Stop expanding Brian Head Resort into Dixie National Forest
Brian Head Resort Expansion project
U.S. Forest Service· Dixie National Forest, Cedar City Ranger DistrictU.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 work Utah
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.
- Bears Ears Inter-Tribal Coalition
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
Works Utah: the monument’s friends group: science, stewardship, and the legal fight over its boundaries.
- Southern Utah Wilderness Alliance
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
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 may authorize Brian Head Resort to use 1,651 more acres of public forest land.
What’s at risk
1,651 acres of Dixie National Forest on the Cedar City Ranger District are at risk of being added to Brian Head Resort's special use permit area, expanding ski terrain and facilities onto currently undeveloped public land.
If this goes through
If approved, the Forest Service would authorize the resort to develop and operate across a significantly larger footprint of public land, and those who do not comment now lose the right to formally object later.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
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 EIS admits that under the conservative 1.3 AF/acre snowmaking rate, Alternatives 2 and 3 face a shortfall of 103.3 acre-feet per year in dedicated snowmaking supply, yet the agency still carries these alternatives forward for approval without requiring binding water agreements first. The letters of intent from Brian Head Town and Aspen Meadows are explicitly described as non-binding. PDC HS22 defers ground-disturbing activity until water-right changes are approved, but that deferral happens after a Record of Decision, not before. The EIS does not explain how a decision can be made responsibly when the water supply needed to operate the project is unconfirmed. The agency should require executed, legally binding water supply agreements and completed water-right change approvals from the Utah Division of Water Rights before issuing a final EIS or Record of Decision, or alternatively…
- The EIS acknowledges that the DNF and Cedar Breaks National Monument jointly developed a workplan to evaluate groundwater connectivity using geochemical sampling and, if connectivity was indicated, groundwater drawdown modeling, but then states that this analysis was not completed because access to the private wells was not provided. Despite this, the EIS proceeds to authorize up to 256.9 acre-feet per year of additional groundwater withdrawal under Alternative 2 without quantifying effects on springs, streams, wetlands, or groundwater-dependent ecosystems that may be hydrologically connected to the source wells. The agency should either complete the groundwater connectivity investigation and modeling before issuing a final decision, or limit any approval to Alternative 4 pending completion of that study.
- The Forest Plan establishes a minimum viable population of 40 American goshawk breeding pairs for the Dixie National Forest, and the EIS states the Forest has never met that standard and currently estimates approximately 9 breeding pairs. Despite this, the agency makes a MIIH determination and proceeds without requiring any specific, quantified, on-the-ground mitigation before a decision. The EIS states that mitigation for loss of suitable goshawk habitat would be developed in coordination with the Forest Service prior to the ROD, meaning the mitigation is undefined at the time of public comment. The agency should publish the specific mitigation plan, including location, acreage, and timeline of habitat improvement treatments, for public review before issuing a final EIS, and explain how authorizing removal of 117 acres of potentially suitable nesting habitat is consistent with Forest…
- The EIS finds that all action alternatives would result in a significant adverse impact to the local Brian Head American pika population, including Alternative 4, which permanently impacts 22 acres of the isolated talus system. The document also states the Brian Head pika population is geographically isolated from the nearest substantial lava flow habitat by more than 5 km, likely exceeding typical pika dispersal capability, and that the population functions as a metapopulation where even small-scale habitat alterations may have population-level effects. Despite these findings, no alternative fully avoids pika habitat, no translocation protocol is finalized, and the species is not federally listed, so no Section 7 backstop applies. The agency should conduct site-specific pika population viability analysis for each alternative and disclose whether any action alternative is consistent…
Show all 12 points from the document
