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How
to Comment on the Draft Environmental Impact Statement for Arizona Snowbowl
Both of the Action
Alternatives in the Snowbowl DEIS will cause harm to the unique environmental,
cultural and visual values of the San Francisco Peaks with little or
no return to local economies. The snowmaking alternative requires a
significant commitment of treated wastewater that currently recharges
Flagstaff’s well fields; this water will not be available to Flagstaff’s
wells should it be used for snowmaking.
Thank you for taking
the time to comment on this proposal. Your comments are important, not
because this is a voting matter, but because they establish a record
of public opposition and raise issues that the Forest Service must address.
You can write anything you like in your comments and comment as many
times as needed to address additional topics. Because comments that
raise specific issues linked to the DEIS are most likely to affect the
Forest Service’s decision, we ask that you include the following
in your comments:
• State that the Forest Service
should choose Alternative One, the No Action Alternative.
•
This is a significant and highly controversial proposal that requires
every possible effort to allow affected publics opportunities for input.
Therefore ask that:
1) The comment period should be extended to 120 days.
2) Hearings should be located within a reasonable distance for the members
of all 13 tribes for whom the San Francisco Peaks are culturally and/or
spiritually significant.
3) The DEIS and EIS should be translated into the languages of all 13
tribes for whom the San Francisco Peaks are culturally and/or spiritually
significant.
•
Oppose any New Uses, especially snowplay, tubing, and new parking.
•
State that the Forest Service failed to notify stakeholders during scoping
that the proposal would result in a new Master Plan for the AZ Snowbowl
and a Forest Plan Amendment. These are significant actions.
•
The 17 issues identified in the DEIS as “tracking” issues
should be identified and treated as significant issues.
Traditional Cultural Property and Wilderness values, socio-economic,
hydrology, geology, soils, wildlife, vegetation, water purity, traffic,
access, aesthetics, noise, air quality and geotechnical issues are all
highly controversial in their potential to affect the environment, social
values and cultural values on the Peaks and in surrounding communities.
These issues should drive alternatives and mitigation and require in-depth
analysis/disclosure.
•
While the DEIS reveals that AZ Snowbowl’s contribution to the
Flagstaff and Coconino County economies is insignificant, it fails to
demonstrate that either Action Alternative will meet the Purpose and
Need as stated in the DEIS:
1. “To ensure a consistent and reliable operating season, thereby
maintaining the economic viability of the Snowbowl and stabilizing employment
levels and winter tourism within the local community” (emphasis
added).
Specifically, it states, but does not
give convincing evidence that:
1) This action is economically feasible for the current owners
2) This action will ensure a consistent and reliable operating system.
Evidence suggests that skiers go to ski areas when it snows (http://www.skiareacitizens.com).
3) This action will result in a significant economic contribution to
the local community, let alone “stabilize employment levels and
winter tourism”.
•
The DEIS acknowledges that the Action Alternatives will result in potential
irreversible and irretrievable impacts to the spiritual and cultural
values of thirteen Native American tribes; the mitigation described
in the DEIS is inadequate and unacceptable.
The DEIS pretends that the intense negative cultural impacts to tribal
members can be mitigated by ensured continued access (Page 3-17) and
“the development of a Cultural Center within the SUP area.”
(Page 3-27). It also indicates that ground disturbance impacts, while
they “can be regarded as irretrievable in nature,” are not
considered irreversible because “the ground could be allowed to
recover over time should the Snowbowl facilities ever be disassembled”
(Page 3-28). This demonstrates a ludicrous and willful refusal to understand,
let alone respect, the nature of the tribes’ relationship to the
Peaks which is described fully elsewhere in the DEIS and acknowledged
by the Forest Service’s nomination of the Peaks for listing in
the National Historic Register as a Traditional Cultural Property (TCP).
•
The DEIS barely touches on the important issue of reduced recharge to
the Regional Aquifer and available water for City wells, stating that
“…this issue extends well beyond the scope of this EIS.”
(Page 3-200).
A hydrological report submitted as comments during scoping by two hydrologists
states that “the proposed snowmaking would result in a net loss
on water from the regional water budget of up to six percent of the
City’s current water use. Accordingly, this may cause groundwater
levels to decline near the City’s wells in east Flagstaff”
(Schwartzman and Springer, 2002). The DEIS does not acknowledge projected
population growth and associated increases in water demand; it also
does not acknowledge climate change.
The
EIS must include new information and an impacts analysis of the potential
presence of Pharmaceuticals and Personal Care Products in the reclaimed
water. Concerns over these substances are the subject
of new research-that the EPA does not require tests or treatment for
these substances is not a justification for dismissing applicable information.
Comments
can be submitted the following ways:
•Directly to the Forest Service via the online
submission form
• Via the Web (e-mail).: comments-southwestern-coconino-peaks@fs.fed.us
• In writing, to Ken Jacobs, Team Leader, 5075 N. Highway 89,
Flagstaff, AZ 86004
• In writing at the Open House - February 25, 2004, from 4:00
PM to 8:00 PM at Flagstaff High School, in the commons area
• Orally, by calling (928) 226-4601 and leaving a voice recording
For more information about issues surrounding the proposed snowmaking
and development at the Arizona Snowbowl and how to comment on the DEIS
or to view the hydrology report, go to www.savethepeaks.org. and www.flagstaffactivist.org.
The DEIS is available at: http://www.fs.fed.us/r3/coconino/publications/snowbowl/index.shtml
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