Stop Waterville Valley Resort from expanding into White Mountain National Forest
Waterville Valley Resort Proposed Expansion
U.S. Forest Service· White Mountain National ForestU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
3 groups work Maine
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Appalachian Mountain Club
Works Maine: has permanently conserved nearly 130,000 acres of the Maine North Woods in the 100-Mile Wilderness south of Katahdin through its Maine Woods Initiative since 2003..
- Friends of Acadia
Works Maine: they work only in Maine.
- National Parks Conservation Association
Works Maine: defended the monument in the 2017 Antiquities Act review, opposed a proposed mine near the monument in 2023, and backs the bipartisan Katahdin Woods and Waters Access Act to expand the park..
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
A ski resort wants to grow its footprint on public forest land, requiring changes to the governing forest plan.
What’s at risk
White Mountain National Forest land is at risk of permanent development to serve a private ski resort. The expansion would require amending the Forest Plan, which sets the rules protecting this public land.
If this goes through
If approved, the resort gains an expanded special use permit and new development on public land, with Forest Plan amendments that could be difficult to reverse.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
9 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The DEIS's forestry section explicitly finds that development in Canada lynx habitat within the LAU is prohibited by Forest Plan Standard S-3, and that the standard 'cannot be made compliant.' Rather than redesigning the project to avoid habitat impacts, the agency's response is to amend away the standard that prevents the project, using the project itself as the amendment's justification. The agency should explain why removing the regulatory protection is preferable to reducing project scope in lynx habitat, and should analyze a genuine avoidance alternative for the highest-quality lynx denning/foraging areas rather than relying on a standard-erasing amendment.
- The document lists at least six other Forest Plan riparian, wetland, and floodplain standards and guidelines that the action alternatives are inconsistent with (G-1, G-2, G-5, G-8, G-10, G-11 for riparian/aquatic habitats, plus wetland guidelines G-2, G-4, G-5, and transportation guideline G-2), all justified by 'engineering and terrain limitations' rather than by demonstrating no feasible alternative siting exists. The agency should provide a rigorous alternatives analysis showing why each specific infrastructure element (access road, lift towers, mid-station) cannot be relocated to avoid these many wetland, vernal pool, and RMZ violations, rather than treating repeated non-compliance as an acceptable outcome.
- The DEIS acknowledges that lift tower and access road construction would directly impact two identified vernal pools and indirectly impact three more, in direct violation of Guideline G-11 which states vernal pools identified during planning 'should not be altered.' The document justifies this by saying the road and lift corridor are 'required to accommodate future maintenance and operations,' which is a conclusory assertion rather than a demonstration that no alternative route was feasible. The agency should analyze and disclose specific alternative routings that would avoid vernal pool impacts entirely.
- The Wildlife section discloses that the proposed action would degrade 71.1 of 92.3 acres (77%) of viable Canada lynx denning habitat and 20.8 of 32.2 acres (65%) of viable foraging habitat within the project footprint, yet the agency's ultimate determination is only that the action 'may affect but would not likely adversely affect' lynx. This determination appears inconsistent with the scale of habitat loss disclosed, especially given no lynx were observed in three years of surveys yet the LAU already exceeds the 30% unsuitable-habitat threshold. The agency should reconcile the
Show all 11 points from the document
- The Recreation section repeatedly emphasizes WVR's declining market share and visitation trends to justify the need for expansion, citing a 26% decline in WVR visitation since 2000 while national visitation rose 16%. However, the EIS never analyzes whether this decline is attributable to factors the proposed infrastructure would not fix (e.g., regional climate trends, competition, pricing) versus the terrain/access/service deficiencies claimed, and the 'Climate Science and Terrain Viability' issue was dismissed as too speculative even though it is directly relevant to whether the underlying purpose and need premise (that infrastructure improvements will reverse the decline) is sound. The agency should analyze the causal link between the identified deficiencies and the visitation decline before relying on it as the primary purpose and need justification.
- The Socioeconomics section states that if all 55 new FTEs relocate to Waterville Valley, this would represent an increase in town population by 10.5 percent, yet the analysis immediately hedges this away as unlikely without providing any actual estimate or methodology for how many employees will need housing versus commute, given the same report's own finding of a 0.3 percent county rental vacancy rate and severe existing employee housing shortage (WVR housing capacity of 60 already below its 75 full-time employees). The agency should require a specific workforce housing mitigation plan tied to the project rather than assuming the impact away.
- The Engineering and Traffic analysis relies on an assumption that 80 percent of guests would continue to arrive by car and that CCC-based estimates represent 'the high end of potential traffic volumes,' yet uses these same assumptions to calculate a parking surplus of only 52 spaces under increased CCC of 5,818 guests per day. Given the acknowledged uncertainty in shuttle-to-lift-system mode shift and the conservative nature of the AADT baseline data (which the report admits doesn't capture peak winter days), the thin 52-space margin could easily be erased, and the agency should conduct a sensitivity analysis on parking demand under less favorable but plausible assumptions rather than relying on a single point estimate with minimal surplus.
- The Hydrology section's WRENSS model is explicitly described as not simulating flood peaks or exceedance probabilities, yet the EIS uses its Q5% output as the primary basis for concluding that 'these effects are minor and localized and are not expected to result in measurable increases in flood risk.' This is a mismatch between the tool's stated capability and the conclusion drawn from it, especially given the same section acknowledges that rain-on-snow events combined with snowmaking-enhanced snowpack 'could increase due to the addition of snowmelt to storm runoff' and that high-flow events 'have been documented in the area.' The agency should conduct event-based flood modeling rather than relying solely on a tool acknowledged to be unsuited for that purpose.
- The Soils analysis states that field investigation identified 53 soil units compared to only 4 originally mapped units, a more than tenfold increase in mapped soil complexity, yet the disturbance and impact tables throughout the section appear to rely on the refined field data without any discussion of how this dramatic remapping might affect the reliability of erosion, compaction, and hydric soil impact estimates elsewhere in the document (e.g., in the Hydrology section's WRENSS modeling, which depends on baseline soil/vegetation inputs). The agency should clarify whether hydrology and other resource models were updated to reflect this substantially revised soil mapping.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Waterville Valley Resort proposes an expansion of their special use permit, Forest Plan amendments, and projects. A public open house will be held on July 15, 2026, at 6 pm at White Mountain National Forest Headquarters and virtually via Microsoft Teams. See the documents tab below for more details.
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