EPA Weighs in Against Full Expansion at Mt.
Ashland Ski Area
On November 4, 2003 the US Environmental
Protection Agency (EPA) submitted its formal comments on the Mt.
Ashland Ski Area Expansion Draft Environmental Impact Statement (DEIS).
The DEIS is the guiding document outlining how, when, and, if a ski
area expansion will take place.
The EPA does not support Ski Ashland's
proposed expansion (Alternative 2 in the DEIS) or the US Forest
Service's slightly modified "preferred alternative" (Alternative 6).
The EPA is concerned that ski area expansion will result in
increased erosion in the Ashland watershed, negatively impact both
Ashland and Cottonwood Creeks, reduce water supply in critical
summer months, and risk violating provisions of the Northwest Forest
Plan.
The EPA continues in their letter to recommend a
smaller-scale expansion that does not cross the pristine Middle
Branch watershed. In effect, they have endorsed the
Community
Alternative put forth by local skiers and snowboarders as an
environmentally sustainable expansion.
Read the full text of the EPA's comments below or
download this letter in an easy-to-read (or print)
PDF file (requires Adobe Acrobat Reader - free
download).
Full text of the US EPA's official comments on
Mt. Ashland Ski Area Expansion DEIS
Cover Letter
November 4, 2003
 Reply To
Attn Of: ECO-088 99-078-AFS
John Schuyler, Acting District Ranger
Ashland Ranger District
United States Forest Service
Rogue River National Forest
645 Washington Street
Ashland OR 97520
Dear Mr. Schuyler:
We have reviewed the draft Environmental Impact Statement (EIS) for
the Mt. Ashland Ski Area Expansion, (CEQ Number: 030337) in Ashland
and Scott River Ranger Districts, Rogue River National Forests in
Southwestern Oregon. We have conducted this review in accordance
with our responsibilities under the National Environmental Policy
Act (NEPA) and Section 309 of the Clean Air Act.
The draft EIS examines five action alternatives and the no-action
alternative. Alternative 1, the no-action alternative, would
continue operation of the existing ski area facility and continue
with existing management activities. Alternative 2, the proposed
action, would include development of new ski areas including ski
lifts and runs on the east and west sides of the Middle Fork of the
East Fork of Ashland Creek (the Middle Fork), west of the current
ski area, widening of existing runs, development of a tubing
facility, several guest service buildings, lighting, a number of
infrastructure improvements, and expansion of the existing parking
lot. Alternative 3 is similar to Alternative 2 but avoids locating
ski runs and lifts on the west side of the Middle Fork. Alternative
4 places the expansion area about a half-mile to the east of the
existing ski areas at a location referred to in the EIS as "The
Knoll." Alternative 5 adds additional ski terrain and lifts mostly
within the present ski area "footprint." Alternative 6 is very
similar to the proposed action, but it reduces ski facility
development in the Middle Fork. Alternative 6 is identified as the
US Forest Service's preferred alternative in the EIS.
We commend the Forest Service for responding to public comment by
making substantial changes in the proposed action since the original
draft EIS was published in February 2000. We have rated the
preferred alternative in the EIS, EC - 2 (Environmental Concerns -
Insufficient Information). Our major concerns are that the Ski Area
expansion may increase erosion in the highly erosive soils of the
expansion area, causing water quality effects downstream in
Cottonwood and Ashland Creek, the latter of which is the City of
Ashland's water supply; the addition of impervious surface for
parking could degrade water quality in Cottonwood and Ashland Creek;
and ski area construction may adversely affect the flow regime and
wetlands in upper Ashland Creek during low flow situations in the
drought season. In addition, we are concerned that watershed scale
effects to riparian reserves cannot be ruled out, which would put
some Northwest Forest Plan (NWFP) Aquatic Conservation Strategy
objectives at risk of not being met.
