Stop Brian Head's 1,651-acre expansion until the water numbers add up
Brian Head Resort Expansion project
U.S. Forest Service· Dixie National Forest, Cedar City Ranger District, Brian Head Resort Special Use Permit areaU.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
4 groups predicted likely to care in Utah
Predicted likely to care is a guess from footprint in Utah, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Bears Ears Inter-Tribal Coalition
Predicted likely to care · a guess
Works Utah: the five-Tribe coalition that petitioned for the monument and shared in managing it until the July 2026 proclamation disbanded the Bears Ears Commission.
- Grand Staircase Escalante Partners
Predicted likely to care · a guess
Works Utah: the monument’s friends group: science, stewardship, and the legal fight over its boundaries.
- Southern Utah Wilderness Alliance
Predicted likely to care · a guess
Works Utah: sued BLM in August 2024 to void 51 reaffirmed oil and gas leases in the San Rafael Desert, including one in the heart of the Labyrinth Canyon Wilderness carved by the Green River.
- Utah Diné Bikéyah
Predicted likely to care · a guess
Works Utah: the Native-led nonprofit whose cultural mapping work built the original monument proposal.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service's draft EIS shows the proposed 1,651-acre, 14-lift Brian Head expansion would need about 103 more acre-feet of snowmaking water each year than its own dedicated water supply provides.
What’s at risk
The document's own biologists call the impact to the local American pika population 'significant' under every action alternative, while the goshawk population on the whole Forest sits at about 9 of the 40 breeding pairs the Forest Plan requires. The proposed action would also permanently or temporarily disturb 69 percent of the wetlands mapped in the project area, and a planned study of whether resort wells are connected to Cedar Breaks National Monument's springs was never completed because well access was not given.
If this goes through
Selecting Alternative 2 would expand the special use permit from 887 to 2,538 acres, add 14 new lifts and 359 acres of clear-cut, graded ski trails, and raise daily capacity from 4,330 to 9,710 guests. Construction is assumed to run through 2036, and the decision also amends the 1986 Forest Plan to convert over 1,100 acres to a winter-sports management designation for the life of the permit.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- SUP boundary expansion
- 887 acres today -> 2,538 acres (+1,651 acres)
- Daily resort carrying capacity
- 4,330 guests/day today -> 9,710 guests/day (Alt 2)
- New clear-cut ski trail acreage
- 359 acres of new graded, clear-cut ski trails
- Snowmaking water shortfall
- ~103.3 acre-feet/year short (Alternatives 2 & 3)
- Goshawk breeding pairs vs. Forest Plan minimum
- ~9 of 40 required breeding pairs forest-wide
- Pika habitat permanently destroyed
- 28 acres lost = 11% of mapped pika habitat
2.2.3
Open the document ↗“Increase the current 887-acre SUP by 1,651 acres, bringing the total SUP boundary to 2,538 acres.”
2.2.3
Open the document ↗“Increase BHR’s daily carrying capacity by 5,380 guests, bringing the total daily carrying capacity to 9,710 guests.”
2.2.3
Open the document ↗“Construct 359 acres of new ski trails, all of which would be clear-cut and graded smooth”
3.7.4
Open the document ↗“estimated snowmaking demand would exceed the dedicated snowmaking supply by approximately 103.3 AF annually”
3.6.3
Open the document ↗“The Forest Plan establishes a minimum viable population of 40 American goshawk breeding pairs for the DNF. The Forest has never met that minimum viable population and currently estimates approximately 9 breeding pairs on the Forest.”
3.6.4
Open the document ↗“approximately 28 acres of habitat would be permanently impacted by the proposed action, which accounts for 11 percent of the estimated 252 acres”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 1
- Holds up
- 5
- No support given
- 1
- Never analyzed
The Forest Service proposes to approve Brian Head Resort's plan to expand its special use permit area by 1,651 acres, to 2,538 acres, with 14 new lifts, up to 359 acres of new trails, new restaurants, snowmaking and roads. It would also amend the 1986 Forest Plan to manage that land as a winter sports site, citing Forest Plan direction to add downhill skiing capacity through private partners to meet growing demand.
