Ski Santa Fe snowmaking expansion on Santa Fe National Forest
Ski Santa Fe Snowmaking Modernization Project (PALS# 68982)
U.S. Forest Service· Espanola 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 New Mexico
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.
- Greater Chaco Coalition
Works New Mexico: the coalition of Diné and Pueblo communities fighting drilling around Chaco.
- New Mexico Wild
Works New Mexico: led the community campaign for the 2014 designation and executive director Mark Allison spoke at the June 2025 Las Cruces rally against monument reductions and the Senate public land sell-off provisions..
- San Juan Citizens Alliance
Works New Mexico: the San Juan Basin watchdog on the ground in greater Chaco.
- WildEarth Guardians
Works New Mexico: serial litigant over greater Chaco drilling permits.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service may authorize expanded water storage and snowmaking infrastructure on public national forest land.
What’s at risk
Water resources and natural terrain on the Espanola Ranger District face alteration from expanded storage and new snowmaking infrastructure. The project would expand a private ski operator's footprint on public land.
If this goes through
If approved, Ski Santa Fe would gain authorization to build additional water storage and install new snowmaking systems on the Santa Fe National Forest, with infrastructure that would be difficult to reverse.
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
- 7
- No support given
- 1
- Never analyzed
The Forest Service proposes to let Ski Santa Fe build a new tank of about 4.6 million gallons, extend up to 4,170 feet of snowmaking pipe to Millennium Chair terrain, and regrade about four acres of the Sunrise run. It says this would make snowmaking more efficient and reliable and would support emergency fire suppression.
“The purpose of the SSF Snowmaking Modernization project is to modernize and expand snowmaking infrastructure within SSF to improve efficiency and reliability of snowmaking operations and support emergency response capabilities.”
1.3.1
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.
Purpose and need
No support given
The new tank would support emergency fire suppression by adding on-site water storage.
Fire suppression is part of the stated purpose, and Table 1.4-2 repeats it. But the tank is filled only from diversions allowed November 1 through March 31 for later snowmaking use, and the document never says water would be held into fire season, how much would be reserved, or how firefighters would draw it. Appendix 6 marks fire plan components not applicable.
AskState how much water would stay in the tank during fire season, how firefighters would reach it, and whether a reserve would be a permit condition.
The agency’s words, the record +Hide the words
The agency says
“The proposed water tank could support emergency fire-suppression response by providing additional on-site water storage.”
3.4.2
Elsewhere in the same document
“Snowmaking diversions are permitted from November 1 through March 31 and are metered for compliance with state requirements.”
2.1.2
“The proposed tank would temporarily store diverted water for later snowmaking use.”
3.4.2
Purpose and need
No support given
Regrading about four acres of the Sunrise run is needed to fix a double fall line that hurts safety and snow retention and complicates snowmaking.
Section 1.3.1 describes the double fall line as a safety and snow-retention problem. No injury, snow depth or grooming data are given. Section 3.1.3 says Alternative 3 delivers the snowmaking benefits without grading, so grading isn't needed to install the pipe. The safety and snow case rests on description alone.
AskProvide injury reports, snow retention or grooming data for Sunrise, and explain why about four acres of grading is justified when Alternative 3 installs the same pipe.
The agency’s words, the record +Hide the words
The agency says
“The double fall line on the existing Sunrise ski run is challenging to navigate even for advanced skiers and riders and operationally does not hold snow as well as it would if it were graded more like another ski run on the mountain.”
2.1.2
Elsewhere in the same document
“Alternative 3 would not include the Sunrise grading; therefore, the snowmaking benefits would occur under Alternative 3, but the terrain-consistency, circulation, and safety benefits associated with grading would not.”
3.1.3
Alternatives
No support given
An alternative without the new tank isn't feasible, because the tank is a prerequisite for the snowmaking extension and the ski area would drop the project.
The document's first reason for dropping this alternative is that it wouldn't meet the purpose and need. That need expressly includes addressing water storage limits and providing water for fire suppression, which a no-tank alternative can't do. Section 1.3.1 also says existing storage limits efficient use of short snowmaking weather windows. The separate feasibility claim, that the tank is a prerequisite and the project would be dropped without it, rests on the proponent's statement. The document gives no storage, demand or hydraulic figures showing why the existing 5-million-gallon tank and two 500,000-gallon tanks can't serve 4,170 feet of pipe and four guns. Appendix 4 also says the 2015 tank was approved to use the entire water right.
