Response: This is the first issue addressed in EA section 3.5.4. To summarize, public use of the inherently dangerous Baldy Chutes could increase, with a corresponding increase in the likelihood of injuries. This would be a safety management issue with which Alta has decades of experience. Skier education, closures, rope lines, and signage have all been incorporated into an effective risk-management system at Alta, and lift access to Mt. Baldy would not be a qualitative change in the demands on that system. Note also that the tram would have download capability for skiers who changed their minds once they reached the top. As for concerns for folks 'getting in over their heads', there are certainly many other existing areas with cliff bands and expert chutes where skiers must choose slopes within their abilities. Therefore that is not a valid concern. (I86-4) Response: This is true. As discussed in EA section 3.5.4, Alta has long experience managing similar risks, and skiers bear the ultimate responsibility for choosing terrain they can handle safely. Albion/Wildcat Base Parking However, snow removal froth [sic]enlarged ramp and parking area will need to be accounted in terrain that would not cause undue hazard to skiers and pedestrians. Snow left along the side of the roadway between Rustler and Alta Lodge now, can be very challenging to navigate, whether on skis or in ski boots. This should be accounted for in the Albion area to ensure the desired pedestrian safety is accomplished. (I16-13) Response: This is a good observation and was considered in the revised plans for this project described in EA sections 1.4 and 2.4.1.1. In the interest of skier safety and convenience, a bench would be created with fill along the lower edge of the Snowpine lot, the road down to the Albion lot, and part of the Albion lot. This bench would be covered with snow plowed from the lots and road and groomed, providing an area for visitors to put on their gear and ski down to the ticket office and lifts rather than carrying their gear and walking down the road.

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Contemporaneous with the transit modifications, safety concerns for the Alta school, accessed from the Wildcat lot, need to be addressed to ensure school children can safety [sic] access their classroom and play yards. (I16-12) Response: Students at Alta school, located in Goldminer’s Daughter lodge, use the same drop off point as lodge guests. The drop-off area was previously designated and would not be affected by this proposed action, though the shift of parking spaces from the Wildcat lot to the Albion lot might reduce overall congestion. Gazex Installations The installation of GasEx seems to be a huge safety concern. Not to mention the environmental impact of their construction and footprint. (I27-4 dup) A remote control system where nobody at Alta has eyes on what is happening in the vicinity could put backcountry users at risk. That includes people in the Wolverine cirque and on the ridgeline between Patsy Marley and Wolverine. (I30-6) Response: The first thing to note is that the proposed Gazex installations would replace artillery, Avalaunchers, and helicopter bombing for avalanche control, all of which pose higher safety risks for both the public and snow safety personnel. EA section 3.5.4 addresses the risk posed by Patsey Marley Gazex installations for sympathetic released in Wolverine Cirque. The conclusion is that the energy potentially transmitted through the ridge to the cirque would be minute – less than current practices generate – so conditions in the cirque would have to be extremely unstable for there to be any chance of a sympathetic release. Under such conditions, no one would be skiing in the cirque. The Gazex installations would be observed as feasible prior to detonation, and they would pose less risk than firing projectiles from artillery or Avalaunchers toward obscured targets. Albion and Sunnyside Lifts Will keeping the Albion lift as is, a fixed-grip double, for another 5 - 10 years cause safety issues as people will have no experience with a double-seat, center pole lift, and may encounter the chair pole with a firm back in the head? (I16-4) Response: Despite the shift toward detachable lifts, there are still a lot of fixed-grip lifts around to keep skiers familiar with their use. Trained lift personnel and the ability to slow and stop the lift provide an additional safety factor. The UWCNF will coordinate with ASL to monitor this potential risk. Congestion of people standing/waiting [at the bottom of Sunnyside] for companions, and those trying to navigate the lines leads to potentially dangerous conflicts among skiers, walkers, and OSVs. (I17-6) Response: The UWCNF and ASL have been working to segregate uses around these lift terminals. There should not be walkers, and any OSVs operating in the area would be involved in ski-area operations. ASL maintain protocols and provides training for OSV operations when skiers are present. Beyond that, the proposed Sunnyside lift replacement would not worsen congestion and may alleviate it by reducing the number of people in the maze.

COMMENTS EXPRESSING GENERAL OPINIONS REGARDING THE PROPOSED ACTION Comments under this heading express opinions, which the Responsible Official will consider in making a decision regarding this proposed action. No response is required.

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Opposition to Proposed Action The majority of commenters (154 of 214) submitted a form letter opposing the proposed action. Since the letter was brief, it is included in its entirety below. Some commenters added additional points to the form letter, and these are addressed separately below or elsewhere as appropriate in this report.

I DO NOT support more development in the high alpine areas of Little Cottonwood Canyon.

The Wasatch Mountains are one of the main reasons why I love Utah! High alpine meadows, granite vista's, meandering creeks, world class developed recreation opportunities and pristine Wilderness areas are just minutes from the ultimate four season resort in the world; the Salt Lake Valley.

The Central Wasatch Visitor Study undertaken in partnership with the Forest Service, gathered over 4,000 comments regarding the values of visitors to the Wasatch. 88% of respondents reported being "highly satisfied" with their visit citing "observe scenic beauty and enjoy peace and tranquility" as the motivating factor for their visit!

Approving a tram up to highly visible Mount Baldy, cutting more trees, vegetation and scaring the landscape with access roads would fly in the face of those who have voiced their need for a balance that is already tipping toward development.

All six resorts in the Central Wasatch offer year-round experiences which add to our quality of life and our local economy yet I hope you are aware that these permanent structures also detract from the experience of users outside the resort boundary due to noise and visual impacts.

As a lover of the Wasatch I stand with the majority of the public who oppose more development, noise and stress for the Wasatch Mountains and the diverse flora and fauna who call this place home.

The Forest Service is charged with making difficult decisions about our public lands and I support you in denying projects which turn the Wasatch into a marketing gimmick for a few at the sake of many.