“The Forest Plan identifies providing increased downhill skiing capacity and working with the private sector to help meet future recreation demand as a desired future condition for recreation on the DNF.”
1.3 Purpose and Need for Action
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Alternatives
No support given
Meeting growing recreation demand can't be done within the resort's existing permit boundary, so an in-footprint upgrade alternative wasn't analyzed.
The best support is Table 3.1-3, which shows 50,218 square feet of guest service space against a recommended 61,550 to 78,740, and the terrain gaps in Table 3.1-1. But the document never estimates how much capacity or guest space upgrades inside the current 887-acre permit could add, even though part of that permit lies outside the operating area. The dismissal is three sentences long.
AskAnalyze an alternative that upgrades lifts, terrain and guest facilities inside the existing 887-acre permit, with capacity and visitation figures, before rejecting it.
The agency’s words, the record and the law +Hide the words
The agency says
“Providing a guest experience that meets the expected growth in population in Utah and associated demand for outdoor recreation cannot be accomplished within BHR’s existing operational and SUP boundary.”
2.4.5 Expansion Within Existing Resort Footprint / Resort Infrastructure Upgrade Alternative
Elsewhere in the same document
“The portion of the resort on NFS lands operates under a special use permit (SUP) administered by the DNF that includes 887 acres, some of which fall outside BHR’s current operational boundary.”
1.2 Background
“As depicted in Table 3.1-3, BHR does not meet the recommended range for overall guest service space and falls below industry averages in most guest service functions, including ski school space, restaurant seating, ski patrol, and kitchen/scramble space.”
3.1.3 Affected Environment
The law
“a reasonable range of alternatives to the proposed agency action, including an analysis of any negative environmental impacts of not implementing the proposed agency action in the case of a no action alternative, that are technically and economically feasible, and meet the purpose and need of the proposal;” National Environmental Policy Act, 42 U.S.C. 4332(2)(C)(iii) ↗
Effects
No support given
At the resort's observed snowmaking rate, the identified water supply would cover the new snowmaking, and use won't exceed authorized quantities.
The agency's support is the 10-season observed average of about 1.0 acre-foot per acre, under which demand fits within the 393.3 acre-feet identified. Design criterion HS22 also bars snowmaking construction until water right changes are approved. But the hydrology section calls 1.0 the minimum expected ratio and reports values as high as 1.2 acre-feet per acre 40 percent of the time. At its chosen 1.3 rate, Table 3.7-3 shows a 103.3 acre-foot shortfall for Alternatives 2 and 3, and the supply letters behind the 393.3 acre-feet aren't binding.
AskBase water sufficiency on the 1.3 acre-feet per acre rate, name which snowmaking acres would be dropped in a shortfall, and require binding supply agreements before approval.
The agency’s words, the record and the law +Hide the words
The agency says
“When the observed average snowmaking application rate of approximately 1.0 AF/acre is applied, snowmaking demand would not exceed the identified dedicated snowmaking supply.”
3.7.4 Direct and Indirect Environmental Consequences, Alternative 3, Water Sufficiency
Elsewhere in the same document
“This would be the minimum expected ratio, as snow may not be made across all acres every year.”
3.7.3 Affected Environment, Existing Snowmaking
“The letters of intent are not legally binding water-supply agreements.”
3.7.3 Affected Environment, Water Rights
The law
“a detailed statement by the responsible official on- (i) reasonably foreseeable environmental effects of the proposed agency action; (ii) any reasonably foreseeable adverse environmental effects which cannot be avoided should the proposal be implemented;” National Environmental Policy Act, 42 U.S.C. 4332(2)(C) ↗
Effects
No support given
Goshawk habitat mitigation, still to be designed, will fully offset habitat loss, supporting the finding that goshawk viability won't be affected.
The agency cites no active nests found, pre-construction surveys, 30-acre nest buffers and Forest Plan Standard X. But the offset measures are only listed as things that may be done, with no acreage, ratio or location. Alternative 2 removes 117 acres of potential nesting habitat. The Forest already sits far below its minimum viable population.
AskDescribe the goshawk offset mitigation in the final environmental impact statement, including acres, ratio, location and timing, so its sufficiency can be reviewed before the decision.