AskProvide the storage and demand calculations showing the new tank is necessary, and explain why the 2015 tank, approved to use the whole water right, falls short.
The agency’s words, the record and the law +Hide the words
The agency says
“The proponent considered this alternative but determined that the action would be dropped without the tank, as the tank is a prerequisite to the snowmaking extension.”
2.2.1
Elsewhere in the same document
“The Forest Service approved the construction of a new 5-million-gallon water storage tank within the SSF ski area to utilize the entirety of their available water right for snowmaking.”
Appendix 4
“Current water storage capacity is limited to one 5-million-gallon tank and two 500,000-gallon tanks.”
3.1.2
The law
“consistent with the provisions of this chapter, study, develop, and describe technically and economically feasible alternatives;” National Environmental Policy Act, 42 U.S.C. 4332(2)(F) ↗
Show 4 more claims +Show fewer
Effects
No support given
The tank and added snowmaking won't take more water from the Rio en Medio than the ski area's existing water right, so downstream users won't be affected.
Diversions are metered and capped at 69.72 acre-feet, and the tank's roughly 14 acre-feet fits inside that cap. But the document never states current actual diversions, and it says storage now limits use of authorized water, so real withdrawals could rise. It also reports losses of 7 to 35 percent against a permitted consumptive use of 16.39 acre-feet and doesn't reconcile the two.
AskDisclose current actual annual diversions and consumptive use, estimate how much they'd rise with the tank, and reconcile the 7 to 35 percent loss range with the 16.39 acre-foot limit.
The agency’s words, the record +Hide the words
The agency says
“Therefore, the proposed tank would not result in removal of additional water from the Rio en Medio beyond SSF’s existing water right.”
3.4.2
Elsewhere in the same document
“SSF and the Forest Service hold snowmaking water rights authorizing up to 69.72 AF (approximately 22.7 million gallons) of annual diversion and 16.39 AF of annual consumptive use.”
2.1.2
“Separately, the 1985 site study estimated physical evaporation and sublimation losses of 9.8 percent, while more recent studies report losses of approximately 7 to 35 percent depending on meteorological conditions.”
2.1.2
Effects
No support given
Forest Plan direction on scheduling facility construction at popular developed sites in summer, and on National Recreation Trails, doesn't apply because the project doesn't include that activity.
Section 3.1.3 finds construction effects minor and temporary. It says no National Forest System trails would close, ample parking would remain, and staging would stay near ski area facilities to preserve hiker parking. That fits the intent of the guideline on popular developed sites, which covers activities that would substantially diminish recreation. But Appendix 6 labels these guidelines not applicable because the project supposedly doesn't include the activity. The project does include summer construction and staging in the base area next to the Winsor Trailhead, and Appendix 6 never shows compliance or addresses weekend and holiday scheduling.
AskReassess the summer scheduling and National Recreation Trail guidelines, and add a design criterion limiting staging and closures on summer weekends and holidays at the Winsor Trailhead.
The agency’s words, the record and the law +Hide the words
The agency says
“The proposed project does not include this activity or affect this resource.”
Appendix 6
Elsewhere in the same document
“Portions of the lots could be temporarily used for staging during the construction season or closed during parts of the day, temporarily reducing available public parking.”
3.1.3
“This portion of the Winsor Trail is part of the Winsor National Recreation Trail and is one of the most popular trails on the Española District as well as a gateway to the Pecos Wilderness.”
3.1.2
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) ↗
Effects
No support given
The project would have no effect on any federally listed or proposed species, including the monarch butterfly.
Habitat for the yellow-billed cuckoo and New Mexico meadow jumping mouse is absent. The bumble bee isn't known in New Mexico and hasn't been confirmed in the United States since 2016. No listed plants occur in the project area, and no critical habitat is present. That backs no effect for those species. For the monarch, section 3.3.1 says potentially suitable habitat may be present on the ski runs where grading and trenching would occur, though it describes those runs as previously disturbed with diminished habitat indicators. Section 3.3.2 then cites a lack of habitat or occurrence without reporting monarch survey results.
AskReport surveys for milkweed and nectar plants on the Sunrise run and trench routes, and explain the no effect finding for the monarch.
The agency’s words, the record and the law +Hide the words
The agency says
“The proposed action was determined to have no effect on federally listed or proposed species identified for the project.”
Table 1.4-1
Elsewhere in the same document
“While potentially suitable habitat for the monarch butterfly and Suckley’s cuckoo bumble bee may be present within ski runs in the project area, these areas have been previously disturbed and habitat indicators are diminished.”