Thank you for your time and attention on this issue. (I2-1, I3-1, I4-1, I5-1, I7-1, I8-1, I9- 1, I10-1, I11-1, I12-1, I13-1, I14-1, I15-1, I18-1, I19-1, I21-1, I22-1, I23-1, I24-1, I25-1, I28-1, I29-1, I31-1, I32-1, I33-1, I34-1, I35-1, I36-1, I37-1, I38-1, I39-1, I40-1, I41-1, I42-1, I43-1, I44-1, I45-1, I46-1, I47-1, I48-1, I49-1, I50-1, I51-1, I52-1, I53-1, I56-1, I58-1, I60-1, I61-1, I63-1, I64-1, I65-1, I68-1, I69-1, I70-1, I72-1, I74-1, I75-1, I77-1, I78-1, I80-1, I81-1, I82-1, I83-1, I87-1, I88-1, I89-1, I91-1, I93-1, I94-1, I95-1, I97-1, I99-1, I100-1, I102-1, I103-1, I104-1, I105-1, I106-1, I107-1, I108-2, I109-1, I110-1, I112-1, I113-1, I114-1, I115-1, I116-1, I117-1, I118-1, I119-1, I121-1, I122-1, I123-1, I124-1, I126-1, I127-1, I128-1, I129-1, I130-1, I131-1, I134-1, I135-1, I136-1, I137-1, I138-1, I139-1, I140-1, I142-1, I143-1, I144-1, I145-1, I146-1, I147-1, I149-1, I150-1, I151-1, I152-1, I153-1, I154-1, I155-1, I156-1, I157-1, I159-1, I160-1, I161-1, I162-1, I163-1, I164-1, I165-1, I166-1, I167-1, I168-1, I169-1, I170-1 I171-1, I172-3, I173-1, I174-1, I175-1, I176-1, I177-1, I178-1, I180-1, I181-1, I182-2, I183-1, I184-1, I185-1, I186-1, I187-1, I188-1, I189-1)

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I DO NOT support more development in the high alpine areas of Little Cottonwood Canyon. I especially do not support the building of a tram to Mt. Baldy. (I158-1)

I grew up in the Salt lake area, and have spent years enjoying the scenic beauty around Alta. I learned to ski in these canyons and I understand the desire to develop this area, but really hope that some restraint can be shown so that someday my children can enjoy the Wasatch mountains the way I did. (I182-1) I try to be a reasonable person and understand that a common ground often has to be reached but my frustration with these development projects is that the common middle ground continuously moves in only one direction: towards more developlement [sic]. For example if there are 10 buildings in Albion Basin and someone wants to build 2 more the common, middle ground between no development and 2 more buildings will be 1 additional structure. This continues indefinitely and always away from the position of no additional development. For this reason I staunchly oppose any addition to the number of lifts or strictures in LCC. (I149-2) What I don’t want is to lose more open space for winter touring and undeveloped areas for summer hiking. (O3-1) Expansion would not be beneficial to the ecosystem, watershed, wildlife habitat, viewscape, and appeal of the Cottonwood Canyons to backcountry hikers, skiers, hunters, and casual sightseers. (I66-6) This summer I hiked to a favorite spot to see high alpine wildflowers and was richly rewarded with the brilliant hues of high alpine lupines and Indian paintbrush and flax. High alpine flowers have much richer tones. The alpine meadows above Albion Basin are world class habitat for the most varied species of wildflowers in the world. The following week on a return trip, the same meadow held a very large bulldozer working on the footings for a high speed lift. Mounds of dirt were all that was left of my favorite meadow. Please preserve what is left of our high alpine treasures. (I167-3) If the destruction of wetlands and magestic [sic] high-alpine environments aren’t worth protecting now, just think of OUR future generations, YOUR children and grandchildren that will never get to experience this uniquely Wasatch grandeur. (I55-1) Our public lands deserve better than continued degradation of its wild lands with irresponsible development and growth. It’s our watershed we’re talking about! (I172-1) Little Cottonwood canyon is an environmentally sensitive watershed area that already suffers from overuse. As a consumer of the water that drains from this canyon I, again, oppose any development that would result in more people in the canyon and the resorts that are contained within it. (I205-2)

Opposition to Baldy Tram Please don’t allow Alta to install a tram on Baldy. (I141-1) I do not support further development of the already crowded Little Cottonwood Canyon. Please leave Baldy as it is. (I54-1) It is a place where, believe it or not, many people want to escape city life and hike, on foot or on skis, without the use of ski lifts or trams to reach serene, peaceful peaks and experience wildlife that has not yet been driven out by development. (I55-2) I object to the proposed Tram from Germania Pass to the top of Mt. Baldy. The tram would significantly change the Alta skier experience, and would detract from the beauty

52 of the mountain. Avalanche control in this area should be done by some other means. (I57-1) I DO NOT support more development in the high alpine areas of Little Cottonwood Canyon. I don’t support a Tram up to Mount Baldy. (I59-1) I understand the need for some of the proposed changes and improvements to the resort, but one I cannot support is the proposed new tram to Mt Baldy. (I71-1) Constructing the proposed Mount Baldy tram would be far worse. Its very existence would seriously degrade EVERYBODY’S experience of this unique area in the summer months when a few paying skiers are not around. (I62-2) Please act with a long term view and reject a Baldy tram. (I96-1) I DON'T support the development of a tram up to Mount Baldy. Part of the appeal of Alta over other ski resorts for me was that the resort contained undeveloped areas, and building a tram up to one of the highest peaks in the resort would diminish this. (I67-1) I am strongly opposed to any construction on Mt. Baldy, especially a tram. This would destroy a beautiful view shed, impact wildlife, and impact summer enjoyment of the mountain. Please consider a better solution to the avalanche control than an intrusive tram. (I73-1) Let skiers earn their turns as they always have by making the hike to the top of Baldy when open. (I76-2) Baldy is a very special mountain. Skiing Main Chute in summer is a rite of passage. In winter, the hike is a classic, made all the more special because it is only open once in a while. (I79-1) Further more, the right to ski baldy belongs to those who earn it. Backcountry and side- country travel are ever more popular and only gaining traction. Please do not take away the ability to use our own human power to take us where we want to go on our own terms. (I84-3) This land is used by an increasing amount of people who like to access the peak by their own, selfpropelled means and I strongly discourage this new development. (I101-2) Alta has managed to control avalanches for 80 years with out a tram. I often hike and ski or splitboard Baldy and there need to be areas on sidecountry where people can access peaks on a more limited basis. (I108-3) I am opposed to permitting the construction of a tram to the summit of Mt Baldy. The construction would adversely impact important wildlife habitat but further impact the solitude of the back country in the Wasatch Front. (I125-1) Alta's stock in trade, its brand, is its attitude of leaving as much terrain untouched as possible. Unlike other resorts that try to tame skiing, Alta allows us to be as adventurous as we like, putting as little technology as possible between us and the mountains. (I148-1) Just the sight of Baldy is awe-inspiring, and the experience of bootpacking up and dropping into one of the chutes is sublime. Hiking up and skiing down a "wild" peak is what makes that experience unique and why I ski at Alta. Yes, I know that it's only possible because of Alta's avalanche control work, but that doesn't diminish the experience. However, throwing cables across Ballroom to Baldy would ruin it. Like roping a wild horse or tethering a hawk, Baldy won't be "wild" any more. (I148-2)