- The EIS discloses that under Alternatives 2 and 3 the project would permanently eliminate 5 miles of state-managed groomed snowmobile route segments in the Navajo Ridge to Dry Lakes Pod and reroute snowmobilers through Brian Head Town, increasing travel distance, time, and converting the experience to a more developed corridor. The document also notes that a DNF-permitted outfitter-guiding operation, Thunder Mountain Motorsports, uses this groomed trail. The EIS does not analyze economic impacts on Thunder Mountain Motorsports specifically, does not disclose whether a separate NEPA process is needed to retire those route miles, and does not explain how permanent closure of state-managed snowmobile routes on NFS lands is consistent with the existing motorized travel management framework. The agency should disclose whether route retirement requires separate travel management NEPA…
- The EIS states that the wastewater system analysis was not carried forward for detailed analysis because the addition of four restaurants that primarily operate seasonally is not anticipated to meaningfully increase wastewater capacity, yet Section 3.3.4 states that Brian Head Town already utilizes a substantial portion of its allocated wastewater treatment capacity at peak winter periods and that wastewater demand would likely approach or exceed existing treatment capacity during peak periods under Alternatives 2 and 3. The agency dismissed wastewater as an issue not warranting detailed analysis while simultaneously finding capacity constraints are likely. The agency should either analyze wastewater infrastructure impacts in detail in the final EIS or explain the specific quantitative basis for finding no meaningful impact when the EIS itself projects capacity to be approached or…
- The EIS discloses that under Alternatives 2 and 3, Alternative 3 requires 3 additional acres of ground disturbance for Ridge Lift 1 and 2 additional acres for Ridge Lift 2 beyond the proposed action, yet states in the summary table that tree removal and terrain grading under Alternative 3 are the same as Alternative 2 at 401 acres and 365 acres respectively. The EIS also acknowledges that additional grading at the relocated Ridge Lift 1 and 2 terminals increases noise propagation and visibility into adjacent forest patches, causes slightly greater adverse impacts to scenic integrity, and results in approximately 4 additional acres of pika habitat loss compared to Alternative 2. The agency presents Alternative 3 as the environmentally refined alternative but documents that it is worse than the proposed action on multiple metrics. The agency should clearly reconcile why Alternative 3 is…
- The EIS projects that under Alternatives 2 and 3, annual winter visitation would reach 639,700 visits by 2036, an increase of approximately 326,403 visits over current levels, and that this could require a 3.0 percent increase in Iron County population if all supported FTEs relocate there. The document then states that more than 50 percent of renters in Iron County already spend over 30 percent of gross income on housing and that Brian Head Town's 2026 proposed budget allocates only $11,838 toward workforce housing implementation. The EIS does not analyze whether existing or planned housing stock can absorb the projected workforce growth, does not require any housing mitigation as a condition of approval, and does not quantify displacement risk. The agency should conduct a housing capacity and affordability analysis for the projected workforce increase and disclose whether approval of…
- The EIS dismisses the alternative of joint ski-snowmobile corridor management because of operational complexity and safety concerns which could not be effectively mitigated, but provides no technical analysis, data, or cited authority supporting that conclusion. Simultaneously the EIS eliminates the no-expansion-on-NFS-lands alternative as substantially similar to no action, the snowmobile priority alternative as not meeting purpose and need, and the expansion-within-existing-footprint alternative as not meeting purpose and need, narrowing the range of alternatives almost entirely to variants of the full buildout. NEPA requires agencies to rigorously explore and objectively evaluate all reasonable alternatives. The agency should provide documented technical or safety analysis justifying dismissal of the joint-management alternative, or reopen scoping to develop an alternative that…
- The SHPO concurred with a finding of adverse effect to historic properties for all action alternatives, and the EIS states that mitigation and avoidance measures will be defined through a Programmatic Agreement that has not yet been executed. The EIS also discloses that some updated development footprints extend beyond previously completed survey coverage, meaning additional Class III inventory and testing would be required in select areas after the decision is made. Tribal consultation is described as recommended prior to implementation rather than completed. The public is therefore asked to comment on heritage impacts without seeing the Programmatic Agreement, without completed survey coverage, and without a record of completed government-to-government consultation outcomes. The agency should complete outstanding Class III surveys, finalize and publish the Programmatic Agreement for…
- 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?