3.3.1
The law
“Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an "agency action") is not likely to jeopardize the continued existence of any endangered species or threatened species” Endangered Species Act, 16 U.S.C. 1536(a)(2) ↗
Process
No support given
Design criteria will keep tribal access to the Lake Peak Traditional Use Area open during construction, supporting consistency with Forest Plan tribal direction.
Appendix 6 frames the access commitment as design criteria that will be developed with the Santa Fe National Forest, and section 1.5 lets the Responsible Official add design criteria later. Several tribal and rural community plan ratings rest on this commitment. But Appendix 2, which the document says holds the design criteria, lists only tribal monitoring and stop-work criteria, with nothing on tribal access or the Lake Peak Traditional Use Area. Chapter 3's cultural section never mentions that area.
AskAdd a specific, enforceable design criterion guaranteeing tribal access to the Lake Peak Traditional Use Area, and analyze access effects in the cultural resources section.
The agency’s words, the record +Hide the words
The agency says
“Design feature(s) would be used to satisfy component/species: PDC and BMPs will be developed in coordination with the SFNF to ensure tribal access to the LPTUA is maintained throughout project implementation.”
Appendix 6
Elsewhere in the same document
“PDCs are site-specific and would be implemented to avoid and minimize potential resource impacts as a result of the proposed action and ensure consistency with applicable Forest Plan direction.”
Appendix 2
What the document never analyzes
Not analyzed
Risk of water tank failure
A tank of about 4.6 million gallons would sit at the bottom of the Alpine and Lobo runs, and all drainage from the project area flows into the Rio en Medio, a watershed rated functioning at risk.
Searched all 151 pages for ‘breach’, ‘rupture’, ‘seismic’, ‘geotechnical’. None appear.
AskAnalyze the tank's foundation stability and the downstream effects of a tank failure on the Rio en Medio, and describe safeguards.
Where its own record backs the agency
EffectsNeither action alternative would adversely affect historic properties, including the traditional cultural property the project area lies within.Why it holds +
Section 3.2.1 says no documented sites of the traditional cultural property intersect the disturbance footprint, the Class III survey found no contributing features, and the visual assessment found all components obscured from sensitive locations. That backs the finding, though Section 106 consultation isn't complete and consultation with the Pueblo of Tesuque continues.
The agency says
“Based on the completed identification and effects assessment, the Santa Fe National Forest has determined that Alternatives 2 and 3 would result in no adverse effect to historic properties.”
3.2.2
Its own record backs it
“None of the individually documented archaeological sites or other discrete cultural resources that comprise the TCP intersect the proposed ground-disturbance footprint.”
3.2.1
“The visual assessment determined that all project components under Alternatives 2 and 3 would be visually obscured from the culturally sensitive locations evaluated because of intervening topography and vegetation.”
3.2.1
Read from the agency’s own decision document ↗, all 151 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 EA dismisses climate-driven water availability as a concern without analyzing how a warming, drying climate undermines the core purpose of the project. Section 3.4.1 states that 'winter snowfall could shift to rain as increases in temperatures continue' and that 'the overall increase in temperature and shift in precipitation type could result in shorter snow seasons,' yet Section 3.4.2 treats these risks as uncertain background noise and performs no analysis of whether the new tank and pipe infrastructure will remain operationally useful or financially justified under reduced snowmaking windows. The agency should either prepare a full EIS that models project utility under projected climate scenarios or, at minimum, supplement the EA with a quantitative analysis of how climate trends affect the purpose-and-need rationale before approving this infrastructure.
- The EA acknowledges the Rio Nambé watershed is already rated 'functioning at risk' but never analyzes whether adding 4.6 million gallons of storage capacity and up to four acres of terrain grading on a watershed already under stress could push it from 'functioning at risk' to 'impaired.' Section 3.4.1 cites the Watershed Condition Framework rating of 'functioning at risk' and separately notes that soil condition is rated 'fair,' yet Section 3.4.2 concludes with no adverse long-term effects without explaining how two additional ground-disturbance footprints are consistent with stabilizing an already stressed watershed. The agency should analyze the cumulative loading on the Rio Nambé watershed explicitly against the Watershed Condition Framework thresholds and justify the FONSI in light of the pre-existing 'functioning at risk' classification.