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Allowing for a new 150 person per hour tram to connect with Baldy raises a host of concerns, from changing the character of the canyons, to ridgeline protections and the impacts of additional infrastructure, to impacts on wildlife and botanical resources. (A1- 1) While we recognize that Alta Ski Area is in the business of providing lifts and uphill transportation to customers we prefer they do not put a tram to the top of Mt Baldy due to environmental and visual impacts, as well as degrading the character of the mountain. (O1-7) Impacting the Baldy summit and surrounding flora and fauna for the Building a tram to Baldy for the purpose of efficient ski patrol access is not worth the impact to surrounding flora and fauna, viewsheds, or worth compromising the character of the canyon. (O2-8) The Wasatch Mountains should be protected from further development. That means no tram up to highly visible Mount Baldy. (I20-1) I am not alone in opposing the Baldy tram, which will give the area somewhat of a garish theme park feel. (I26-2) I don't believe that we need another eye sore structure atop one of the majestic peaks of the Wasatch. I think that it takes away from the Alta experience and believe that it continues to violate the spirit of the canyons which aims to minimize development. (I76-1) Even if only ski patrollers use the tram, having a lift cable marring the glorious view of the face with Perlas and Little Chute, and adding an ugly tram base to the classic summit, would really be sad and disappointing. (I79-2) I am OPPOSED in particular to the addition of a tram to Mount Baldy. This would simply not be in the best interest of preserving the year-round natural beauty of the area. (I90-1) Please, please no Mount Baldy Tram. One area tram has already significantly altered the beauty of the area. (I98-1) I DO NOT support Alta creating a tram on Baldy areas of Little Cottonwood Canyon. Ski resorts need to allow certain peaks in the Central Wasatch to go without mechanization and impacts to the view shed. (I108-1) The Cottonwood Canyons are are [sic] beautiful natural area that we are lucky to have and that allowing more and more development in them is degrading them. (I111-3) Second as a patron of alta, nothing is more annoying then [sic] getting a look down the beautiful LCC ridgeline and having it obstructed by the snowbird tram station— and still worse, is hearing the snowbird tram from anywhere you have line of site. Please don’t allow this same mistake to happen again. (I132-2) While project's purpose is being sold as primarily about avalanche the intent is obviously to expand the resort. I oppose the expansion into new areas as well as any development that increases the number of skiers to Alta. (I205-1) I could not believe what I was reading when I read that there is this proposal for a tram to the the top of Mt. Baldy. (I195-1) The Utah Chapter of the Sierra Club does not support the tram from Germania Pass to the top of Mount Baldy. It will deface a second peak in the central Wasatch and it [sic] not needed for avalanche control. GasEx is being proposed for other areas within the resort, it can also be used on Mount Baldy for the same purpose. (O4-1)

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I object to the idea of a tram to the top of Baldy. ….Hiking to get the goods is part of the Alta experience. (I192-1) ..lift in this location would not be only an eyesore but I believe that due to the nature of the terrain, it would benefit a very small portion of skiers. (I194-2) One of the great things about Alta is the openness of that area, and the majestic Baldy chutes right above easier skiing. The view from the existing chair is wonderful. The lift would degrade that experience, and flow lots of expert skiers on areas dominated by kids and beginners. (I198-1) I also believe that any new ski lift and associated facilities construction will have the effect of permanently scarring this unique alpine region to the detriment of summer visitors. (I200-2) And in the summer, I would hate to see our beautiful mountain views degraded by wires, buildings. I understand the desire to get rid of the Howitzer, but this is extreme. (I198-2) Tram from Germania Pass to the top of Mt. Baldy. Heavens NO! Baldy is perfect the way it is, stating it is for avy control purposes is obviously a temporary ruose [sic] to get skiers on baldy via lift access. Not a good option. No need for another Tram on a peak that can be seen form [sic] everywhere, incldign [sic] my house in south jordan. (I203-3) Opposition to Other Projects Similarly, the expansion of Albion parking and construction of an equipment facility is a developmental assault, disrupting currently beautiful riparian/woodland area. (I66-4) Based on its role in watershed protection we strongly encourage the USFS to deny approving projects that destroy native wetlands. (O1-23) I am very opposed to Alta's proposal to build new any lifts on our public lands. New lifts, supporting buildings, roads, will negatively impact my experience (and other's) in the Wasatch Range. (I206-1)

Support for Proposed Action The Mountain owners and operators have consistently been excellent partners with the Forest Service, the Town of Alta and the citizens of the Unites States those many years. It is our belief that although some do not support change and development improvements of any kind, those who responsibility manage the change which inevitably occurs should be supported in their efforts. Alta has demonstrated responsible stewardship with their words and deeds for over 79 years and should be supported in their efforts. (I193-2) I believe the EA has not found any issues that can not be reasonably mitigated. (I86-7) Specifically, we support Alta's efforts to construct new lifts from Germania Pass to the top of Mt. Baldy and the Flora lift from the bottom of Sugarbowl to the top of the Collins lift. In addition, we support the replacement of the Sunnyside and Wildcat lifts. Further, we support the additions to both the Watson shelter and Alf's restaurant. Lastly, we support the construction of additional parking in both the Albion and Wildcat base areas and any support structures necessary accommodate the Mountain's needs and an improved skier experience…We support these Improvement projects due to a number of factors. They include improved safety and convenience for individuals who utilize Alta's current facilities on a year round basis. (I193-1)

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Support for Baldy Tram I support all reasonable projects that can get AC complete quickly and safely. Therefore I support the Gazzex AC system installations as well as the tram to Mt Baldy. Alta is notorious for having terrain closed for extended periods because of the difficulty of completing AC safely; this is bad for customers, the ski resort, and Utah. (I86-2) As much as I am against increased traffic, especially those who should not be skiing Mt. Baldy's terrain (ability wise), the improved safety, ability to open more terrain more frequently, and the seemingly limited environmental impact are strong arguments for the cause. (I27-2) FOA is has [sic] many concerns about adding a tram to an untouched area, but also recognize the safety implications for such a proposal. (O1-17) I like the idea of extra lift service on Baldy at Alta. I'm not sure I like a team [sic], but a seated lift would be okay…This is already a developed ski area, I see no problem adding additional lift service. (I197-1) I would like to support the addition of a tram to the top of Baldy for avalanche control, but I would also like to support the continuous opening of hiking gates for access to the area only for advanced skiers which maintains the integrity of the chutes to be accessed by fewer people. (I208-1)

Support for Other Projects I also support the parking lot and building improvement and expansion projects. Alta is one of the top ski resorts in the nation and it needs facilities to serve its customers and compete in the national market. (I86-6) Yes this [Albion/Wildcat base parking] is greatly needed and will ease congestion on the state Hwy. (I203-1) I am also greatly in favor of modifying the Wildcat parking area to better accommodate public transit, we all know what a nightmare parking and driving in Little Cottonwood is, so implementing any strategies to improve the use of public transit and access should be a priority for both Alta and Snowbird. (I208-4) I also think installing GazEx’s would be an awesome safe alternative to getting the Patsey Marley and Devils Castle regions open and available to the public. GazEx's are safer to operate than manual explosives, easier to set off at regular intervals and don't leave remaining hazardous explosive materials on the hill for ski patrol to have to retrieve before opening to the public. (I208-2) I strongly support upgrading the Wildcat and Sunnyside lifts. I also support the new Flora lift to avoid the EBT slope and associated avalanche closures. (I86-5) Replacement of Albion and Sunnyside lifts. Yes, more efficient and practical locations. (I203-5) Replacement of wildcat lift. Yes. (I203-7) Flora lift from bottom of Sugarbowl to the top of Collins lift. Yes. (I203-8) Alf’s restaurant building addition. Yes. (I203-10) Watson Shelter building addition. Yes (I203-11)

