CHAPTER 5 RESPONSE TO COMMENTS 5.1 INTRODUCTION The Notice of Availability (NOA) for the Montana Snowbowl Expansion DEIS was published in the Federal Register on March 11, 2011. A 45-day public comment period was held from March 11 through April 25, 2011. One open house regarding the proposed project and DEIS was held at the Grant Creek Inn in Missoula on March 30, 2011. Staff from the LNF, MSB and the third- party EIS contractor (Atkins, formerly known as PBS&J) held a presentation, had a brief question and answer period and were available to answer questions from 5:00 to 7:00 pm. Seventy members of the public attended the open house. Individuals, agencies, non-governmental organizations, and businesses submitted comments at the open house on comment forms and via mail, electronic mail (email) and phone. A total of 61 responses were received (Appendix E). There were no form letters received. 5.2 CONTENT ANALYSIS Content analysis is the process of compiling, categorizing and analyzing all comments received during the DEIS public comment period. This process incorporates public viewpoints and concerns into the FEIS and facilitates appropriate clarifications, adjustments or the addition of information. It is important to note that this process does not treat comments as votes for or against a proposed project. A majority of comments in favor or against the proposed project does not have bearing on the decision of the LNF. Each response was given an identification number. Comments within each response were categorized and sorted by resource or topic and paraphrased if necessary for clarity and consistency. The respondents that included that comment are identified by number. Comments that simply stated support for or opposition to the project were not included in the content analysis. The LNF responded to each substantive comment (Sections 5.2.1 through 5.2.17). The original verbatim comments are provided in Appendix E. 5.2.1 Purpose and Need 1. The proposed project will expand the terrain and serve more of the public (beginners and intermediate skiers) than is currently offered at MSB. Respondents: 1, 3, 4, 5, 8, 19, 29, 32, 37, 45, 47, 49, 54, 56, 58, 60, 61. Response to comment: We agree. That is the Purpose and Need of the project (Section 1.4, p. 1-7 of the FEIS). 2. The proposed project would not provide terrain appropriate for beginner and intermediate skiers. Respondents: 17 Response to comment: The LNF believes that the proposed project would provide terrain appropriate for beginner and intermediate skiers. The available beginner and intermediate terrain at MSB would increase from 105 acres to 144 acres. The number of beginner and intermediate SAOT that could be accommodated at MSB would increase Final EIS 5-1 Montana Snowbowl Chapter 5 Response to Comments from 1,050 people to 1,440 people. The LNF feels that this increase does represent an adequate increase in ski terrain for beginner and intermediate ability skiers and therefore meets the Purpose and Need for the project (Section 1.4, pp. 1-7 through 1-10 of the FEIS). 3. There is no justification for expanding MSB. Respondents: 16, 21, 51, 52 Response to comment: Any proposed project that would utilize public lands must undergo an analysis of whether the project meets the stated Purpose and Need for the project, as required under NEPA. The Purpose of and Need (Section 1.4, pp. 1-7 through 1-10 of the FEIS)for this project is based on the goal of the Forest Plan (USDA 1986) to provide recreation opportunities including developed and year-round recreation. These opportunities include: Providing additional ski terrain Providing additional beginner and intermediate ski terrain Enhancing summer use and balancing summer and winter use. The proposed project would increase ski terrain at MSB from 255 acres to 441 acres. The available beginner and intermediate terrain at MSB would increase from 105 acres to 144 acres. Summer use would be enhanced by adding more chairlift-serviced hiking and mountain bike trails and access to the new lodge for summer guest services. The LNF feels that the proposed project meets the Purpose and Need; and therefore, that the expansion of MSB is justified. 