- The water-loss range cited in the EA is enormous and the agency never explains which end of the range applies here, yet consumptive-use compliance depends on an accurate loss figure. Section 2.1.2 states that 'the 1985 site study estimated physical evaporation and sublimation losses of 9.8 percent, while more recent studies report losses of approximately 7 to 35 percent depending on meteorological conditions.' A swing from 7 to 35 percent on 69.72 AF of authorized diversion means consumptive use could range from roughly 5 to 24 AF annually, yet the EA simply repeats the permitted consumptive-use figure of 16.39 AF without reconciling it against the more recent, higher-loss research. The agency should incorporate the most current loss-rate data into the water sufficiency analysis and demonstrate that authorized consumptive use will not be exceeded under the higher loss scenarios enabled…
- The Pueblos of San Ildefonso and Tesuque were not present at the first consultation meeting because of prior commitments, and the EA confirms that Section 106 consultation is still incomplete at the time of public comment. Section 3.2.2 states 'The Forest Service will complete Section 106 consultation before authorizing project implementation,' meaning the public is being asked to comment on a project whose consultation record is open and whose effects on a National Register-eligible Traditional Cultural Property have not been fully resolved. Authorizing the project before completing Section 106 violates the sequence required by 36 CFR 800; the agency should extend the comment period, release the completed Section 106 record for public review, and not issue a Decision Notice until all consulting tribes have formally concurred or the process has otherwise concluded.
Show all 12 points from the document
- The EA eliminates the no-tank alternative from detailed analysis on the grounds that SSF itself said it would not proceed without the tank, effectively letting the permit applicant define the range of alternatives. Section 2.2.1 states the alternative was eliminated because 'the proponent considered this alternative but determined that the action would be dropped without the tank.' NEPA requires the agency, not the applicant, to define a reasonable range of alternatives; deferring that judgment to SSF's business preference does not constitute the independent analysis required by law. The agency should analyze the no-tank alternative in full, or document with its own evidence why no purpose-and-need-meeting configuration exists without the tank, and provide that analysis for public comment.
- The EA states that two PEM wetlands were identified adjacent to proposed access routes but then summarily concludes they will not be impacted because culverts already exist beneath the roads. Section 3.4.1 identifies the wetlands as approximately 0.28 and 0.01 acres and notes they are 'unclassified by the National Wetland Inventory,' meaning their functions are poorly characterized, yet Section 3.4.2 dismisses any impact based solely on existing road infrastructure without a functional assessment of those wetlands or any analysis of whether staging and heavy equipment passing repeatedly over those routes will alter hydrology. The agency should commission a functional assessment of the two PEM wetlands, disclose results during the comment period, and incorporate findings into the effects analysis before issuing a FONSI.
- The SCC Plan Consistency Report lists five species of conservation concern requiring analysis, but the introductory text of Appendix 5 contains an internal inconsistency: it states 'the following three SCC species are known to occur or have suitable habitat within the project area' yet immediately names five species. This clerical error suggests the analysis was not thoroughly reviewed and raises the question of whether all five species received the full habitat and effects evaluation required by the 2022 Forest Plan and the 2012 Planning Rule. The agency should correct and re-release the SCC analysis with a clear, verified species list and confirm that each listed species received a complete effects review before the comment period closes.
- The EA relies on an approximately 30-year-old Master Development Plan to establish the project's consistency with SSF's long-term vision, yet never analyzes whether the 1997 MDP anticipated climate-adjusted snowmaking demand, the scale of the proposed 4.6-million-gallon tank, or current Tribal consultation obligations. Section 1.2 states that 'SSF completed a master development plan (MDP) in 1997 to identify existing and desired conditions' and that this EA 'analyzes improvements consistent with goals and objectives in the 1997 MDP.' An outdated planning document cannot substitute for current site-specific analysis under NEPA; the agency should identify which specific 1997 MDP goals are being implemented, explain whether those goals remain current given changed conditions, and provide that justification for public review.
- The EA dismisses downstream irrigator impacts without analyzing the timing effect of the new storage tank on the Rio en Medio during the snowmelt period. Table 1.4-2 states that 'water would not be diverted directly from the Rio en Medio during acequia irrigation season as this does not coincide with snowmaking operation periods,' but the tank holds up to 14 AF that will melt out during spring, and the EA never analyzes whether concentrating snowmelt from a larger artificial snowpack in one area of the watershed changes the timing or volume of spring flows that downstream acequia users depend on. The agency should model snowmelt return-flow timing from the expanded snowmaking footprint and disclose the results to downstream water users and acequia associations before the comment period closes.