56

Structural and Functional Loss in Restored Wetland Ecosystems

David Moreno-Mateos1,2*, Mary E. Power1, Francisco A. Comı´n3, Roxana Yockteng4 1 Integrative Biology Department, University of California at Berkeley, Berkeley, California, United States of America, 2 Jasper Ridge Biological Preserve, Stanford University, Woodside, California, United States of America, 3 Department of Conservation of Biodiversity and Ecosystem Restoration, Pyrenean Institute of Ecology – CSIC, Zaragoza, Spain, 4 UMR CNRS 7205, Muse´um National d’Histoire Naturelle, Paris, France

Abstract Wetlands are among the most productive and economically valuable ecosystems in the world. However, because of human activities, over half of the wetland ecosystems existing in North America, Europe, Australia, and China in the early 20th century have been lost. Ecological restoration to recover critical ecosystem services has been widely attempted, but the degree of actual recovery of ecosystem functioning and structure from these efforts remains uncertain. Our results from a meta-analysis of 621 wetland sites from throughout the world show that even a century after restoration efforts, biological structure (driven mostly by plant assemblages), and biogeochemical functioning (driven primarily by the storage of carbon in wetland soils), remained on average 26% and 23% lower, respectively, than in reference sites. Either recovery has been very slow, or postdisturbance systems have moved towards alternative states that differ from reference conditions. We also found significant effects of environmental settings on the rate and degree of recovery. Large wetland areas (.100 ha) and wetlands restored in warm (temperate and tropical) climates recovered more rapidly than smaller wetlands and wetlands restored in cold climates. Also, wetlands experiencing more (riverine and tidal) hydrologic exchange recovered more rapidly than depressional wetlands. Restoration performance is limited: current restoration practice fails to recover original levels of wetland ecosystem functions, even after many decades. If restoration as currently practiced is used to justify further degradation, global loss of wetland ecosystem function and structure will spread.

Citation: Moreno-Mateos D, Power ME, Comı´n FA, Yockteng R (2012) Structural and Functional Loss in Restored Wetland Ecosystems. PLoS Biol 10(1): e1001247. doi:10.1371/journal.pbio.1001247 Academic Editor: Michel Loreau, McGill University, Canada Received May 27, 2011; Accepted December 8, 2011; Published January 24, 2012 Copyright: ß 2012 Moreno Mateos et al. This is an open-access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited. Funding: Support for this research came from Spanish Ministry for Innovation and Science (www.micinn.es) and Spanish Foundation for Science and Technology through the postdoctoral mobility grants program, and from the National Centre for Earth Surface Dynamics (nced.umn.edu), an NSF Science and Technology Center. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Competing Interests: The authors have declared that no competing interests exist. * E-mail: [email protected]

Introduction rates might be affected by the physical characteristics of the ecosystem, the degrading activity, or the environmental setting From tropical mangroves to boreal peatlands, wetlands are [7,12]. Abiotic factors, such as size of restored ecosystems and amongst the most productive and economically valuable ecosys- climate, might affect recovery rates. It could be expected that tems in the world [1]. They provide critical ecosystem goods and intensely engineered small (few hectares) wetlands might recover services, including carbon storage, biodiversity conservation, fish faster than less manipulated, large wetlands (hundreds of hectares) production, fuel production, water purification, flood and to their original characteristics, but this prediction remains shoreline surge protection and erosion control, and recreation unconfirmed. Higher recovery rates could also be expected in [1–3]. However, owing to human activities, over half of the warmer climates than in cold ones, because of accelerated wetland ecosystems existing in the early 20th century have been ecosystem processes [7,13]. Restoration efforts during the recovery lost in North America, Europe, Australia, and China [2]. Over the process may lead ecosystems to reference states or redirect them last century, restoration of degraded wetlands and creation of new towards alternative states [14–16] that could also be initiated by ones have been attempted, in efforts to recover physical, chemical, prerestoration disturbance itself. If recovery is slow, it could be and biological processes and entities lost because of wetland difficult to distinguish between these alternatives. We surveyed destruction or degradation [4]. Frequently, however, this ap- long-term (up to 100 y, available for some but not all of the studied proach does not restore ecosystem structure and functions to variables) chronosequences of restored wetland ecosystems from preimpact levels [5–8]. In North America (including Canada, 621 restored and created wetlands relative to 556 reference United States, and Mexico) alone, over US$70 billion have been wetlands (Figure S1). Following Article 1.1 of the Ramsar spent attempting to restore more than 3,000,000 ha of wetlands in Convention of Wetlands [17], we considered wetlands to be the last 20 y (see Text S1) [9], but the recovery trajectories of marshes, peatlands, floodplains, mangroves, depressional wet- structure and functions in restored wetlands have not yet been lands, and lacustrine wetlands—submerged permanently or globally assessed [10,11]. periodically under flowing or still fresh, salty, or brackish water. After degradation or natural perturbation, ecosystem structure We compared structure and function of 401 wetlands restored on and functions recover towards reference levels [7,12], but recovery sites where they had been previously degraded and 220 newly