Accordingly, we believe that the most environmentally preferable
development alternative would be Alternative 3, or some similar
project design that limits constructing ski lifts and runs to the
east side of the East Fork of the East Branch of Ashland Creek, and
reduces the effects to all of these resources over the entire
project site. We concur with the Forest Service that Alternative 6
is environmentally preferable to Alternative 2.
This rating and a summary of our comments will be published in the
Federal Register. A copy of the rating system used in conducting our
review is enclosed for your reference. Thank you for the opportunity
to review this draft EIS. If you would like to discuss this letter,
please contact
Jonathan Freedman at (206) 553-0266.
Sincerely,
Judith Leckrone Lee, Manager
Geographic Unit
Main Letter Text
98-078-AFS
DEIS MOUNT ASHLAND SKI AREA EXPANSION DEIS COMMENT LETTER
11/4/03
EPA's Detailed Comments on the Mt. Ashland Ski Area Expansion
Purpose and Need
The purpose and need discussion has been greatly
expanded from the previous draft to specifically analyze each
separate goal the project is attempting to achieve and describe how
the EIS developed each alternative to respond to the mix of needs
presented. The EIS also more fully discusses the question of skier
demand in local, regional and national contexts. We generally concur
with Purposes 1-5, and strongly support Purpose 6: Maintain and
Improve Trend of Watershed Recovery.
Alternatives
The EIS has taken a thorough look at
alternatives, including the addition of Alternative 4, which
examined expansion in the Knoll area, and the addition of
Alternatives 3, 5, and 6, which respond to environmental
considerations that were added to project goals since preparation of
the original EIS. We commend the Forest Service for being responsive
to public input and making major improvements in the analysis of
alternatives in order to minimize environmental impacts.
We have a strong preference for Alternative 3.
Based on information presented in the EIS, we conclude that in the
critical area of effects to aquatic resources, including water
quality, instream flows, erosion and sedimentation, Alternative 3
would entail less risk of environmental damage in Ashland Creek
basin than with either Alternative 2 or Alternative 6. This is
because ski lifts and ski runs would be confined to the east side of
the critical upper portion of the East Fork drainage. In addition,
Alternative 3 limits both direct and indirect impacts to the
McDonald's Peak Roadless Area and avoids direct impacts to the
regionally rare Engelmann spruce grove. According to the information
in the EIS, Alternative 3 accomplishes most of the terrain balance
and diversity purposes as well or almost as well as Alternatives 2
and 6 and does so at less economic risk than the latter two.
According to information in Chapter 2, the substantive difference
between Alternatives 2, 3 and 6 is that the first two create about
25% more novice terrain and 20% more intermediate terrain than
Alternative 3. In Appendix I of the EIS, the financial feasibility
analysis states that "the performance
of 2, 3, and 6 is reasonably similar." It also states that
Alternative 3, unlike the other alternatives, yields a favorable
economic result under low, medium, and high visitor scenario trends.
This figure is attributed to lower capitalization costs, and because
less capital is put at risk. We recommend that the Forest Service
select Alternative 3, or a version of it that confines development
to the east side of the East Fork drainage.
Water Quality and Impervious Surfaces
EPA has concerns about potential project effects
on water quality in Ashland and Cottonwood Creeks. Ashland Creek
discharges into Reeder Reservoir, the source of water supply for the
City of Ashland. Reeder Reservoir is a Clean Water Act Section
303(d) listed water quality limited water body for sedimentation.
Upper Ashland Creek is considered impaired and may be listed as
impaired on the 303(d) list for high temperatures. There is little
data on Cottonwood Creek, although it is a tributary to the Klamath
River, which is classified as an impaired stream.
