Stop Grand Targhee's 694-acre expansion into Teton wildlands

Issues on the record, awaiting the decision

• PendingThe FEIS acknowledges a parking deficit of 927 spaces under the Proposed Action on days when visitation reaches the new CCC of 6,170 guests, yet defers the entire solution to a privately approved coun

  The FEIS acknowledges a parking deficit of 927 spaces under the Proposed Action on days when visitation reaches the new CCC of 6,170 guests, yet defers the entire solution to a privately approved county plan, the PUD-PR, that the Forest Service explicitly states it has no authority over and that may never be built. Section 3.5.3 shows 2,382 vehicles seeking to park against only 1,455 available spaces, a shortfall the agency calls "well-balanced" only under a cumulative scenario that assumes full build-out of 450 private lodging units and a mandatory transit program the Forest Service cannot enforce. This is circular reasoning: the agency approves a federal action that creates a large parking deficit, then relies on a private county-approved development to fix it. The Forest Service should analyze the traffic and parking impacts of the Proposed Action independently of the PUD-PR build-out, disclose the impacts if the PUD-PR is not built, and identify enforceable mitigation measures within its own authority before approving any SUP expansion.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS projects that under the Proposed Action, WY-22 over Teton Pass reaches Level of Service F on summer busy days and LOS D/E on winter CCC days, yet the document attributes virtually all of that

  The FEIS projects that under the Proposed Action, WY-22 over Teton Pass reaches Level of Service F on summer busy days and LOS D/E on winter CCC days, yet the document attributes virtually all of that degradation to background growth and treats the resort's incremental contribution as minor. Table 3.5-8 shows that the Proposed Action adds 440 vehicles to WY-22 on a winter CCC day beyond the No-Action forecast, pushing the road further into a failing condition the agency already acknowledges exists. The document provides no mitigation for WY-22 and no coordination with WYDOT or Teton County, Wyoming to address a road that already operates at near-failure. The Forest Service should quantify the resort's proportional contribution to WY-22 degradation, consult with WYDOT about mitigation requirements, and condition SUP approval on a binding transportation demand management plan that does not rely solely on the PUD-PR.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS documents that affordable housing is already severely strained in the study area, with up to 70 percent of renters in Madison County cost-burdened, yet the agency's only mitigation is to note

  The FEIS documents that affordable housing is already severely strained in the study area, with up to 70 percent of renters in Madison County cost-burdened, yet the agency's only mitigation is to note that GTR is required by the PUD-PR to provide some employee housing and that new FTEs might fall within baseline growth projections. Section 3.4.3 acknowledges workers are turning down job offers due to housing costs and that the School District, Fire Protection District, and Teton Valley Health are struggling to fill positions. The document then projects up to 614 new FTEs under the Proposed Action with no enforceable Forest Service requirement for GTR to provide commensurate housing beyond what is already required on private land by Teton County. The agency should either require binding employee housing commitments as a SUP condition proportional to each alternative's FTE increase, or disclose why it lacks authority to do so and explain how the public interest is served without such a requirement.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS eliminates from detailed analysis a 'no capacity increase' alternative on the grounds that it would not meet the purpose and need, but the purpose and need is defined entirely by GTR's busine

  The FEIS eliminates from detailed analysis a 'no capacity increase' alternative on the grounds that it would not meet the purpose and need, but the purpose and need is defined entirely by GTR's business objectives: remaining viable in the competitive destination skier market. Section 1.3 states the agency's role is to decide whether the project is in the public interest, yet the purpose and need never independently evaluates public interest in limiting resort growth given the documented housing, traffic, and wildlife impacts. Dismissing a capacity-limited alternative without analyzing whether unconstrained capacity growth is itself in the public interest is an unreasoned gap. The agency should either analyze a limited-capacity alternative that addresses existing SUP deficiencies without SUP expansion, or provide a reasoned explanation grounded in public-interest findings rather than the applicant's market position.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS acknowledges that the South Bowl area is currently experiencing high backcountry use, that the Colter Lift has increased access, and that incorporating South Bowl into the SUP will eliminate

  The FEIS acknowledges that the South Bowl area is currently experiencing high backcountry use, that the Colter Lift has increased access, and that incorporating South Bowl into the SUP will eliminate 266 acres of backcountry terrain for non-resort recreationists and may displace those users to Teton Canyon and South Leigh Canyon. Yet the recreation section contains no quantitative analysis of impacts to the outfitter and guide SUP holders who operate in the affected area, stating only that they 'may need to have their operational areas relocated.' Section 3.1.4 identifies named outfitter organizations operating in Teton Canyon but provides no analysis of economic or operational impacts to their existing federal permits. The agency should analyze direct impacts to existing outfitter and guide SUP holders whose operating areas overlap or adjoin the proposed South Bowl expansion and disclose whether those permits would be curtailed or relocated.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS states that climate change projections show declining snow water equivalent and shortened snow residence time in the Intermountain Region under RCP 8.5, and acknowledges that south-facing slo