The agency’s words, the record and the law +Hide the words
The agency says
“The final mitigation approach will be documented in the ROD and would be sufficient to offset the suitable goshawk habitat loss associated with the applicable project component.”
3.6.4 Direct and Indirect Environmental Consequences, Alternative 2, American Goshawk
Elsewhere in the same document
“The Forest Plan establishes a minimum viable population of 40 American goshawk breeding pairs for the DNF.”
3.6.3 Affected Environment, American Goshawk
“The Forest has never met that minimum viable population and currently estimates approximately 9 breeding pairs on the Forest.”
3.6.3 Affected Environment, American Goshawk
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
Show 2 more claims +Show fewer
Effects
No support given
Traffic impacts from expansion would be localized and manageable, with only two intersections showing winter deficiencies in 2042.
The agency relies on a full-buildout scenario of 13,250 guests, acceptable summer operations at all study intersections, and acceptable level of service in Parowan. It also points to feasible fixes for the two winter problem intersections. But the reported 2042 winter peak-hour totals of 639 and 1,248 vehicles equal the 2024 counts (209 and 408) plus project trips (430 and 840). That means they appear to leave out the background growth the method says was added. This text doesn't show intersection results with that growth included, so the 'localized and manageable' conclusion isn't demonstrated.
AskRecalculate 2042 peak-hour totals with background growth included, rerun intersection results, and state who would fund and build the fixes at the two deficient intersections.
The agency’s words, the record and the law +Hide the words
The agency says
“Traffic effects would be most pronounced during winter peak periods; however, the traffic analysis indicates that impacts would generally be localized and manageable.”
3.4.3 Direct and Indirect Environmental Consequences, Alternatives 2 and 3
Elsewhere in the same document
“Future plus project conditions AM and PM peak-hour volumes for the summer and winter peak periods were developed by adding the project trip generation to the 2042 background traffic volumes.”
3.4.3 Direct and Indirect Environmental Consequences, Future (2042) Plus Project Conditions
“Under the conservative full-buildout traffic scenario, total peak-hour traffic volumes are projected to reach 639 vehicles during the winter AM peak hour and 1,248 vehicles during the winter PM peak hour.”
3.4.3 Direct and Indirect Environmental Consequences, Future (2042) Plus Project Conditions
The law
“a detailed statement by the responsible official on- (i) reasonably foreseeable environmental effects of the proposed agency action; (ii) any reasonably foreseeable adverse environmental effects which cannot be avoided should the proposal be implemented;” National Environmental Policy Act, 42 U.S.C. 4332(2)(C) ↗
Science
No support given
A complete cultural survey covered every federal and state area that would be disturbed.
The agency's support is a Class III inventory of 2,058 acres over three field seasons and State Historic Preservation Office concurrence on June 18, 2026. It also relies on a Programmatic Agreement that would require added inventory before ground disturbance. But Section 3.5.3 says some updated footprints fall outside surveyed areas, so the survey doesn't cover every area to be disturbed under the current design. Alternative 3 moves disturbance to the edge of sites of Tribal interest with no buffer, and the document says Tribes still need to confirm that's acceptable.
AskComplete cultural surveys of all current footprints and finish Tribal consultation on site avoidance before the final decision, and disclose how many acres remain unsurveyed.
The agency’s words, the record and the law +Hide the words
The agency says
“A Class III (100 percent of surface) cultural survey on all federal- and state-owned areas to be disturbed including structure locations and access disturbance was conducted.”
Table 2.2-1. Project Design Criteria, H1
Elsewhere in the same document
“The cultural resource inventory was based on preliminary design and spatial data, and some updated development footprints extend beyond previously completed survey coverage.”
3.5.3 Direct and Indirect Environmental Consequences, Effects Common to All Action Alternatives
“Continued Tribal consultation is recommended prior to implementation to gain further insight into the values Tribes may place in these resources and confirm whether this level of avoidance is satisfactory.”
3.5.3 Direct and Indirect Environmental Consequences, Alternative 3
The law
“ensure the professional integrity, including scientific integrity, of the discussion and analysis in an environmental document; (E) make use of reliable data and resources in carrying out this chapter;” National Environmental Policy Act, 42 U.S.C. 4332(2)(D)-(E) ↗
What the document never analyzes
Not analyzed
Avalanche hazard and control on new terrain
The expansion adds 181.2 acres of expert terrain, snowcat skiing on the East Ridge and Brian Head Peak, and lifts across steep talus slopes. Yet the geologic hazard review covers only rockfall, landslides and debris flow.
