The Forest Service seems intent on continuing to ignore the reality that ski areas often propose expansions not to serve a public recreational need, but to increase the value of private land for ski-in/ski-out second home sales.  Over four years ago (November 22, 1998), the Denver Post declared that the Forest Service:
 

“don[s] blinders when reviewing ski-area plans, looking only at the immediate proposals put in front of its nose, not the big picture… For the Forest Service to pretend its decision’s aren’t central to the off-site development potential is patently absurd.”

As with the Draft, the Final Environmental Impact Statement (EIS) for the WRNF Plan Revision used faulty assumptions in rationalizing that there isn’t enough skiing acreage, and that skier numbers would rise significantly.  Similarly, the notice for the Ski Tip proposal rationalizes a need to “reduce the existing crowding at Keystone Resort” and “reduce visitor congestion issues at ingress/egress (entry/exit) locations on the front side of Keystone Resort”.  The notice suggests that the Forest Service will consider nothing but Keystone’s expansion proposal, excluding reasonable alternatives such as increasing lift capacity or decreasing down time of existing lifts.

Ecological Impacts

The wildlife impacts from development into and encroaching upon Jones Gulch may be ecologically devastating.  An October, 1999 report prepared for the now abandoned Parcel A development proposal noted the importance of Jones Gulch for wildlife movements:
 

“As part of the environmental analysis associated with the adjacent, proposed expansion of Keystone Ski Area into Jones Gulch, wildlife biologists analyzing the Canada lynx (Felix lynx canadensis) issue identified a potential landscape linkage (part of a long distance movement corridor) running through Jones Gulch that was, and is, considered vital for the long term viability of lynx in Colorado.  Parcel A, located at the mouth of Jones Gulch, occurs on the western edge of a portion of this potential movement corridor… resource biologists are in nearly complete agreement regarding the corridor’s boundaries, the biological importance of this corridor to lynx and other species, and the significance of Parcel A.”

The Ski Tip lift, run, and snowmaking may similarly affect the integrity of this wildlife movement corridor.  According to the U.S. Fish and Wildlife service, “Jones Gulch represents the last remnant of a naturally broad forested corridor through the Snake River Valley connecting broad components of the ecosystem to the north and south ... if it is lost, all remaining potential for landscape connectivity from the Continental Divide to the Ten Mile Range will be lost permanently.”

Snowmaking with Polluted Water?

Even though a recent study showed Keystone’s snowmaking is polluting untainted drainages with toxic heavy metals from the Snake River, the resort and Forest Service haven’t implemented any promised water quality improvement projects other than standard practices required as part of their permit.  In a March 10, 2000 press release, WRNF Supervisor Martha Ketelle stated that "The ultimate solution to these issues it to clean up the Snake River... Keystone and the Forest Service are involved in the cleanup effort in conjunction with the Snake River Task Force."  Yet the Task Force has not made progress in proposing or implementing clean up measures.

Now Keystone is proposing to cover an additional 19 acres with polluted man-made snow, likely in violation of the Clean Water Act as no point-source discharge permit has ever been granted.  In an October 19, 2000 letter to Colorado Wild, the Forest Service stated that "If sufficient data is collected in the above referenced study to indicate that Keystone's operations are not consistent with federal, state, or local environmental laws, then the Forest Service would require Keystone to come into compliance with the terms of its permit."  Even though the study demonstrated a likely violation of the Clean Water Act, the Forest Service has not only failed to take action to bring Keystone into compliance with the terms of their permit, but is now entertaining Keystone's proposal for even more snowmaking.

Landslide Risks

In a July 30, 2001 memo regarding expansion into Jones Gulch, both the WRNF soil scientist & hydrologist concluded that “…there is little argument about the instability of the terrain… adding water (snowmaking) and removing vegetation are typically the opposite measures employed to stabilize landslide terrain.”  Even former Regional Forester Lyle Laverty, in a Feb. 15, 2000 letter, took the unusual step of declaring that “The Jones Gulch snowmaking proposal, as currently envisioned, seems to be out of step with the spirit of the [ski industry’s] Environmental Charter…”  The expansion proposal, particularly coupled with snowmaking, will increase landslide risk on already unstable slopes.

Take Action!

Write your letter to the Forest Service postmarked by July 20, 2002.  Include some or all of the following points in your letter:
 

• Ask how the Forest Service can objectively evaluate the proposal, including alternatives to any possible crowding problems, when they have already expressed support for an expansion alternative?
• Demand that the Forest Service acknowledge the obvious motivation for the expansion – to increase the sale value of ski-in/ski-out condos at the base of the proposed lift and ski run.
• Request that the Forest Service reject any current or future expansion proposal into Jones Gulch, including the Ski Tip lift, run, and snowmaking currently proposed.
• Should the Forest Service not shelve the proposal altogether, request they assess landslide risks, ecological impacts on wildlife habitat connectivity statewide, snowmaking with polluted water in clean drainages and the need for Clean Water Act point-source discharge permits, and whether the supposed need for the proposal can be accommodated through other alternatives.
• Insist they perform a full EIS for the project, and ensure the integrity of analysis by not contracting with SE Group – known for its biased analyses tilted toward the ski industry’s expansion proposals.

Send your letter, postmarked by July 20, to:

Jamie Connell – District Ranger
Dillon Ranger District
P.O. Box 620
Silverthorne, CO 80498
Fax: 970-468-7735

For more information, contact:

Jeff Berman, Colorado Wild Executive Director
E-mail, 970-385-9833

Michael Liu, US Forest Service
mcliu@fs.fed.us, 970-262-3440