  The FEIS states that climate change projections show declining snow water equivalent and shortened snow residence time in the Intermountain Region under RCP 8.5, and acknowledges that south-facing slopes at lower elevations face greater operational difficulty, yet the South Bowl expansion is on a south-facing aspect. Section 3.11 discloses these climate trends but the recreation and purpose-and-need sections never reconcile the long-term viability of investing in a south-facing SUP expansion given those very projections. The agency grants a potentially irreversible 266-acre Forest Plan amendment based on a business case that its own climate analysis undermines. The agency should directly analyze the expected operational lifespan and return on environmental cost of the South Bowl lift and terrain under the climate scenarios it discloses, and explain how long-term public benefit is served by a south-facing expansion that its own data suggests may have diminished utility within the permit period.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS discloses that under the Proposed Action, hydrologic disturbance will increase in Targhee Principal Watersheds and HUC6 subwatersheds, and that the 1997 Forest Plan guideline states not more

  The FEIS discloses that under the Proposed Action, hydrologic disturbance will increase in Targhee Principal Watersheds and HUC6 subwatersheds, and that the 1997 Forest Plan guideline states not more than 30 percent of any principal watershed should be in a hydrologically disturbed condition at any one time. Tables 3.15-5 through 3.15-8 provide the project-generated and combined HD estimates, but the document does not state explicitly whether any TPW or HUC6 subwatershed exceeds or approaches the 30 percent threshold after project implementation. The agency cites the standard, presents the numbers, but never draws a clear compliance conclusion. Downstream water users and the public cannot determine from the FEIS whether the 30 percent standard is met. The agency should provide an explicit finding for each TPW and HUC6 subwatershed stating whether the combined HD under each alternative meets or exceeds the Forest Plan's 30 percent threshold, and if any threshold is approached or exceeded, explain the basis for approving the action.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS acknowledges that dye tracer tests have not yet been completed for Rick's Basin, South Bowl, and the Papoose Creek Watershed to determine connection to downstream public water systems, yet pr

  The FEIS acknowledges that dye tracer tests have not yet been completed for Rick's Basin, South Bowl, and the Papoose Creek Watershed to determine connection to downstream public water systems, yet project design criteria Table 2.4-1 lists that dye tracer test completion is required only prior to construction, not prior to the NEPA decision. The agency therefore cannot fully disclose potential impacts to downstream public water systems before approving the action. Section 2.4 and Section 3.15 both acknowledge this gap. Approving ground disturbance near karst topography without knowing whether those disturbance areas are hydrologically connected to public water supplies is a significant analytical gap. The agency should complete the dye tracer tests and incorporate their results into the FEIS before issuing a Record of Decision, or at minimum explain why deferring this analysis to a pre-construction PDC is legally sufficient under NEPA.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS proposes Forest Plan amendments to remove 125 acres of Aquatic Influence Zone designation from lands that would be converted to Management Prescription 4.2 in the Mono Trees expansion, yet it

  The FEIS proposes Forest Plan amendments to remove 125 acres of Aquatic Influence Zone designation from lands that would be converted to Management Prescription 4.2 in the Mono Trees expansion, yet it does not analyze the baseline ecological functions those AIZ acres currently provide to downstream riparian and aquatic systems before concluding the conversion is acceptable. Section 1.9.1 describes the AIZ prescription as providing high-level aquatic protection including sediment transport, microclimate control, nutrient regulation, and connectivity. The document converts that protection by Forest Plan amendment without a site-specific analysis of the functional loss. The agency should conduct and disclose a site-specific functional assessment of the 125 AIZ acres proposed for conversion under each action alternative before amending the Forest Plan, quantifying the loss of aquatic protection functions and any proposed compensatory measures.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe FEIS estimates impacts to whitebark pine, a species the document identifies as a Forest Service sensitive species facing climate-driven decline, under the Proposed Action across multiple tables in

  The FEIS estimates impacts to whitebark pine, a species the document identifies as a Forest Service sensitive species facing climate-driven decline, under the Proposed Action across multiple tables in Section 3.12. Tables 3.12-5 through 3.12-8 disclose acres disturbed and estimated WBP individuals impacted, yet the document relies on density estimates described as uncertain and notes that specific volumes of cut timber cannot be specified. The primary mitigation is a requirement to obtain Whitebark Pine Friendly Ski Area Certification before implementation. The agency cannot verify that certification requirements will actually prevent loss of WBP viability when the baseline density data are acknowledged as imprecise and the certification standard is set by a non-governmental foundation rather than the Forest Service. The agency should require pre-construction WBP surveys with quantified tree-level impact estimates as a condition of any ROD, and establish an enforceable, measurable WBP population monitoring and mitigation standard within its own permit conditions rather than delegating that standard to a third-party certification program.

  A hole PLAN found in the agency’s own analysis, quote verified against the document