This is not intended to be read as a comprehensive critique of the Draft Environmental Statement (DEIS) or as formal comments on that document. It is intended to point out some of the important issues with the analysis and Preferred Action and to enable readers to easily locate these issues by page number in the DEIS.

Under Purpose and Need for the Proposed Action, the purpose of the proposal is described as:
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).

2. “To improve safety, skiing conditions, and recreational opportunities, bringing terrain and infrastructure into balance with current use levels.” (pp ES-3-4)

Although the purpose and need includes “stabilizing employment levels and winter tourism within the local community”, under the Social and Economic Resources section (p 3-71), the DEIS states numerous times that Snowbowl’s contribution to the Flagstaff and Coconino County economies is insignificant:

Page 3-71
“In contrast with a number of other ski resorts in the Rocky Mountain region, the Arizona Snowbowl is not a dominant driver of growth and the economy in its host community.”

Page 3-75
“While the Arizona Snowbowl is not a dominant force in the economy, tourism, of which the Snowbowl is a part, is usually identified as the Flagstaff area’s primary industry. While a number of factors play a part in tourism, it is clear that the presence of the Grand Canyon … brings a substantial number of persons through the area.”

Page 3-78
“From a statistical perspective, Alpine skiing accounts for a minor segment of the State of Arizona’s travel activity. … skiing volume does not have a major impact on statewide visitation.”

Page 3-113
“… even a cursory examination of the scope of the ski area operation in comparison with the full scope of the Flagstaff area economy makes it clear that the ski area is of insufficient size to be a dominant driver of trends in tourism or the broader economy.”

Page 3-80
“Although the Arizona Snowbowl does not ‘drive’ the Flagstaff area economy, it is apparent that the ski area is a provider of jobs and that ski area visitors are positive contributors to the area economy.”

The DEIS, on this same page, notes that, on average, Snowbowl directly provides the full-time equivalent (FTE) of 172 jobs. The same document minimizes impacts to the heritage resources of the mountain and the proposed actions impacts to spiritual and ecological values by stating that the developed area is only 1% of the total area of the mountain and that the “proposed action would affect approximately one percent of the total spruce-fir forest cover on the San Francisco Peaks and approximately 14 percent of the spruce-fir forest within the SUP (Snowbowl special use permit) area” (pg. 3-260).

Yet nowhere does it similarly minimize Snowbowl’s total direct contribution to area employment as only .29% of jobs in Coconino County, although this is what the numbers reveal.

The DEIS questionably predicts that at the end of the ten year planning period, with snowmaking, Snowbowl will indirectly and directly provide 564 FTE jobs. Even if this does occur, Snowbowl’s contribution will still only be .95% of jobs in the County, or less than the 1 percent of the San Francisco Peaks that the ski area impacts.

Page 3-121
“Given the small segment of the BBB tax generated by Snowbowl visitors, it is unlikely that overall BBB tax collections would have a significant correlation with business activity at the Snowbowl; Snowbowl related collections constitute too small a percentage of total collections.”

The Bed Board and Booze tax is a two percent tax collected on all purchases at local restaurants, lounges, hotels and campgrounds in Flagstaff. This is a category of business that would most likely be affected by any significant contribution to the Flagstaff economy from Snowbowl’s business. Data from the City of Flagstaff and tables in the DEIS make it clear that Snowbowl visitation does not have a significant correlation with Flagstaff tourism or BBB revenues.

Under Issues and Indicators, the DEIS states that:
“Based on the results of internal and public scoping, the Forest Service identified specific areas (resources) of concern and classified them as being either: 1) significant issues that drive alternatives, require mitigation, or generally require in-depth analysis/disclosure; 2) tracking issues that do not necessarily drive alternatives or mitigation, but are tracked throughout the analysis with their effects disclosed; and 3) non-issues. (Page 1-11).

Of 19 issues presented in the DEIS, only two are treated as significant issues. The rest are treated as “tracking” issues, an arbitrary definition or category that does not relieve the Forest Service of its responsibility to treat these issues as significant.

The two significant issues identified in the DEIS are Heritage Resource Issues:

“Issue # 1: The installation and operation of snowmaking infrastructure as described in the Proposed Action, and the use of reclaimed wastewater as a water source, will impact cultural and spiritual values associated with the San Francisco Peaks.”