- The EA's nine-acre staging area is described as temporary disturbance but receives no effects analysis in the watershed, soils, or wildlife sections, even though staging occurs in the base-area parking lots and several other mapped areas that may be near sensitive features. Section 2.1.2 states that 'staging areas include approximately nine acres of temporary disturbance' and that all areas will be revegetated post-construction, but Chapter 3 never identifies where these nine acres fall relative to wetlands, stream riparian management zones, or summer recreation trails, and provides no quantified erosion or compaction analysis for the staging footprint. The agency should map each staging area against resource features, assess erosion and compaction risk for each, and incorporate that analysis into the EA before a final decision is made.
- 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
Ski Santa Fe is proposing to modernize and expand its snowmaking system through additional water storage, new and upgraded snowmaking infrastructure, and associated terrain improvements to improve snowmaking efficiency and reliability.
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 EA relies on an approximately 30-year-old Master Development Plan to establish the project's consistency with SSF's long-term vision, yet never analyzes whether the 1997 MDP anticipated climate-ad
The EA relies on an approximately 30-year-old Master Development Plan to establish the project's consistency with SSF's long-term vision, yet never analyzes whether the 1997 MDP anticipated climate-adjusted snowmaking demand, the scale of the proposed 4.6-million-gallon tank, or current Tribal consultation obligations. Section 1.2 states that 'SSF completed a master development plan (MDP) in 1997 to identify existing and desired conditions' and that this EA 'analyzes improvements consistent with goals and objectives in the 1997 MDP.' An outdated planning document cannot substitute for current site-specific analysis under NEPA; the agency should identify which specific 1997 MDP goals are being implemented, explain whether those goals remain current given changed conditions, and provide that justification for public review.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that two PEM wetlands were identified adjacent to proposed access routes but then summarily concludes they will not be impacted because culverts already exist beneath the roads.
The EA states that two PEM wetlands were identified adjacent to proposed access routes but then summarily concludes they will not be impacted because culverts already exist beneath the roads. Section 3.4.1 identifies the wetlands as approximately 0.28 and 0.01 acres and notes they are 'unclassified by the National Wetland Inventory,' meaning their functions are poorly characterized, yet Section 3.4.2 dismisses any impact based solely on existing road infrastructure without a functional assessment of those wetlands or any analysis of whether staging and heavy equipment passing repeatedly over those routes will alter hydrology. The agency should commission a functional assessment of the two PEM wetlands, disclose results during the comment period, and incorporate findings into the effects analysis before issuing a FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges the Rio Nambé watershed is already rated 'functioning at risk' but never analyzes whether adding 4.6 million gallons of storage capacity and up to four acres of terrain grading on
The EA acknowledges the Rio Nambé watershed is already rated 'functioning at risk' but never analyzes whether adding 4.6 million gallons of storage capacity and up to four acres of terrain grading on a watershed already under stress could push it from 'functioning at risk' to 'impaired.' Section 3.4.1 cites the Watershed Condition Framework rating of 'functioning at risk' and separately notes that soil condition is rated 'fair,' yet Section 3.4.2 concludes with no adverse long-term effects without explaining how two additional ground-disturbance footprints are consistent with stabilizing an already stressed watershed. The agency should analyze the cumulative loading on the Rio Nambé watershed explicitly against the Watershed Condition Framework thresholds and justify the FONSI in light of the pre-existing 'functioning at risk' classification.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA eliminates the no-tank alternative from detailed analysis on the grounds that SSF itself said it would not proceed without the tank, effectively letting the permit applicant define the range of
The EA eliminates the no-tank alternative from detailed analysis on the grounds that SSF itself said it would not proceed without the tank, effectively letting the permit applicant define the range of alternatives. Section 2.2.1 states the alternative was eliminated because 'the proponent considered this alternative but determined that the action would be dropped without the tank.' NEPA requires the agency, not the applicant, to define a reasonable range of alternatives; deferring that judgment to SSF's business preference does not constitute the independent analysis required by law. The agency should analyze the no-tank alternative in full, or document with its own evidence why no purpose-and-need-meeting configuration exists without the tank, and provide that analysis for public comment.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe SCC Plan Consistency Report lists five species of conservation concern requiring analysis, but the introductory text of Appendix 5 contains an internal inconsistency: it states 'the following thre
The SCC Plan Consistency Report lists five species of conservation concern requiring analysis, but the introductory text of Appendix 5 contains an internal inconsistency: it states 'the following three SCC species are known to occur or have suitable habitat within the project area' yet immediately names five species. This clerical error suggests the analysis was not thoroughly reviewed and raises the question of whether all five species received the full habitat and effects evaluation required by the 2022 Forest Plan and the 2012 Planning Rule. The agency should correct and re-release the SCC analysis with a clear, verified species list and confirm that each listed species received a complete effects review before the comment period closes.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses downstream irrigator impacts without analyzing the timing effect of the new storage tank on the Rio en Medio during the snowmelt period.