Searched all 200 pages for ‘avalanche’, ‘snow safety’. None appear.
AskAnalyze avalanche hazard in the new steep terrain and ridgeline snowcat areas, including any explosive control work and its effects on wildlife, pika habitat and backcountry users.
Where its own record backs the agency
Purpose and needWinter skier visits to Brian Head Resort have grown substantially in recent years, alongside regional population and recreation growth.Why it holds +
Table 3.1-2 shows winter visits rising from 175,296 in 2016/17 to 313,297 in 2024/25. Part of that rise tracks longer seasons, which grew from 143 to 179 days. The document also reports Iron County growth of 15.1 percent from 2020 to 2024 and a 32 percent rise in Utah's outdoor recreation economy from 2021 to 2022.
The agency says
“As depicted in Table 3.1-2, skier visitation to BHR during the winter season has been increasing, with annual visitation increasing substantially between the 2016/17 season and the 2024/25 season.”
3.1.3 Affected Environment
Its own record backs it
“Locally, Iron County grew by 15.1 percent between April 1, 2020 and July 1, 2024.”
3.1.3 Affected Environment
“Annual growth trends in Utah’s outdoor recreation economy indicate over a 32 percent increase from 2021 to 2022.”
3.1.3 Affected Environment
Read from the agency’s own decision document ↗, all 200 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The Forest Service's own hydrology analysis admits that under Alternatives 2 and 3 the resort's snowmaking demand would run about 103.3 acre-feet short of what the agency itself calls the 'dedicated snowmaking supply' every year (Table 3.7-3), yet the draft EIS still advances both as fully analyzed, viable alternatives without identifying where the missing water would come from. Before approving either alternative, the Forest Service should require binding, quantified water-supply agreements that close this gap and should not select an alternative that cannot demonstrate it has enough water to operate as designed.
- DNF and Cedar Breaks National Monument planned a joint study to determine whether the resort's wells are hydraulically connected to the Monument's springs, but the draft EIS admits the study 'was not completed because access to the private wells was not provided.' The agency is asking the public to accept increased groundwater pumping for snowmaking without knowing which springs, streams, or wetlands it might affect. The Forest Service should complete the groundwater connectivity study, or condition any approval on completing it, before authorizing additional withdrawals.
- The Forest Service's own biologists conclude that even the reduced-scope Alternative 4 would cause a significant adverse impact to the local American pika population, and the proposed action would do the same. A finding of significant impact to a locally isolated, non-hibernating species with almost no ability to disperse is exactly the kind of impact an EIS should grapple with directly rather than accept as unavoidable under every action alternative. The agency should analyze whether any alternative can avoid this significant-impact finding before selecting one.
- The draft EIS states plainly that the Dixie National Forest has never met its own Forest Plan minimum of 40 American goshawk breeding pairs and currently has only about 9, yet it still concludes the proposed action's removal of 222 acres of goshawk habitat, including 117 acres of potential nesting habitat, is not likely to contribute to a trend toward federal listing or loss of population viability. The agency should explain, with forest-wide population data, how removing more nesting habitat from a species already at roughly a fifth of its own viability target does not push it closer to that trend.
Show every point from the document
- The draft EIS discloses that the proposed action would permanently or temporarily affect 69 percent of the wetlands mapped in the project area. That is not a marginal, avoidable edge effect; it is more than two-thirds of the wetland resource the agency itself identified and describes elsewhere as High Quality Waters. The Forest Service should analyze a design that avoids this magnitude of wetland loss before finalizing the decision.
- Part of the water-sufficiency case for snowmaking rests on 174 acre-feet from Brian Head Town and 69.3 acre-feet from Aspen Meadows identified only in letters of intent, which the draft EIS admits outright are not binding. The document nonetheless builds its 393.3 acre-foot 'dedicated snowmaking supply' figure on these non-binding letters and uses that figure throughout the hydrology chapter to argue the project can be adequately watered. The Forest Service should require executed, binding water-supply agreements before relying on these quantities in a final decision.