Issue # 2: Proposed ground disturbances and vegetation removal may result in permanently evident, visible alterations (i.e., “scarring”) of the San Francisco Peaks’ landscape.” (Page 1-12)

The DEIS is disingenuous regarding Heritage Resource Issues.
The DEIS acknowledges the importance of the San Francisco Peaks to thirteen Native American tribes and admits of snowmaking that “based on the belief systems of many of the tribes we must consider at least a portion of these impacts as a potentially irreversible impact to these tribes’ religions.” Ironically, 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).

The DEIS pretends that the intense negative cultural impacts to tribal members of further development and snowmaking can be mitigated by ensured continued access (Page 3-17) and “the development of a Cultural Center within the SUP area.” (Page 3-27).

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).

According to the DEIS, “A TCP is a place that is associated with the cultural practices or beliefs of a living community. Those practices or beliefs must be rooted in the history of the community and be important in maintaining the continuing cultural identity of the community” (Page 3-4).

The DEIS further notes that “The concept of landscape should be considered when discussing Native American relationships to the land.” “Many groups consider the landscape to be part of a living cultural system, which encompasses both the people and the land together.” (Page 3-7). This understanding, as well as the comments of hundreds of tribal members and statements from tribal representatives, makes it clear that the issue is not one of access to particular sites. This is further affirmed by the TCP boundary, which encompasses the 74,000 acres surrounding and including the entire mountain. Any development that affects the Peaks natural environment damages the “continuing cultural identity” of the region’s Native American tribes, including, perhaps especially, the development of a Native American Cultural Center.

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 found that the potential use of 552 acre feet (AF) of reclaimed water per year for snowmaking raised significant concerns about how proposed snowmaking at the Arizona Snowbowl facility will affect water availability in the Flagstaff region. This report 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 attempts to dismiss these concerns with a table incorporating questionable estimates of comparative ground water recharge. The DEIS minimizes the projected impacts in several ways:
1) It does not analyze the impacts of full use of the allotted water, 552 AF, but rather of partial use, 358 AF.
2)While it incorporates Schwartzman and Springer’s estimates for evapotranspiration from the Rio de Flag, it assumes that around 50 percent of the reclaimed water used will contribute to groundwater recharge, an estimate far below the 60-90 percent Schwartzman and Springer project as a reasonable estimate of water that will be lost to sublimation at Snowbowl.
3) While Schwartzman and Springer look at the percent net loss of the City’s water use on a current year estimate, the DEIS compares the net loss with the City’s water production as averaged over a ten year period, which is highly questionable in view of the drier conditions the area has experienced in recent years.
4) The DEIS does not acknowledge projected population growth and associated increases in water demand; it also does not acknowledge climate change, even though Schwartzman and Springer cautioned in their report that “Climatic indicators over the past three years suggest a transition away from the 1978-1998 PDO [Pacific Decadal Oscillation] phase and its associated wet climate” and that “… population is expected to increase by about 35 percent from 2000 to 2020. If per capita water use stays constant, total water use can be reasonably expected to increase by 35 percent over the same time period.” (Schwartzman and Springer, 2002).
5) The DEIS does not acknowledge that any groundwater recharge from snowmaking to the regional aquifer is unlikely to contribute to Flagstaff’s water supply. According to Schwartzman and Springer, “Because of the distance between Snowbowl and the City of Flagstaff’s production wells, additional recharge at Snowbowl would likely provide little increase in groundwater availability to the City.”

In the Soils and Geology section the DEIS states that the proposed action will result in substantial impacts to soils (pg 3-231).

“While the sediment detachment quantities predicted … are measures of potential detachment, and not actual sediment yield or delivery, the anticipated increase in post-implementation detachment of 483 tons is substantial. After re-vegetation, even with de-commissioning of a portion of the existing mountain access road reducing detachment by approximately 14 tons per year, the total increase in detachment is anticipated to be almost 180 tons. … Furthermore, five of the six affected soils mapping units have erosion hazards rated as “Severe,” while revegetation potential is rated as Low to Moderate.”

In the same section, under irreversible and irretrievable commitments of resources (Page 3-254), the DEIS states that: “Because pedogenesis (development or generation of new soils) is a process that occurs over the course of decades and centuries, the effects of soils compaction, loss of organic matter and tilth, and soils loss via increased detachment and transport may be considered an irreversible commitment of resources.”

Yet the issues concerning soils and geology are described by the DEIS as “tracking” rather than significant issues.

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 hydrologic report, go to www.flagstaffactivist.org and www.savethepeaks.org.

email: coalition@savethepeaks.org

Click here to view the Hydrologic Report

Elements of the Proposal

How to Comment on the DEIS