4. Meeting current and future ski area demand is the main premise behind the "needed" Snowbowl expansion; however, figures expressed within the DEIS do not support this. The DEIS's first chapter states that the three- year average of skier visits to Snowbowl for the 2004-2009 seasons was nearly 10 percent lower than 2002-2004. These figures also express a general decline at MSB after the 2003 closure of Marshall Mountain Ski Area. The numbers don't lie. Data brought forth in the DEIS to support the "need" for expansion actually refutes any "need." Respondent: 21 Response to comment: The number of skiers that visit a ski area is heavily influenced by snow conditions. Low snowpack as a result of drought conditions in the last 10 years resulted in several years where skier numbers were low at MSB, as they likely were at all regional ski areas. The year that was most instrumental in the drop in the 2003-2005 three-year skier average shown on Figure 1-3 (p.1-9 of the FEIS) was the 2003-2004 ski season; due to the lowest snowpack in 20 years MSB only recorded approximately 39,000 skiers that year. In comparison, the 2010-2011 ski season, which had a record high snowpack, brought 74,050 skiers to MSB. The most recent data has been added to Figure 1-3. Although skier numbers are difficult to predict the LNF believes that there is an increased need for more beginner and intermediate terrain at MSB, especially after the closure of Marshall Mountain. Final EIS 5-2 Montana Snowbowl Chapter 5 Response to Comments 5. The 2006 document states unequivocally that the Missoula region does not need to increase ski area capacity to keep up with demand. Therefore, this issue should have been moot for some time. Respondent: 21 Response to comment: We believe the commenter is referring to the “Downhill Skiing Needs Assessment for the Bitterroot and Lolo Forest Plan Revisions” (Ryberg 2005). This document concludes, “Based on the analysis of local and regional ski area capacity, the existing or approved capacity of these ski areas is adequate to accommodate projected increases in skier/snowboarder visits within an acceptable utilization range. Considerations should be given to Montana Snowbowl’s proposal to provide a more balanced mix of terrain to meet the desires of the skiing public.” One of the elements of the Purpose and Need for the proposed project is to provide more ski terrain (Section 1.4.1, p. 1-8 of the FEIS). However, another element is to provide additional beginner and intermediate terrain (Section 1.4.2, p. 1-10 of the FEIS). The Ryberg (2005) document states that consideration must be given to this purpose based on the analysis provided in the report. 6. Wants and needs differ drastically, and for the USFS to acquiesce to the wants of a small, self-interested, and vocal population sends the wrong message to the public at- large. Respondent: 21 Response to comment: As discussed in the Purpose and Need for this project includes providing additional ski terrain as well as additional beginner and intermediate ski terrain, and enhancing summer use and balancing summer and winter use (Section 1.4, p. 1-7 through 1-10 of the FEIS). These needs were identified, and the desires of any group, whether majority, minority or otherwise, have no bearing on the decision whether or not to allow the expansion of MSB. 7. Adding more beginner and intermediate terrain at MSB will fill that which was lost when Marshall Mountain closed. Respondents: 4 Response to comment: We agree. That is the Purpose and Need of the project. 8. The proposed project is not an appropriate use of public lands. Private entities should not gain financially from public lands. Respondents: 21, 50 Response to comment: The LNF adheres to the goals and standards laid out in its current Forest Plan (USDA 1986). Forest Plan Standard 6 states in part: The LNF will provide for a wide spectrum of Forest-related dispersed recreation and range of skill levels available to Forest visitors including the elderly and handicapped. The program will provide for use of the Forest on a year-round basis in areas that will minimize conflicts between user groups and other Forest resources. Final EIS 5-3 Montana Snowbowl Chapter 5 Response to Comments Forest Plan Standard 7 states in part: Emphasis will be placed on increasing the use of existing sites by making them usable by a wide segment of society….The private sector and other agencies will be encouraged to provide for increased public needs on National Forest System land and on lands adjacent to the Forest. If and when development proposals are received for expansion of existing or construction of new ski areas, they will be evaluated according to the normal procedures for determining ski area feasibility. These standards do not preclude financial gain by a proponent. 9. The area has already been developed as a ski area or has a history of past management; therefore it is an appropriate place for the proposed project. Respondents: 26, 29, 58, 60, 61 Response to comment: No response necessary. 10. MSB is not providing adequate services to their customers within their current SUP area and must do so before they are allowed to expand. Respondent: 24 Response to comment: The LNF cannot evaluate MSB’s customers’ satisfaction with their operation as part of the NEPA analysis for this proposed project.