- The draft EIS states that the proposed action would not fully meet the High Scenic Integrity Objective in foreground and near-middleground views at Brian Head Peak and other sensitive viewpoints. Rather than redesigning the project to meet that existing standard, the document resolves the shortfall by amending the Forest Plan to reclassify those areas from a 'Natural-Appearing' landscape theme to 'Developed Recreation-Rural Interface,' which redefines what counts as meeting High SIO instead of avoiding the impact. The agency should disclose this as a lowering of the scenic standard and analyze design alternatives that actually meet the existing objective.
- The draft EIS acknowledges Brian Head Town already uses a substantial share of its allocated wastewater treatment capacity at peak winter periods, and that under the expansion demand would likely approach or exceed existing capacity, requiring future coordination with Parowan. The document approves a large increase in visitation and employment without any commitment to fund or build the additional treatment capacity it says will likely be needed. The Forest Service should require a specific wastewater capacity commitment, not a vague promise of future coordination, before authorizing the expansion.
- The draft EIS states that BHR's existing employee housing has capacity for only 80 employees and is typically 80 percent full, while Alternatives 2 and 3 would require approximately 253 new employees. The document's only response is that new employees may move into existing units, share housing, or live outside Brian Head Town or Parowan, without analyzing whether that capacity exists or committing the applicant to build any. The agency should require a specific workforce housing plan tied to the number of new employees before approving Alternatives 2 or 3.
- The 20 percent snowmaking loss rate used throughout the hydrology chapter to calculate consumptive water use is not based on conditions at Brian Head; the draft EIS admits the estimate is not based on site-specific measurements for the project area and instead borrows figures from Colorado ski areas and a study in the Swiss Alps. Every water-demand, depletion, and groundwater-effect number in the chapter flows from this borrowed assumption. The Forest Service should collect site-specific snowmaking loss data for Brian Head before finalizing the water-balance calculations underlying its sufficiency conclusions.
- 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
Brian Head Resort is proposing terrain and ski area improvements within and adjacent to their current special use permit (SUP) on the Dixie National Forest. The plan includes adding an additional 1,651 acres to their Special Use Permit boundary.
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe draft EIS states plainly that the Dixie National Forest has never met its own Forest Plan minimum of 40 American goshawk breeding pairs and currently has only about 9, yet it still concludes the p
The draft EIS states plainly that the Dixie National Forest has never met its own Forest Plan minimum of 40 American goshawk breeding pairs and currently has only about 9, yet it still concludes the proposed action's removal of 222 acres of goshawk habitat, including 117 acres of potential nesting habitat, is not likely to contribute to a trend toward federal listing or loss of population viability. The agency should explain, with forest-wide population data, how removing more nesting habitat from a species already at roughly a fifth of its own viability target does not push it closer to that trend.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingDNF and Cedar Breaks National Monument planned a joint study to determine whether the resort's wells are hydraulically connected to the Monument's springs, but the draft EIS admits the study 'was not
DNF and Cedar Breaks National Monument planned a joint study to determine whether the resort's wells are hydraulically connected to the Monument's springs, but the draft EIS admits the study 'was not completed because access to the private wells was not provided.' The agency is asking the public to accept increased groundwater pumping for snowmaking without knowing which springs, streams, or wetlands it might affect. The Forest Service should complete the groundwater connectivity study, or condition any approval on completing it, before authorizing additional withdrawals.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe draft EIS acknowledges Brian Head Town already uses a substantial share of its allocated wastewater treatment capacity at peak winter periods, and that under the expansion demand would likely appr
The draft EIS acknowledges Brian Head Town already uses a substantial share of its allocated wastewater treatment capacity at peak winter periods, and that under the expansion demand would likely approach or exceed existing capacity, requiring future coordination with Parowan. The document approves a large increase in visitation and employment without any commitment to fund or build the additional treatment capacity it says will likely be needed. The Forest Service should require a specific wastewater capacity commitment, not a vague promise of future coordination, before authorizing the expansion.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Forest Service's own hydrology analysis admits that under Alternatives 2 and 3 the resort's snowmaking demand would run about 103.3 acre-feet short of what the agency itself calls the 'dedicated s
The Forest Service's own hydrology analysis admits that under Alternatives 2 and 3 the resort's snowmaking demand would run about 103.3 acre-feet short of what the agency itself calls the 'dedicated snowmaking supply' every year (Table 3.7-3), yet the draft EIS still advances both as fully analyzed, viable alternatives without identifying where the missing water would come from. Before approving either alternative, the Forest Service should require binding, quantified water-supply agreements that close this gap and should not select an alternative that cannot demonstrate it has enough water to operate as designed.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Forest Service's own biologists conclude that even the reduced-scope Alternative 4 would cause a significant adverse impact to the local American pika population, and the proposed action would do
The Forest Service's own biologists conclude that even the reduced-scope Alternative 4 would cause a significant adverse impact to the local American pika population, and the proposed action would do the same. A finding of significant impact to a locally isolated, non-hibernating species with almost no ability to disperse is exactly the kind of impact an EIS should grapple with directly rather than accept as unavoidable under every action alternative. The agency should analyze whether any alternative can avoid this significant-impact finding before selecting one.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe draft EIS discloses that the proposed action would permanently or temporarily affect 69 percent of the wetlands mapped in the project area.
