Telluride Ski Resort expansion nears final approval

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 EA states Canada lynx habitat will recover over time as vegetation regenerates, but simultaneously acknowledges that gladed areas 'would be maintained for skiing' and that 'maintenance of gladed terrain will be minimal and focused on hazard trees that pose a threat to public safety.' This creates a direct contradiction: if gladed areas are maintained open for recreation, young regenerating trees will be repeatedly removed, preventing the dense horizontal cover (DHC) recovery that the analysis relies upon. The document does not reconcile how habitat recovery and recreational maintenance can both occur, nor does it analyze what 'minimal maintenance' means in terms of acres or frequency of additional vegetation removal needed to keep areas ski-able as trees regenerate.
• The document eliminates from detailed analysis a Conservation Alternative that 'would not meet the purpose and need' because the Purpose and Need itself explicitly lists only the applicant's proposed projects as meeting the identified needs (pages 2-3, 16-17). This violates NEPA's requirement that the Purpose and Need not be so narrowly defined that only one action alternative can meet it. A reasonable conservation alternative should have been analyzed that would meet the underlying objectives (e.g., improve forest health, enhance beginner terrain) through means that minimize environmental impacts. The agency should either revise the Purpose and Need to be less applicant-driven or prepare an alternative analysis showing how different approaches could meet each identified purpose independently.
• The EA states that tethered logging 'eliminates the need for helicopter use and pile burning' (page 12) and that the cut-to-length approach reduces soil disturbance compared to conventional logging. Yet the document provides no quantitative comparison of soil impacts, erosion potential, or sediment yield between tethered logging and the ground-based or helicopter alternatives previously approved under SBEADMR. The 2022 SBEADMR Checklist update permitting tethered logging on slopes up to 60 percent is cited only briefly, but the agency has not fully analyzed whether tethered logging actually reduces impacts or merely redistributes them across steeper terrain previously excluded. The agency should provide a detailed comparison of soil impacts, erosion control effectiveness, and long-term soil productivity outcomes between the three logging methodologies.
• The document claims effects to recreational use at TSR are anticipated to be beneficial with no measurable increase in overall visitation (page 27), yet the Purpose and Need states the action is needed to 'address existing lift and operational challenges...expand recreational opportunities on the GMUG' (pages 7). If the projects successfully expand terrain and improve lift capacity, visitation should be expected to increase or at minimum visitor satisfaction and use patterns should shift. The EA does not analyze how increased capacity, new beginner terrain, additional dining, and improved skier circulation would interact to change visitor behavior, length of stay, or total mountain visitation. This indirect effect should be disclosed and analyzed for impacts to parking, congestion, cumulative recreation impacts, and wildlife displacement.