We are concerned about the addition of impervious surface for the
expansion of parking at the Mt. Ashland Ski Area. Construction could
increase sediment delivery to the headwaters of Cottonwood Creek,
while use of the parking lot and operation of could increase the
discharge of contaminants and sediment from parking lot runoff and
road sanding. Maintenance of ski runs with motorized equipment in
closer proximity to surface waters than before could cause an
increase in the discharge of contaminants, particularly in Ashland
Creek. The EIS should include specific estimates of increases in
contaminant loading, and about the proposed treatment and control of
pollutants from the new impervious surfaces and ski runs. This may
include the location, size and type of oil / water separators,
stormwater ponds, water quality swales or settling ponds and
proposed operation and maintenance of these facilities. We are also
concerned about the predicted lack of effects of vegetation and land
clearing on stream temperatures in the project area. The EIS should
provide some justification to support the conclusion that no changes
to stream water temperatures would occur.
Instream Flows
EPA has concerns about potential project effects
on surface water flow in Ashland Creek, which as noted above,
discharges into Reeder Reservoir, the source of water supply for the
City of Ashland. Ski area expansion may cause a change in the flow
regime in creeks draining the project area, particularly Ashland
Creek. All action alternatives include the addition of impervious
surface, and disturbance associated with vegetation and land
clearing associated with the Ski Area expansion such as construction
of ski runs and lifts on steep slopes with unstable soils. These
activities can change the periodicity of surface runoff, increase
creek flows during "rain on snow" storm events, and increase the
potential for erosion.
Expanding the Ski Area on Ashland Creek may also reduce groundwater
storage near the surface, resulting in the decrease of low flow
surface water during the drought season, which may cause impacts to
special aquatic sites, increases in water temperature, water quality
impacts and a reduction in water availability downstream. Members of
the Ashland community have reported observations of substantial
surface flow in the Middle Fork and well hydrated vegetation in the
immediate vicinity of the creek in August 2003 in contrast to much
lower flows and vegetation conditions outside the riparian area
(Headwaters Group October 2003). This suggests that the substrate of
the Middle Fork drainage within the project area may be acting as a
significant groundwater recharge or discharge area throughout the
summer. If so, there could be a risk that construction of ski lifts
and ski runs could disrupt this function, potentially lowering
drought season flows in the Middle Fork and removing
hydrology from vegetation communities in the Special Use Permit
area.
The EIS needs to present more information on current surface flows
in the Middle Fork. The figures which appear on III-63 do not
present a complete picture of existing flow conditions in the Middle
Fork. There is also little specific information in the EIS regarding
soils or substrate in this part of the project area that could
explain either increased groundwater storage capacity and discharge
or these surface flows. Given the potential impacts to surface flow,
the EIS should clarify where the data has been collected, and what
the period of record is so it is possible to determine how much
water might be discharged from the project area from the Middle
Fork. Based on the information presented and the customized stream
flow model, discussed again in Chapter IV on Page IV-71, the EIS
predicts very minor increases in flow in both Ashland Creek, but
does not discuss in sufficient detail how the conclusions were
derived. The EIS should describe the use and application of the
stream flow model, and support the results with additional
explanation. Without such explanation, it
is difficult for EPA to determine what the indirect effects to the
flow regime might be, and what referred effects might occur to
vegetation communities such as project area wetlands in the Middle
Fork. The EIS and the Record of Decision (ROD) should commit to
monitoring surface flows in Ashland Creek during and after
construction for any effects to surface flows, and if any effects
are found, should also commit to performing mitigation measures to
either minimize or compensate for the effects.
Soil Erosion
The potential for soil erosion is a major concern
for this proposed project. The EIS acknowledges that many soils at
the Ski Area have granitic origins which have a higher potential for
surface erosion and failure because of steep slopes, often
unconsolidated material and coarse grain size. Disturbed areas such
as road cuts in the vicinity of the project site show large
quantities of unconsolidated granite being moved downslope.
Construction would
consist of removing vegetation and topsoil and disturbing soil
cover, all of which could greatly increase erosion. The EIS, on
Pages II-13, and Map III-3, shows that some construction areas in
riparian zones in the Ashland Creek watershed have substrate
classified as having high potential risk for both sediment delivery
and landslides.