19 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 EIS acknowledges that the DNF and Cedar Breaks National Monument jointly developed a workplan to evaluate groundwater connectivity using geochemical sampling and, if connectivity was indicated, gr
The EIS acknowledges that the DNF and Cedar Breaks National Monument jointly developed a workplan to evaluate groundwater connectivity using geochemical sampling and, if connectivity was indicated, groundwater drawdown modeling, but then states that this analysis was not completed because access to the private wells was not provided. Despite this, the EIS proceeds to authorize up to 256.9 acre-feet per year of additional groundwater withdrawal under Alternative 2 without quantifying effects on springs, streams, wetlands, or groundwater-dependent ecosystems that may be hydrologically connected to the source wells. The agency should either complete the groundwater connectivity investigation and modeling before issuing a final decision, or limit any approval to Alternative 4 pending completion of that study.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Forest Plan establishes a minimum viable population of 40 American goshawk breeding pairs for the Dixie National Forest, and the EIS states the Forest has never met that standard and currently est
The Forest Plan establishes a minimum viable population of 40 American goshawk breeding pairs for the Dixie National Forest, and the EIS states the Forest has never met that standard and currently estimates approximately 9 breeding pairs. Despite this, the agency makes a MIIH determination and proceeds without requiring any specific, quantified, on-the-ground mitigation before a decision. The EIS states that mitigation for loss of suitable goshawk habitat would be developed in coordination with the Forest Service prior to the ROD, meaning the mitigation is undefined at the time of public comment. The agency should publish the specific mitigation plan, including location, acreage, and timeline of habitat improvement treatments, for public review before issuing a final EIS, and explain how authorizing removal of 117 acres of potentially suitable nesting habitat is consistent with Forest Plan Standard X when the population is already at 23 percent of the minimum viable threshold.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states field observers found the dry channels at the bottom of the Desbah and Kodachrome ski runs to be incised, with visible sediment accumulation where they meet Parowan Creek.
The document states field observers found the dry channels at the bottom of the Desbah and Kodachrome ski runs to be incised, with visible sediment accumulation where they meet Parowan Creek.
- PendingThe document identifies two specific numbered Forest Service roads where field review found rill and gully erosion and found roadside ditches missing or filled in along many sections.
The document identifies two specific numbered Forest Service roads where field review found rill and gully erosion and found roadside ditches missing or filled in along many sections.
- PendingThe document states field observers saw sediment from a specific numbered Forest Service road depositing directly into Brown Creek.
The document states field observers saw sediment from a specific numbered Forest Service road depositing directly into Brown Creek.
- PendingThe document states that an unnamed perennial stream near where the Roulette 2 lift's bottom terminal is proposed has already experienced minor undercutting of its banks.
The document states that an unnamed perennial stream near where the Roulette 2 lift's bottom terminal is proposed has already experienced minor undercutting of its banks.
- PendingThe document states two upper sections of an unnamed perennial stream currently have no culvert and instead flow directly across two named roads.
The document states two upper sections of an unnamed perennial stream currently have no culvert and instead flow directly across two named roads.
- PendingThe document cites counter data showing more than 400 mountain bike passes per week during peak summer use at a specific trailhead junction, indicating a measurable existing traffic level on the trail
The document cites counter data showing more than 400 mountain bike passes per week during peak summer use at a specific trailhead junction, indicating a measurable existing traffic level on the trail network.
- PendingThe document asserts that the Navajo Ridge to Dry Lakes Pod currently has only Forest roads and a county road on the ground, with no developed ski trails, resort infrastructure, or facilities present
The document asserts that the Navajo Ridge to Dry Lakes Pod currently has only Forest roads and a county road on the ground, with no developed ski trails, resort infrastructure, or facilities present anywhere in the pod.
- PendingThe document states an existing dirt and gravel road, the Brian Head Peak Road, already provides vehicle access to the summit and also supports boot-pack access in winter, meaning no chairlift or new
The document states an existing dirt and gravel road, the Brian Head Peak Road, already provides vehicle access to the summit and also supports boot-pack access in winter, meaning no chairlift or new road is currently needed to reach the peak.
- PendingThe document states that within the Sid's Peak to East Ridge Pod, existing infrastructure is limited to a few non-forested administrative roads and three named single-track trails, with no existing sk
The document states that within the Sid's Peak to East Ridge Pod, existing infrastructure is limited to a few non-forested administrative roads and three named single-track trails, with no existing ski trails or resort facilities anywhere in the pod.