The EA dismisses downstream irrigator impacts without analyzing the timing effect of the new storage tank on the Rio en Medio during the snowmelt period. Table 1.4-2 states that 'water would not be diverted directly from the Rio en Medio during acequia irrigation season as this does not coincide with snowmaking operation periods,' but the tank holds up to 14 AF that will melt out during spring, and the EA never analyzes whether concentrating snowmelt from a larger artificial snowpack in one area of the watershed changes the timing or volume of spring flows that downstream acequia users depend on. The agency should model snowmelt return-flow timing from the expanded snowmaking footprint and disclose the results to downstream water users and acequia associations before the comment period closes.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses climate-driven water availability as a concern without analyzing how a warming, drying climate undermines the core purpose of the project.
The EA dismisses climate-driven water availability as a concern without analyzing how a warming, drying climate undermines the core purpose of the project. Section 3.4.1 states that 'winter snowfall could shift to rain as increases in temperatures continue' and that 'the overall increase in temperature and shift in precipitation type could result in shorter snow seasons,' yet Section 3.4.2 treats these risks as uncertain background noise and performs no analysis of whether the new tank and pipe infrastructure will remain operationally useful or financially justified under reduced snowmaking windows. The agency should either prepare a full EIS that models project utility under projected climate scenarios or, at minimum, supplement the EA with a quantitative analysis of how climate trends affect the purpose-and-need rationale before approving this infrastructure.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's nine-acre staging area is described as temporary disturbance but receives no effects analysis in the watershed, soils, or wildlife sections, even though staging occurs in the base-area parkin
The EA's nine-acre staging area is described as temporary disturbance but receives no effects analysis in the watershed, soils, or wildlife sections, even though staging occurs in the base-area parking lots and several other mapped areas that may be near sensitive features. Section 2.1.2 states that 'staging areas include approximately nine acres of temporary disturbance' and that all areas will be revegetated post-construction, but Chapter 3 never identifies where these nine acres fall relative to wetlands, stream riparian management zones, or summer recreation trails, and provides no quantified erosion or compaction analysis for the staging footprint. The agency should map each staging area against resource features, assess erosion and compaction risk for each, and incorporate that analysis into the EA before a final decision is made.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe water-loss range cited in the EA is enormous and the agency never explains which end of the range applies here, yet consumptive-use compliance depends on an accurate loss figure.
The water-loss range cited in the EA is enormous and the agency never explains which end of the range applies here, yet consumptive-use compliance depends on an accurate loss figure. Section 2.1.2 states that 'the 1985 site study estimated physical evaporation and sublimation losses of 9.8 percent, while more recent studies report losses of approximately 7 to 35 percent depending on meteorological conditions.' A swing from 7 to 35 percent on 69.72 AF of authorized diversion means consumptive use could range from roughly 5 to 24 AF annually, yet the EA simply repeats the permitted consumptive-use figure of 16.39 AF without reconciling it against the more recent, higher-loss research. The agency should incorporate the most current loss-rate data into the water sufficiency analysis and demonstrate that authorized consumptive use will not be exceeded under the higher loss scenarios enabled by the expanded tank capacity.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Pueblos of San Ildefonso and Tesuque were not present at the first consultation meeting because of prior commitments, and the EA confirms that Section 106 consultation is still incomplete at the t
The Pueblos of San Ildefonso and Tesuque were not present at the first consultation meeting because of prior commitments, and the EA confirms that Section 106 consultation is still incomplete at the time of public comment. Section 3.2.2 states 'The Forest Service will complete Section 106 consultation before authorizing project implementation,' meaning the public is being asked to comment on a project whose consultation record is open and whose effects on a National Register-eligible Traditional Cultural Property have not been fully resolved. Authorizing the project before completing Section 106 violates the sequence required by 36 CFR 800; the agency should extend the comment period, release the completed Section 106 record for public review, and not issue a Decision Notice until all consulting tribes have formally concurred or the process has otherwise concluded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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