On Page III-19, the EIS states that the Forest Service used the
Water Erosion Prediction Project (WEPP) model for predicting runoff,
choosing "Disturbed WEPP" to characterize the possible effects of
constructing the proposed ski area expansion. Disturbed WEPP is
described by those who developed it as suitable for sites with
little soil disturbance but a definable amount of soil residue
cover. Disturbed WEPP is not intended for sites "where soil is
severely disturbed or compacted, such as roads and trails (or)
construction
sites" such as the Ski Area (Draft Disturbed WEPP / WEPP Interface
for Disturbed Forest and Range, Runoff, Erosion and Sediment
Delivery, USDA Forest Service, 2/00). The types of disturbance model
users can select are typified by a 5-year-old forest, a heavily
logged site, a forest one to two years after a prescribed fire, or a
forest two to three years after a wildfire, which do not appear to
match up well to site conditions at the Ski Area during
construction.
In addition, the EIS states that measured rates of soil erosion to
granitic soils have been extrapolated from Idaho, and these rates
have been compared to the results of sediment monitoring at Mount
Ashland from the 1970s and 1980s. While we acknowledge that these
estimates use the best existing information, we would have more
confidence in them if 1) we could be certain that the WEPP model was
appropriate for the site conditions and 2) if the results had been
compared to measured recent erosion rates from the project site.
Additionally, it may not be correct to compare roads to rills on the
construction site (III-26). The results of the Montgomery report
(1977) described in the EIS are an indication of how important
assumptions about erosion rates for different land use types can
influence the results of any model. The EIS should therefore use
more recent soil erosion data from the project site to derive
predicted erosion rates.
The EIS states that erosion will more than double in the Ashland
Creek basin under all alternatives aside from alternatives 1 and 5.
The EIS should better explain why alternative 3 is predicted to have
equal erosion to Alternative 2 and greater erosion than alternative
6 when these latter alternatives would require more grading and
construction over a larger area. The restoration projects only
account for a decrease of 5 cubic yards of sediment erosion in
Ashland Creek and .2 cubic yards in Cottonwood Creek. The EIS should
also better explain how estimated annual sediment delivery to
streams
was derived, and include more complete descriptions of ongoing
monitoring efforts designed to predict the amount of erosion that
might be expected from construction. In addition, the EIS should
include a more complete description of the size, location, and plans
for operation and maintenance of sediment ponds.
The historical data the EIS displays about the effects of the
original ski area construction (Page III-33) shows a large "pulse"
of erosion in the years following the original development. The
estimates were based on aerial photo interpretation, not actual
systemwide data collection. The analysis attributes most of this to
the construction of new roads, which should not occur on as large a
scale for the expansion. Chapter IV of the EIS should discuss
whether some risk remains for such an erosion pulse to occur, given
project
site substrate and soils, the relative size of the new work, and the
lack of ground-truthed data from the critical initial
post-construction years. Some conclusions may be drawn from the
historical experience with erosion control measures at the Ski Area
as presented in Chapter III and Appendix E.
Parking
The Forest Service has stated in informal
communications with this office that there are parking shortages on
approximately 12-14 days per year, usually when there has been
recent snow and the weather is clear. The EIS states that the
existing lot is narrow and difficult to maneuver in when full.
Vehicles are often parked on the County Road leading to the Mt.
Ashland Ski Area during busy weekends and holidays, causing safety
concerns.
In conversations with Forest Service staff in July 2002, we
expressed concerns about the addition of impervious surface for
expanded parking and requested that the Forest Service consider
alternatives such as expanded shuttle service that focus on getting
more users to the ski area, not necessarily more cars. The Forest
Service should consider directing the Mount Ashland Association (MAA)
to develop a bus shuttle service that would operate from the
junction of the Ski Area access road with Interstate 5 to minimize
creation of new impervious surfaces for parking. Such a shuttle
service would transport skiers to and from the ski area on busy
weekend days when the parking lot is full. Members of the local
community have informed our office that there is State of Oregon
land (Department of Transportation) and private land that may be
available for vehicle parking. It may be possible for MAA to
consider a pricing scheme that encourages ski area users to car pool
by charging fees (or higher fees) to autos with less than 3 persons
for parking at the ski area. This could provide additional income
for MAA and incentive for ski area users to car pool or use the
shuttle service from the base of the County Road. While we
acknowledge that the EIS describes that MAA has incurred a cost for
sponsoring a shuttle service from the City of Ashland, we would
strongly encourage the Forest Service to fully consider such an
option in the EIS. The use of pricing incentives at the ski area,
along with providing free parking along the Interstate 5 turnoff
could help minimize the costs to MAA and most importantly, to
minimize the creation of impervious surface at the Ski Area.