The draft EIS discloses that the proposed action would permanently or temporarily affect 69 percent of the wetlands mapped in the project area. That is not a marginal, avoidable edge effect; it is more than two-thirds of the wetland resource the agency itself identified and describes elsewhere as High Quality Waters. The Forest Service should analyze a design that avoids this magnitude of wetland loss before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe draft EIS states that BHR's existing employee housing has capacity for only 80 employees and is typically 80 percent full, while Alternatives 2 and 3 would require approximately 253 new employees.
The draft EIS states that BHR's existing employee housing has capacity for only 80 employees and is typically 80 percent full, while Alternatives 2 and 3 would require approximately 253 new employees. The document's only response is that new employees may move into existing units, share housing, or live outside Brian Head Town or Parowan, without analyzing whether that capacity exists or committing the applicant to build any. The agency should require a specific workforce housing plan tied to the number of new employees before approving Alternatives 2 or 3.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingPart of the water-sufficiency case for snowmaking rests on 174 acre-feet from Brian Head Town and 69.3 acre-feet from Aspen Meadows identified only in letters of intent, which the draft EIS admits out
Part of the water-sufficiency case for snowmaking rests on 174 acre-feet from Brian Head Town and 69.3 acre-feet from Aspen Meadows identified only in letters of intent, which the draft EIS admits outright are not binding. The document nonetheless builds its 393.3 acre-foot 'dedicated snowmaking supply' figure on these non-binding letters and uses that figure throughout the hydrology chapter to argue the project can be adequately watered. The Forest Service should require executed, binding water-supply agreements before relying on these quantities in a final decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe 20 percent snowmaking loss rate used throughout the hydrology chapter to calculate consumptive water use is not based on conditions at Brian Head; the draft EIS admits the estimate is not based on
The 20 percent snowmaking loss rate used throughout the hydrology chapter to calculate consumptive water use is not based on conditions at Brian Head; the draft EIS admits the estimate is not based on site-specific measurements for the project area and instead borrows figures from Colorado ski areas and a study in the Swiss Alps. Every water-demand, depletion, and groundwater-effect number in the chapter flows from this borrowed assumption. The Forest Service should collect site-specific snowmaking loss data for Brian Head before finalizing the water-balance calculations underlying its sufficiency conclusions.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe draft EIS states that the proposed action would not fully meet the High Scenic Integrity Objective in foreground and near-middleground views at Brian Head Peak and other sensitive viewpoints.
The draft EIS states that the proposed action would not fully meet the High Scenic Integrity Objective in foreground and near-middleground views at Brian Head Peak and other sensitive viewpoints. Rather than redesigning the project to meet that existing standard, the document resolves the shortfall by amending the Forest Plan to reclassify those areas from a 'Natural-Appearing' landscape theme to 'Developed Recreation-Rural Interface,' which redefines what counts as meeting High SIO instead of avoiding the impact. The agency should disclose this as a lowering of the scenic standard and analyze design alternatives that actually meet the existing objective.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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