- PendingThe SHPO concurred with a finding of adverse effect to historic properties for all action alternatives, and the EIS states that mitigation and avoidance measures will be defined through a Programmatic
The SHPO concurred with a finding of adverse effect to historic properties for all action alternatives, and the EIS states that mitigation and avoidance measures will be defined through a Programmatic Agreement that has not yet been executed. The EIS also discloses that some updated development footprints extend beyond previously completed survey coverage, meaning additional Class III inventory and testing would be required in select areas after the decision is made. Tribal consultation is described as recommended prior to implementation rather than completed. The public is therefore asked to comment on heritage impacts without seeing the Programmatic Agreement, without completed survey coverage, and without a record of completed government-to-government consultation outcomes. The agency should complete outstanding Class III surveys, finalize and publish the Programmatic Agreement for public review, and document the outcomes of Tribal consultation before issuing the final EIS, consistent with Section 106 requirements.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS finds that all action alternatives would result in a significant adverse impact to the local Brian Head American pika population, including Alternative 4, which permanently impacts 22 acres of
The EIS finds that all action alternatives would result in a significant adverse impact to the local Brian Head American pika population, including Alternative 4, which permanently impacts 22 acres of the isolated talus system. The document also states the Brian Head pika population is geographically isolated from the nearest substantial lava flow habitat by more than 5 km, likely exceeding typical pika dispersal capability, and that the population functions as a metapopulation where even small-scale habitat alterations may have population-level effects. Despite these findings, no alternative fully avoids pika habitat, no translocation protocol is finalized, and the species is not federally listed, so no Section 7 backstop applies. The agency should conduct site-specific pika population viability analysis for each alternative and disclose whether any action alternative is consistent with maintaining population viability, or explain the legal and scientific basis for proceeding with acknowledged significant adverse impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS discloses that under Alternatives 2 and 3 the project would permanently eliminate 5 miles of state-managed groomed snowmobile route segments in the Navajo Ridge to Dry Lakes Pod and reroute sn
The EIS discloses that under Alternatives 2 and 3 the project would permanently eliminate 5 miles of state-managed groomed snowmobile route segments in the Navajo Ridge to Dry Lakes Pod and reroute snowmobilers through Brian Head Town, increasing travel distance, time, and converting the experience to a more developed corridor. The document also notes that a DNF-permitted outfitter-guiding operation, Thunder Mountain Motorsports, uses this groomed trail. The EIS does not analyze economic impacts on Thunder Mountain Motorsports specifically, does not disclose whether a separate NEPA process is needed to retire those route miles, and does not explain how permanent closure of state-managed snowmobile routes on NFS lands is consistent with the existing motorized travel management framework. The agency should disclose whether route retirement requires separate travel management NEPA analysis, quantify economic impacts to permitted outfitters, and explain its legal authority to close state-managed routes through a ski area permit decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS states that the wastewater system analysis was not carried forward for detailed analysis because the addition of four restaurants that primarily operate seasonally is not anticipated to meanin
The EIS states that the wastewater system analysis was not carried forward for detailed analysis because the addition of four restaurants that primarily operate seasonally is not anticipated to meaningfully increase wastewater capacity, yet Section 3.3.4 states that Brian Head Town already utilizes a substantial portion of its allocated wastewater treatment capacity at peak winter periods and that wastewater demand would likely approach or exceed existing treatment capacity during peak periods under Alternatives 2 and 3. The agency dismissed wastewater as an issue not warranting detailed analysis while simultaneously finding capacity constraints are likely. The agency should either analyze wastewater infrastructure impacts in detail in the final EIS or explain the specific quantitative basis for finding no meaningful impact when the EIS itself projects capacity to be approached or exceeded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS discloses that under Alternatives 2 and 3, Alternative 3 requires 3 additional acres of ground disturbance for Ridge Lift 1 and 2 additional acres for Ridge Lift 2 beyond the proposed action,