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Author Summary from the same studies were not necessarily independent (see Materials and Methods), so statistical inferences must be Wetlands, which include tropical mangroves and boreal interpreted cautiously. peatlands, are among the most valuable ecosystems in the We compared recovery trajectories of hydrologic, biological, world because they provide critical ecosystem goods and and biogeochemical variables of restored and created wetlands to services, such as carbon storage, biodiversity conservation, address three questions: (a) How fast are biological and fish production, water purification, and erosion control. As biogeochemical components of restored ecosystems changing global change accelerates the loss of wetlands, attempts relative to less perturbed reference ecosystems?; (b) Do these are increasing to restore this fragile habitat and its changes trend towards or away from the predisturbed ecosystem associated functioning. There has been no global evalua- or parallel control ecosystems?; and (c) Does wetland size or tion, however, of how effective such restoration efforts environmental setting (regional climate, hydrologic connectivity) have been. Here, we present a meta-analysis of the biological structure (driven mostly by plant communities) affect recovery? and biogeochemical functioning (driven primarily by the storage of carbon in wetland soils) of 621 wetland sites. Results/Discussion Our analysis suggests that even a century after restoration efforts, these parameters remained on average 26% and Hydrologic and Biological Recovery 23% (respectively) lower in restored or created wetlands Some hydrologic features can often be restored by manipulating than in reference wetlands. Our results also indicate that local topography, soil permeability, surface and ground water ecosystem size and the environmental setting significantly flows—physical features that are usually engineered in wetland affect the rate of recovery. Recovery may be more likely restoration projects. Hydrological features defined for these and more rapid if more than 100 contiguous hectares of analyses (Table 1) appeared to be recovered immediately after habitat are restored. In warm climates, and in settings restoration (Figure 1A), but see Cole [18], Hunt et al. [19], Ahn linked to riverine or tidal flows, recovery can also proceed and Dee [20], and Kumar and Zhao [21] for deeper consider- more rapidly. In general, however, once disturbed, ations of challenges to hydrologic restoration in wetlands (from wetlands either recover very slowly or move towards factors like climate variation [20] or complex flow paths of water alternative states that differ from reference conditions. through heterogeneous vegetation and soils [21]). In addition, all Thus, current restoration practice and wetland mitigation hydrologic variables reported in studies we reviewed were followed policies will maintain and likely accelerate the global loss only for 10 y to 15 y, so longer-term changes remain unknown. of wetland ecosystem functions. In contrast to reported hydrologic performance, biological structure (as defined in Table 1) in restored or created wetlands, created wetlands (wetland creation de novo is currently accepted recovered to only 77% (on average) of reference values (Figure 1A for environmental mitigation [4]). We also examined how size of and 1B; Table S3), even 100 y after restoration, when data on 14 ecosystem and its environmental setting (climate regime and taxa from two studies of three wetland sites are available [22,23]. hydrologic connectivity) affected recovery. Using a standardized Abundance, species richness, and diversity of native animals and method (see Materials and Methods), we selected 124 studies (see plants in wetlands were severely reduced following degradation. Text S2) in which ecological responses were measured at known After restoration, recovery proceeded at different rates, and time intervals since restoration. From the selected studies, we trajectories plateaued at different levels. Vertebrate assemblages extracted 1,501 data points (Tables 1, S1, and S2) comparing reached similar structural values to those in reference wetlands hydrologic, biological, and biogeochemical variables in restored or within 5 y (Figure 1B). Vertebrate richness recovered more slowly created and reference wetlands. Response ratios (see Materials and than abundance (p = 0.021; Figure 2A), possibly reflecting Methods) were calculated for each data point. Variables selected responses by a few highly mobile vertebrate species [24,25] once

Table 1. Variables measured simultaneously in restored or created and reference wetlands to estimate wetland restoration performance over time.

Wetland Structure and Functions na Variables Measured

Hydrology 32 Water level, flooding regime, water storage Biological components 809 Vertebrates 166 Abundance, density, species richness, occupancy Macroinvertebrates 161 Density, abundance, species richness Plants 439 Plant cover, species richness, biomass, abundance Biogeochemistry 692 Carbon storage and cycling 103 Soil total and organic carbon, respiration rate, mineralization rate Nitrogen storage and cycling 102 Soil total and organic nitrogen, denitrification, and nitrification Phosphorus storage 103 Soil total and organic phosphorus, Ca-Fe-Al bounded phosphorus Other elements storage 106 Salinity, soil Fe, Al, Ca, K, Mn, Mg, water dissolved oxygen Organic matter accumulation 177 Soil organic matter, bulk density, soil texture, soil moisture

Only the most frequently measured variables were included (see Tables S1 and S2, for full description of the variables measuring restoration performance). an = number of variables used to plot each chronosequence. doi:10.1371/journal.pbio.1001247.t001

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annual) could accelerate population recovery after they arrive [28,29]. Plant assemblages in restored and created wetlands were slowest to recover. Plants took on average 30 y to converge statistically with reference states; although again, absolute average values of structural features of plant assemblages remained lower than reference levels even after 100 y following restoration (Figures 1B and 2B). The slow and incomplete recovery of plant assemblage might be due to dispersal limitation, vulnerable early life history stages, or sensitivity of any life stage to altered conditions (e.g., reduced organic content of soils, discussed below) during early succession following disturbance [30,31]. Other factors, such as exotic colonists, subsequent disturbance or altered disturbance regimes, priority effects (historical legacies), and nonlinear interactions may also lead to delayed recovery or persistent differences between restored biota and those in reference wetlands [6,31,32].

Biogeochemical Recovery Four biogeochemical responses were sufficiently well document- ed in some studies we reviewed to examine trends over time: these were the storage of carbon, nitrogen, and phosphorus (Figure 1C) (see also storage and cycling combined for carbon and nitrogen in Figure S2A), and the accumulation of organic matter in soil (Figure S2B). The storage and cycling of carbon and nitrogen were drastically reduced from preimpact levels after degradation. In contrast, phosphorus storage seemed unaffected. After restoration, responses were variable. Initially, carbon storage increased slightly but then plateaued below reference levels; nitrogen storage and cycling increased slowly but continuously; and phosphorus storage remained unaffected. Wetland degradation notoriously oxidizes stores of accumulated organic carbon and releases CO2 to the atmosphere, as aerobic conditions accelerate microbial respiration [2,33]. After wetland hydrologic regimes are recovered, more anaerobic conditions allow stores of organic carbon to slowly reaccumulate in the soil. After 20 y, however, carbon storage in restored and created wetland soils was still significantly lower (by 50%; p = 0.008) than in reference wetlands (Figure 1C; Table S3; Text S1; data from six studies of 21 wetlands) Organic matter accumulated slowly [34,35], so that average values remained only 62% of the value at the reference wetlands 20–30 y following Figure 1. Recovery trajectories of created and restored restoration (Figure S2B; data from seven studies of 21 wetlands). wetlands. Chronosequences of the means (6standard error [SE]) of Aerobic conditions in degraded wetlands also perturb nitrogen the response ratios (see Materials and Methods) of restored and created storage and cycling, allowing mineralization of organic N and wetlands at successive age classes of 5 y or 10 consecutive y for transformation of ammonium to nitrate [2]. Nitrate is quickly hydrology, biological structure, and biogeochemical functions (A) and processed by microorganisms and plants, leaving the original pool for the main biological structural components (B). Chronosequences of the means (6SE) of the element loss in soils of restored or created of nitrogen in the soil depleted or unavailable. Nitrogen storage wetlands at successive age classes of 5 y or 10 consecutive y (C). The remained significantly lower in restored wetlands for 30 y after the zero value dashed line represents reference wetlands. Only trend lines wetlands were restored or created (Figure 1C; Table S3). Depleted for those variables for which we had enough data points (see Materials or unavailable soil nitrogen can limit wetland productivity, and Methods) were plotted (N, number of data points used to calculate retarding carbon storage [33,36]. In contrast, total phosphorus the mean [6SE] per age class; Y, years after restoration. Subscripts are as follows: bp, biogeochemical processes; bs, biological structure; C, decreased only slightly in restored or created wetlands and did not carbon; hf, hydrological features; m, macroinvertebrates; N, nitrogen; p, show significant differences with reference wetlands (Figure 1C). plants; P, phosphorus; v, vertebrates). Although, phosphorus chemical fractions could change in doi:10.1371/journal.pbio.1001247.g001 representation, the amount of total phosphorus did not change significantly [37]. This lack of variation in phosphorus might be explained because of the more conservative cycling by phosphorus hydrological connectivity was restored. Macroinvertebrates (64% (lack of exchange with the atmosphere) [38]. In addition, without noninsects) took 5 y to 10 y to statistically converge with reference extrinsic inputs, phosphorus levels would be geologically deter- assemblages in restored and created wetlands (Figure 1B), and mined. average values never reached absolute reference levels. Many After 50 y to 100 y, restored wetlands recovered only to an macroinvertebrates cannot recolonize new or restored wetlands by average of 74% of their biogeochemical functioning relative to themselves, but are carried in by flowing water or other organisms reference wetlands (Figure 1A; data from two studies of seven [26,27]; however, their short life cycles (often annual or semi- wetlands; data of wetlands recovering for more than 50 y after