If this option proves unworkable, we would recommend moving the new
parking area to the Alternative 4 location at the Knoll, where the
risk of stream sedimentation and contamination may be less than at
the proposed site for all of the other Alternatives. The Knoll is
characterized in the EIS as an area with more stable slopes, at much
greater distance from areas mapped as Hazard Zones 1-2 (although the
EIS does not predict a reduction of sediment delivery to Neil Creek
compared to Alternative 2). The Knoll may also be a site where
treatment of runoff may be easier to manage. This option would still
require operation of a shuttle to take ski area users the short
distance to the ski area on busy weekends. However, it would reduce
or eliminate the present hazardous situation, where drivers
searching for spaces share a highly confined paved area with
pedestrians, it could minimize the release of contaminants to
surface waters.
Wetlands
The EIS states that Upper Ashland Creek within
the project study area contains about 28.4 acres of wetlands, or
about 2.6% of the project survey area (based on National Wetland
Inventory data). There are 187.13 acres of wetlands in the entire
Upper Ashland Creek watershed, about 1.4% of that survey area. Based
on this data, the study area contains about 6.5% of the wetlands
within the Upper Ashland Creek basin. Wetlands in the project area
are presently almost all undisturbed and functioning normally.
Direct effects to
wetlands are forecast to be small under all of the alternatives (as
high as .54 and .83 acres for alternatives 2 and 6 respectively).
However, the listed indirect effects of Alternatives 2 and 6 are
greater (7.33 and 8.36 acres respectively). The predicted effects
under Alternative 3 are less than for Alternatives 2 and 6. Affected
wetlands include high value forested wetlands supporting alder,
regionally rare Engelmann spruce and montane meadows.
The Specific Watershed Effects Section starting on Page IV-74
discusses the effects from the construction of ski runs and ski
lifts, including land clearing, contouring, excavation, filling and
addition of impervious surface on various aquatic functions in
wetlands and riparian areas, but concludes that implementation of
the proposed Best Management Practices (BMPs) would minimize
effects. It is somewhat difficult for reviewers to evaluate whether
the proposed BMPs are sufficient to bring effects to a minimal level
until it can be seen
how BMPs are applied and perform in a specific location. The EIS and
the ROD should include a commitment to monitor affected wetlands to
verify whether BMPs are proving successful, and if not, employ
contingency measures to ensure that effects are kept to the
predicted minimal level.
Mitigation, Restoration Measures, Best
Management Practices (BMPs) and Monitoring
Proposed mitigation measures, proposed BMPs and
monitoring appear in Chapter II and in the resource impact analysis
Sections of Chapter IV. The list of watershed restoration projects
listed in Chapter II is detailed. Proposed mitigation, BMPs and
monitoring discussions are distributed throughout Chapter IV and
sometimes described in general terms (see above Section). However,
it is difficult to evaluate how much compensation for lost natural
resource functions may be predicted from implementation of these
projects, and difficult to tell what impacts the projects are
intended to compensate for, if done as mitigation. The Forest
Service should create a separate Section in Chapter IV, or a Section
in the ROD summarizing mitigation, restoration, BMPs and monitoring
projects, with a description of the intended compensation for
specific impacts, as appropriate.