The EIS discloses that under Alternatives 2 and 3, Alternative 3 requires 3 additional acres of ground disturbance for Ridge Lift 1 and 2 additional acres for Ridge Lift 2 beyond the proposed action, yet states in the summary table that tree removal and terrain grading under Alternative 3 are the same as Alternative 2 at 401 acres and 365 acres respectively. The EIS also acknowledges that additional grading at the relocated Ridge Lift 1 and 2 terminals increases noise propagation and visibility into adjacent forest patches, causes slightly greater adverse impacts to scenic integrity, and results in approximately 4 additional acres of pika habitat loss compared to Alternative 2. The agency presents Alternative 3 as the environmentally refined alternative but documents that it is worse than the proposed action on multiple metrics. The agency should clearly reconcile why Alternative 3 is recommended over the proposed action when its own analysis shows greater pika habitat loss, greater scenic impact at Brian Head Peak, and greater AMZ disturbance, or revise the alternatives to produce a genuinely improved option.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS projects that under Alternatives 2 and 3, annual winter visitation would reach 639,700 visits by 2036, an increase of approximately 326,403 visits over current levels, and that this could requ
The EIS projects that under Alternatives 2 and 3, annual winter visitation would reach 639,700 visits by 2036, an increase of approximately 326,403 visits over current levels, and that this could require a 3.0 percent increase in Iron County population if all supported FTEs relocate there. The document then states that more than 50 percent of renters in Iron County already spend over 30 percent of gross income on housing and that Brian Head Town's 2026 proposed budget allocates only $11,838 toward workforce housing implementation. The EIS does not analyze whether existing or planned housing stock can absorb the projected workforce growth, does not require any housing mitigation as a condition of approval, and does not quantify displacement risk. The agency should conduct a housing capacity and affordability analysis for the projected workforce increase and disclose whether approval of Alternatives 2 or 3 without housing mitigation is consistent with the Forest Plan's direction to support the continued stability of dependent communities.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS dismisses the alternative of joint ski-snowmobile corridor management because of operational complexity and safety concerns which could not be effectively mitigated, but provides no technical
The EIS dismisses the alternative of joint ski-snowmobile corridor management because of operational complexity and safety concerns which could not be effectively mitigated, but provides no technical analysis, data, or cited authority supporting that conclusion. Simultaneously the EIS eliminates the no-expansion-on-NFS-lands alternative as substantially similar to no action, the snowmobile priority alternative as not meeting purpose and need, and the expansion-within-existing-footprint alternative as not meeting purpose and need, narrowing the range of alternatives almost entirely to variants of the full buildout. NEPA requires agencies to rigorously explore and objectively evaluate all reasonable alternatives. The agency should provide documented technical or safety analysis justifying dismissal of the joint-management alternative, or reopen scoping to develop an alternative that retains snowmobile connectivity without permanent trail loss, and explain in the final EIS how the range of alternatives is not impermissibly narrow.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EIS admits that under the conservative 1.3 AF/acre snowmaking rate, Alternatives 2 and 3 face a shortfall of 103.3 acre-feet per year in dedicated snowmaking supply, yet the agency still carries t
The EIS admits that under the conservative 1.3 AF/acre snowmaking rate, Alternatives 2 and 3 face a shortfall of 103.3 acre-feet per year in dedicated snowmaking supply, yet the agency still carries these alternatives forward for approval without requiring binding water agreements first. The letters of intent from Brian Head Town and Aspen Meadows are explicitly described as non-binding. PDC HS22 defers ground-disturbing activity until water-right changes are approved, but that deferral happens after a Record of Decision, not before. The EIS does not explain how a decision can be made responsibly when the water supply needed to operate the project is unconfirmed. The agency should require executed, legally binding water supply agreements and completed water-right change approvals from the Utah Division of Water Rights before issuing a final EIS or Record of Decision, or alternatively select only Alternative 4 where the projected shortfall under the conservative rate drops to 9.7 AF and is far more plausible to close.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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From More Than Just ParksAfter more than a decade chasing peak color across America, we built the foliage map we always wanted.
Another foreign mining company wants a piece of America’s public lands. This one comes with millions of gallons of groundwater pumping and radioactive radon.
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