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Figure 2. Recovery trajectories of animal and plant richness and density. Chronosequences of the means (6standard error [SE]) of the response ratios (see Materials and Methods) of restored or created wetlands at successive age classes of 5 y or 10 consecutive y for vertebrates and macroinvertebrates density and richness (A) and for plant density and richness (B). Insufficient data points meeting our plotting criteria (see Materials and Methods) were available to plot for macroinvertebrate richness. The zero value dashed line represents reference wetlands (N, number of data points used to calculate the mean [6SE] per age class; Y, years after restoration. Subscripts are as follows: md, macroinvertebrates density; pd, plant density; pr, plant richness; vd, vertebrate density; vr, vertebrates richness). doi:10.1371/journal.pbio.1001247.g002 restoration were not plotted in Figure 1A because the sample size variables recovered to reference levels before biological structure did not meet our criteria for average points, see Materials and did (data from eight studies of eight wetlands). Whether this Methods section, on this graph). Since phosphorus storage difference in recovery sequence is a real aspect of tropical appeared only slightly changed, the overall lack of recovery of wetlands, or an artifact of small sample size, remains to be seen. In biogeochemical functioning may have been driven largely by the a much larger sample of studies from temperate climates this low recovery of the carbon storage and the low accumulation of sequence was reversed, and biogeochemical recovery was slower. soil organic matter (see Text S1). Biological structural variables appeared recovered 5 y after restoration, while even 30 y after restoration, biogeochemical Effects of Size and Environmental Setting functions had only recovered to 79% of reference levels (data from Comparing wetland recovery trajectories under different condi- 83 studies of 302 wetlands). In cold climates, corresponding tions may shed light on factors that impede or facilitate recovery. biogeochemical recovery was only 53% 50 y after restoration; Although biogeochemical responses in both restored and created both biogeochemical functions and biological structure variables wetlands were similar, biological structure in created wetlands approached reference conditions more quickly (Figure S3A and S3B; Table S5). Created wetlands may have been engineered to force the initial system towards defined reference conditions [39]. Ecosystem size and local and regional context affect wetland recovery. Large wetlands (.100 ha) appeared to recover their biological structure and biogeochemical functions sooner after restoration or creation than smaller wetlands (Figures 3 and S4; Table S4; data from 13 studies of 25 wetlands). This differential recovery suggests that small wetlands may not provide adequate local resources or connectivity for local biota to restore preimpact functioning. Restored and created wetlands, particularly if small, may have become more isolated and surrounded by more fragmented landscapes than they had been before impact [40]. Also, small wetlands would only be able to support a limited number of individuals, and thus, will not be able to support all the species, particularly taxa with large body sizes, formerly capable of Figure 3. Effect of size on wetland recovery. Evolution of the mean (6standard error [SE]) of the response ratios (see Materials and occupying the area [41]. Methods) of restored or created wetlands at successive size categories Regional climate had a strong effect on the sequence and rate of for wetlands between 0 y to 5 y after restoration or creation. The zero wetland recovery following restoration. As expected, warm value dashed line represents reference wetlands. Mean (6SE) at 0.1 ha temperatures accelerate ecosystem processes [7,13,42], including was estimated for wetlands with sizes #0.1 ha. Means (6SE) at 1 ha those mediating biological and biogeochemical recovery after were estimated for wetlands in which sizes ranged between 0.1 ha and wetland restoration or creation. In tropical and summer-warm 1 ha. The same approach was used to estimate the means (6SE) at 10, 100, 1,000, and 10,000 ha (N, number of data points used to calculate temperate climates, wetlands approached reference conditions the mean [6SE] per age class; size, size in hectares of the restored relatively rapidly, while wetlands restored in cold climates had not wetlands. Subscripts are as follows: bp, biogeochemical processes; bs, recovered to reference conditions after 50 y (Figure 4A and 4B; biological structure). Tables S3 and S5). In tropical climates only, biogeochemical doi:10.1371/journal.pbio.1001247.g003

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Figure 4. Effects of climate and hydrology on wetland recovery trajectories. Chronosequences of the means (6standard error [SE]) of the response ratios (see Materials and Methods) of restored and created wetlands at successive age classes of 5 y or 10 consecutive y for biogeochemical functions and for biological structures under contrasting climates (A and B), and under different hydrologic connectivity (C and D) [31]. The zero value dashed line represents reference wetlands. The arrow (B) indicates the outlier mean value of two restoration studies with extremely low recovery rates (N, number of data points used to calculate the mean [6SE] per age class; Y, years after restoration. Subscripts are as follows: bp, boreal peatland; d, depressional; hc, humid cold; ht, humid temperate; r, riverine; str, seasonal tropical; ste, seasonal temperate; t, tidal). doi:10.1371/journal.pbio.1001247.g004 remained statistically distinct from reference conditions for the chemical functioning. First, the chronosequences we examined entire (50-y) chronosequence (Figure 4A and 4B; Tables S3 and may be too short (,30 y) for full recovery, especially of carbon S5; data from 33 studies of 311 wetlands). and nitrogen storage [44]. Second, restored wetlands may have Hydrologic setting [43] also affected recovery (Figure 4C and 4D; shifted to alternative states, different from their condition before Tables S3 and S5). Riverine and tidal wetlands, linked to larger degradation [14,15]. The subreference plateaus of soil organic hydrologic regimes by natural flow variation, recovered biogeochem- accumulation, carbon storage, and general biogeochemical ical functions and biological structure after 20 y and 30 y, functioning could support the second hypothesis of alternative respectively (data from 73 studies of 210 wetlands). These results states in restored systems. Slow recovery of plant density and are similar to those (15 y to 25 y to recover the original biotic richness might be linked to lags in carbon storage. Mutualist composition and diversity) found by Borja et al. [8] in 51 globally symbionts critical for plant productivity (e.g., N-fixing bacteria [2] distributed estuarine and coastal ecosystems. In contrast, wetlands in or mycorrhizal fungi [45]) may be absent in recently (,50 y) inland depressions that were watered by precipitation or groundwater restored wetland soils. Alternatively, fast-growing, early succes- flow had not recovered to reference conditions even after 50 y sional terrestrial plants, and potentially also wetland plants, usually following restoration (data from 36 studies of 358 wetlands). Peatlands allocate most of their carbon to photosynthetically active structures (usually only the upper layer [,1 m] of peat was removed) recovered of low density and high nutrient content, which are easily grazed biological structure immediately, but 30 y after restoration, biogeo- or rapidly decomposed, retarding local storage of carbon [46,47]. chemical functioning in peatlands remained statistically lower than in reference wetlands (data from 11 studies of 18 wetlands). Comparison with Other Findings Two other studies have assessed recovery rates of large scale Slow Recovery or Alternative States? natural ecosystems following disturbance or perturbations [7,12]. Two hypotheses could explain the lag in biological and Both of these studies examined a broad range of ecosystem types biogeochemical recovery of the biological structure and biogeo- (terrestrial, freshwater, and marine), including wetlands. Jones and