Implementation of the Northwest Forest Plan
Aquatic Conservation Strategy
The Northwest Forest Plan's (NWFP) Aquatic
Conservation Strategy (ACS) includes four primary components,
riparian reserves, key watersheds, watershed analysis, and watershed
restoration, and nine objectives. Since the proposed action takes
place on lands within the NWFP area, the EIS must discuss whether
the action is consistent with the primary components and NWFP
Standards and Guidelines for the ACS. The EIS has broken out this
analysis by watershed.
The Standards and Guidelines for Riparian Reserves state that
intermittent streams, if in unconsolidated material or granite,
should include buffers ranging from 75 to over 200' depending on the
slope class (See graph entitled Ecological Protection Width Needs on
Page B-15 of the NWFP ROD). The EIS should state whether these
guidelines were used to establish final riparian area boundaries.
The NWFP Standards and Guidelines for Recreation Management under
Riparian Reserves specify that new recreational facilities within
riparian reserves should be designed so as not to prevent meeting
ACS objectives, and that existing developed recreation practices
that retard or prevent attainment of ACS objectives should be
adjusted or eliminated.
The EIS should describe how the proposed expansion and continued
operation of the Ski Area will not preclude or retard meeting ACS
objectives. The EIS shows that the Ski Area expansion will encroach
on riparian reserves in the project area, particularly in Ashland
Creek. The document also states that site scale effects to the ACS
objectives of landscape features, watershed connectivity, physical
integrity of aquatic systems, water quantity, floodplain inundation
regime and plant community structure and function would be degraded.
The analysis presumes the effectiveness of proposed BMPs and
restoration measures to determine that the ACS objectives of water
quality and sediment regime would be maintained. The EIS should
explain in more detail how the proposed BMPs would accomplish this.
The EIS further concludes that the project would maintain ACS
objectives at the watershed scale. The EIS presumes the
effectiveness of proposed BMPs and restoration measures to determine
that objectives are maintained at the watershed scale, and also
relies upon the relative small size of the affected site in
comparison to the watershed to arrive at this effect determination.
The ACS Strategy Objectives of water quality, sediment and water
quantity impacts on the Middle Fork of the East Branch of Ashland
Creek may not be confined to the site but could extend a
considerable distance downstream. However, the analysis states that
effects would not be measurable at the watershed scale. The
information presented in the EIS is not sufficient to support these
conclusions. The EIS should describe in more detail how the Forest
Service arrived at the watershed effect determinations of "maintain"
for these three ACS objectives.
Cumulative Watershed Effects
The EIS states that the cumulative watershed effects, with the
exception of the Upper Ashland Creek watershed, are minimal due to
the small amount of affected area within the other watersheds. Table
IV-22 uses a Forest Service model called the Equivalent Roadless
Area (ERA) which considers the percentage of roaded area, develops a
Threshold of Concern based on a number of hydrologic and substrate
characteristics such as slope stability and channel sensitivity to
derive a Watershed Sensitivity Level risk ratio for project area
watersheds in the analysis area, and finally a risk ratio. We
recommend that the EIS explain the data in Table IV-22 a little more
fully. Neither the past impacts on the affected watersheds, the
present conditions nor the assumptions of future activity that the
model used are discussed in any detail. Also, the final risk ratio
numbers are somewhat difficult to interpret. Ratios for upper Neil
Creek are at approximately 0.940, compared to much lower ratios for
the other watersheds. The EIS should explain the sensitivity of
these numbers to changing resource conditions in the ERA model. What
and how much restoration activity or negative impact would cause the
risk ratios to move significantly? How significant is the difference
between a ratio of 0.268 and 0.939, or 0.939 and the stated yellow
flag threshold of 1.0? Some of this information may be explained in
Appendix E, but a summary discussion should appear in the main
document to assist reviewers in interpreting the results.
-
Jonathan Freedman (206) 553-0266
USEPA, Region 10
Geographic Implementation Unit
1200 Sixth Avenue, ECO - 088
Seattle WA 98101
FAX: (206) 553-6984
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