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Schmitz [12] found that across ecosystems and perturbation types nous substrates were imported during the restoration or creation (natural and human-caused), about half of the tracked response activities. For this reason, the term ‘‘construct*’’ was not included variables were considered by original authors to have recovered to in the search terms, because we found in an independent search preimpact states. Jones and Schmitz computed averaged recovery that .99% of the studies of constructed wetlands were of highly times for the subsamples of variables and cases that primary artificial systems not maintained under natural conditions. The authors considered to have recovered over the course of their search produced 2,959 selected articles. We applied the general studies. These recovery times ranged from about 10 y to 40 y, and selection criterion: ‘‘Articles must compare measurements of were longer for forests, and following human-caused, rather than structural components and biogeochemical processes in restored natural perturbations. To assess whether systems had recovered or or created and reference wetlands at a known age.’’ Under this not, Jones and Schmitz used authors’ expert opinion, return to criterion we selected 172 articles. These articles were read, and historic initial conditions, or approach to parallel reference states those in which data were averaged over time intervals larger than (our study evaluated recovery only for studies using the last of these 5 y, those in which sizes differing by more than one order of criteria). Given the narrower scope of our study (assessing wetlands magnitude were averaged, and those lacking reliable measure- only), and our different analysis approach, estimated recovery ments or comparable restored and reference conditions were times from these two reviews are surprisingly similar. Rey Benayas discarded, leaving 124 articles (see Text S2). Reference wetlands et al. [7] studied recovery across a wide range of human-perturbed were usually adjacent to restored or created wetlands, although in ecosystems, including wetlands. Using (as we did) the response some cases they were separated by several kilometers (maximum ratio of restored to reference ecosystems, Benayas et al. found distance found was ,100 km). In all cases, restored or created biodiversity and selected ecosystems services to be 86% and 80% wetlands were of the same wetland hydrogeomorphic type [17] as recovered in a sample of 89 cases pooled over all age categories reference wetlands with which they were compared. From the since perturbation. Interestingly, they reported slightly (6%) higher selected articles, six were carried out on experimental wetlands, recovery in biological variables compared to ecosystems services the rest were carried out on wetland restoration or creation (nutrient cycling; primary production; provisioning of timber, fish, projects. Studies either described measurements at a known age and food crops; and regulation of climate, water supply, and soil). after wetlands were restored or created, or a chronosequence of These ecosystem services overlap in part with categories of the progression during the wetland restoration process. Restored biogeochemical variables in our study (e.g., carbon and nutrient and created wetlands were located in 12 countries and totaled storage and cycling). The similarity between their results and our .21,294 ha in area and reference wetlands .19,694 ha. The finding (that biological variables were 9% more recovered than exact total area is not known because it was not reported in 23 out these biogeochemical responses) suggests that structural recovery of the 124 selected studies. might often be necessary to achieve functional recovery. Data Extraction Conclusions Measurements of structural components and biogeochemical Our meta-analysis suggests that recovery of wetlands following processes were extracted from the main text, tables, and figures of restoration as currently practiced is often slow and incomplete. In the articles. When abundance of one species was measured at warm climates, and in settings linked to riverine or tidal flows, different life stages, only the adult abundance of each species was recovery may proceed more rapidly. Recovery may also be more selected. Variables describing hydrological structure, biological likely and more rapid if .100 contiguous ha are restored. In many structure, element storage and cycling, and organic matter wetlands, however, ecosystem services may not be fully recovered accumulation were classified as structural components or biogeo- even when wetlands appear to be biologically restored. If markets chemical processes according to wetland functions described by for ecosystem services and mitigation offsets from restored or Smith et al. [42], and as ecosystem services described in the created wetlands are used to justify further wetland degradation, Millennium Ecosystem Assessment (MEA) (organic matter accu- net loss of global wetland services will continue and likely mulation was sometimes designated as ‘‘soil formation’’ in the accelerate (see also Race and Fonseca [48]). We join other MEA but not in other soil science references) [49]. wetland ecologists and restoration scientists in calling for better Element storage and cycling variables measured processes scientific understanding of biotic and abiotic factors that constrain (mineralization or denitrification) and concentration of elements ecosystem restoration. For our common future, we need more in different pools (total content in soil, organic content in soil, or realistic, long-term evaluations to find better ways to alleviate content in roots), which suggest how nutrients are moving between constraints limiting the recovery of wetland ecosystems. pools through biotic and abiotic processes (Tables S1 and S2). The studies presented enough data points to plot recovery of storage of Materials and Methods carbon, nitrogen, and phosphorus. Literature Search Response Ratio Calculation On the 22nd of December 2010 a reference search was done in To standardize and compare data, we used standard response the scientific database ISI Web of Science – SCI-Expanded. The ratios used in meta-analysis, ln(Xrest+1/Xref+1) [3], where Xrest is terms used were ‘‘(wetland* or floodplain*or peatland* or marsh* the value of the measured variable in the restored or created or mangrove*) same (restor* or creat* or re-creat* or rehabilit*).’’ wetland and Xref is the value of the measured variable in the We used these terms to cover a wide variety of wetlands as defined reference wetland. To avoid the value ‘‘0’’ in the natural logarithm in the Article 1.1 of the Ramsar Convention text [7]. For this of the equation, ‘‘1’’ was added to both values in restored or analysis, we considered restored wetlands to be wetlands recreated created and reference wetlands. The effect of adding ‘‘1’’ to the on sites where wetlands had formerly existed but been drained or values in the response ratio equation has been demonstrated to otherwise severely degraded. Created wetlands were described by have little effect on conclusions [50]. The effect size was not authors as wetlands built on sites that lacked previous wetland weighted because variance was reported for only 64% of the history. We selected studies of wetlands under natural hydrological variables. Differences between weighted and unweighted meta- regimes, planted with native species, and in which no allochtho- analysis statistics are generally small [7].

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As variables depicting structural components and biogeochem- difference from reference conditions) for each estimated mean of ical processes in restored or created wetlands converged to values the response ratios for variables at each age interval of a restored in the reference wetlands, recovery of function was generally or created wetland. To test for differences between the same enhanced. But for some variables, such as soil bulk density [51,52], variable measured under two different environmental settings at a or proportions of exotic species [53,54], higher values are given recovery time, we used Kruskal-Wallis tests. associated with lower levels of wetland recovery. In some cases, the specific context of a study made variables negative for recovery Chronosequences Plotting of a particular restored wetland, e.g., the presence of woody To plot the temporal trends, the mean values and the standard species where none had occurred in the reference wetlands error of each variable with every age class of 5 y (0–4.9, 5–9.9, etc) [55,56]. In these cases (11% of the collected variables), we changed were used. The criterion for a mean for a certain age class to be the sign to reverse the value of the response ratio. used in the plot was that it must have been derived from at least nine different data points obtained from at least two different Data Classification studies. When this criterion was not fulfilled, the mean values and For each variable we recorded the age of the restored or created standard error of age classes of 10 y (e.g., 10–19.9, or 20–30) were wetland, the wetland hydrogeomorphic type, the number of used. Temporal trend lines were fitted when enough data to restored or created and reference wetlands considered in a given calculate means for two or more age classes were available. study, the size (ha) of the restored or created and reference wetlands, the initial condition (restored or created), the geographic Supporting Information location, and the climate. Most data (49%) were from wetlands that had been restored or created for less than 5 y (Figure S1). If Figure S1 Distribution of wetland sizes across wetland data from several wetlands of different sizes were averaged in the ages for the 654 restored and created wetlands consid- study, then we also averaged the sizes for our analysis. The ered in the study. geographic location was registered as the latitude and longitude in (TIF) degrees of the center of the wetland or group of wetlands. The Figure S2 Chronosequences for the storage and cycling climate was classified according to the last revision of the Ko¨ppen- of carbon and nitrogen (A), and for the accumulation of Geiger climate classification [57]. We used the name humid organic matter in soils (B). temperate climate for Cf climate, humid cold climate for Df (TIF) climate, seasonal temperate climate for Cs climate (with dry Figure S3 Chronosequences for biogeochemical pro- summer), and seasonal tropical for A climates. Two of our sampled cesses (A) and for biological structures (B) under studies were done in seasonal temperate climate with dry winter contrasting initial conditions (restored wetlands versus (Ko¨ppen-Geiger climate classification Cw), and were not consid- wetlands created de novo in dry lands). ered in our climate study. Wetland hydrogeomorphic type was (TIF) classified according to Brinson [58] and Smith et al. [42] as depressional, riverine, tidal, peatland, lacustrine, and seeping Figure S4 Evolution of the response ratios of restored slope. Only three studies were on lacustrine wetlands and one on or created wetlands at successive size categories for seeping slope wetlands, so these types were not considered in our wetlands between 5 y to 15 y after restoration or study of differences among wetland types. creation. In studies where more than one wetland was studied and data (TIF) were available for each individual wetland, data were collected for Table S1 Variables measuring structural components. each wetland. In 27 studies, more than one wetland was compared (DOC) with the same reference wetland, and in 11 studies, restored or created wetlands were compared with more than one reference Table S2 Variables measuring biogeochemical process- wetland. All studies where more reference rather than restored or es. created wetlands were studied provided only averaged data for (DOC) both groups of wetlands. We calculated contingency tables Table S3 Statistical significance of differences between between the wetland size, the initial conditions (created versus the means of the response ratios in restored or created restored), and the covariates included in the environmental setting versus reference wetlands. section (climate and wetland hydrogeomorphic type), using (DOC) contingency coefficients (C), to test for independence between them. Wetland type showed relevant degrees of association with Table S4 Statistical significance of differences between the climate (C = 0.63) and wetland size (C = 0.58), the rest of the means of the response ratios in restored or created variables had coefficients below 0.5, indicating low degree of versus reference wetlands at each size interval. association. These associations may be explained by the influence (DOC) of the climate on wetland types, e.g., peatlands are usually Table S5 Statistical significance of differences between associated to cold climates, and mangroves to tropical climates. the response ratios in restored or created wetlands Also, peatlands usually extend over vast surfaces (hundreds or under different environmental settings. thousands of hectares) and depressional wetlands are usually small (DOC) basins (less than 10 ha or few tens of hectares). Text S1 Wetland restoration investment and carbon Statistical Analysis storage calculation. (DOC) Because data were non-normally distributed (according to the Kolmogorov-Smirnoff test for normality), we used Wilcoxon Text S2 References used in the meta-analysis. signed rank tests to test for significant deviations from zero (no (DOC)

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Acknowledgments Author Contributions We acknowledge the comments from Joy B. Zedler, Oswald Schmidt, J.M. The author(s) have made the following declarations about their Rey Benayas, William E. Dietrich, Andrea Swei, and one anonymous contributions: Conceived and designed the experiments: DMM MEP. reviewer on earlier versions of the manuscript, and the collaboration of Analyzed the data: DMM. Wrote the paper: DMM MEP. Performed the Maribel Vara Rodriguez. meta-analysis: DMM RY. Interpreted and discussed results from the meta- analysis: DMM MEP FAC.

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From: Hotze, Rebecca - FS Sent: October 17, 2017 5:42 PM To: Condrat, Charlie -FS Subject: RE: Alta wetlands

Thanks Charlie – I told them they need to avoid the wetlands or do a 5-1 mitigation ratio since that is what they just did… We’ll see. Mike Maughn is calling me to discuss and I’ll let him know as well.

Thank you, Bekee

Bekee Hotze District Ranger

Forest Service

Uinta-Wasatch-Cache National Forest, Salt Lake Ranger District

p: 801-733-2675 f: 801-733-2684 [email protected]

6944 South 3000 East Salt Lake City, UT 84121 www.fs.fed.us

Caring for the land and serving people

From: Condrat, Charlie -FS Sent: Tuesday, October 17, 2017 5:10 PM To: Hotze, Rebecca - FS Subject: FW: Alta wetlands

Bekee, here are some of my thoughts about the wetland survey Tim Royer did.

 Since the base area of the proposed Flora Lift is in a wetland, there needs to be a discussion in the EA on the evaluation that took place that concluded that these wetlands cannot be avoided.  If these wetlands cannot be avoided, then mitigation of wetland impacts need to be presented in the EA.