Las Vegas-Area Ski Resort Expansion Plans

Final Environmental Impact Statement:
Lee Canyon Ski Area Master Development Plan

Phase I
Prepared by:
US Department of Agriculture – Forest Service
Humboldt-Toiyabe National Forest
With the assistance of:

Cirrus Ecological Solutions, LC
Logan, UT
November 2019
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LEE CANYON SKI AREA MASTER DEVELOPMENT PLAN
PHASE I FINAL ENVIRONMENTAL IMPACT STATEMENT
CLARK COUNTY, NEVADA
Lead Agency: USDA Forest Service

Responsible Official: William A. Dunkelberger, Forest Supervisor
Humboldt-Toiyabe National Forest
1200 Franklin Way
Sparks, Nevada 89431
Information Contact: Jonathan Stein, Interdisciplinary Team Manager
Spring Mountains National Recreation Area
4701 North Torrey Pines Drive
Las Vegas, Nevada 89130
(702) 515-5418
Abstract: The Spring Mountains National Recreation Area, Humboldt-Toiyabe National Forest (HTNF),
proposes to authorize Lee Canyon ski area, which operates under Forest Service special use permit, to
implement Phase 1 of the ski area’s accepted master development plan. Elements of the Phase 1 project are
intended to update and renovate ski area infrastructure, improve capacity balance on several levels, and
provide year-round recreational opportunities. Three alternatives including the required no-action
alternative, the proposed action, and the Bristlecone Trail alternative, were developed and analyzed to
provide a range of options for development at the ski area. The preferred alternative is the Bristlecone Trail
alternative. Under this alternative, proposed infrastructure would be shifted away from a popular multi-
purpose trail, the Bristlecone Trail, in order to minimize impacts on trail users. This alternative would still
meet the purposes and needs addressed by the proposed action.
Opportunity to Object: This project is subject to objection pursuant to 36 CFR 218, Subparts A and B.
Only those individuals or organizations who submitted timely, specific, written comments during a public
comment period are eligible to file an objection. Incorporation of documents by reference in the objection
is permitted only as provided for at 36 CFR 218.8(b). Minimum content requirements of an objection (36
CFR 218.8) include (1) Objector’s name and address with a telephone number if available, with signature
or other verification of authorship supplied upon request; (2) Identification of the lead objector when
multiple names are listed, along with verification upon request; (3) names of the project, responsible
official, and national forest/ranger district of project, and (4) sufficient narrative description of those aspects
of the proposed project objected to, specific issues related to the project, and suggested remedies which
would resolve the objection.
How to Object and Timeframe: Written objections, including any attachments, must be sent via regular
mail, fax, email, hand-delivery, or express delivery to Objection Reviewing Officer, USDA-Forest Service
Intermountain Region, 324 25th Street, Ogden, UT 84401 within 45 days following the publication date of
the legal notice in the Reno Gazette-Journal.
Information about this EIS will be posted on the internet at:
https://www.fs.usda.gov/project/?project=50649
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Final Environmental Impact Statement Lee Canyon Ski Area MDP Phase I
EXECUTIVE SUMMARY
INTRODUCTION
On December 6, 2016, the Humboldt-Toiyabe National Forest (HTNF) received a proposal from Lee
Canyon ski area (Lee Canyon), requesting authorization to implement Phase 1 of improvements included
in their master development plan (MDP). Lee Canyon operates entirely on National Forest System (NFS)
land, so all the proposed infrastructural improvements require Forest Service approval prior to
implementation. As this project (hereafter referred to as the proposed action) would have the potential to
impact the human environment, it is subject to review in accordance with the National Environmental
Policy Act (NEPA). This environmental impact statement (EIS) documents that review. Based on this EIS
and associated documentation, the responsible official will determine whether, and under what conditions,
the Forest Service will authorize this project or any of its elements.
Lee Canyon is located in the Spring Mountains National Recreation Area (SMNRA), 30 miles northwest
of Las Vegas, Nevada, in Clark County, T19S, R56E, Sections 10, 11, 14, 15, 16, 21, and 22.
The Land and Resource Management Plan, Toiyabe National Forest, as amended (including the General
Management Plan [GMP] for the SMNRA, hereafter referred to collectively as the Forest Plan), provides
primary guidance for management of HTNF resources, including those within the ski area (Forest Service
1986a).
PROPOSED ACTION
The proposed action includes the following elements:
Lifts and Ski Runs:
• Lift 4: A new carpet lift along the skier’s left edge of the Rabbit Peak run.
• Chair 5 pod: A new fixed-grip quad chairlift on the slope east of the existing beginner area, with
three new novice-level ski runs and a conveyor lift (Lift 6) from the bottom of Chair 3 to the bottom
of Chair 5.
• Chair 8 pod: A new fixed-grip quad chairlift accessing several new higher-elevation novice-to-
intermediate ski runs southwest of Chair 2.
• Glading (i.e., selective tree removal to open dense forest patches) between Chairs 1 and 5, above
the snow-making pond, and between Chairs 2 and 8.
Snowmaking Coverage:
• Additional snowmaking lines and a pump house.
Summer Activities:
• Mountain coaster.
• Hiking trail.
• Mountain bike trail system.
• Zip line.
Facilities:
• Equipment rental/food & beverage building at the upper base area.
• First aid/ski patrol building near the bottom of the new Lift 4.
• Vault toilet facility at the overflow parking lot.
• Parking lot below the beginner area.
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• Gate house on the access road.

• Culinary water tank near the snowmaking reservoir.
Project-specific Forest Plan Amendment:

• Forest Plan amendment exempting the project from standards 0.31 and 11.57.
PURPOSE AND NEED

Two main factors underlie the purpose and need for action at Lee Canyon: the length of time since the ski
area’s facilities have been upgraded and emerging trends in ski-area recreation.
Lee Canyon has been operating under Forest Service permit since 1964. The permitted area comprises 785
acres. Incremental improvements have been made over time, but over the past two decades the ski area has
fallen behind in developing and maintaining the infrastructure required in today’s recreation market. The
goals of Lee Canyon’s MDP are to modernize the ski area and develop underutilized portions of the permit
area.
Regarding emerging recreation trends, extensive customer surveys conducted by Lee Canyon and other ski
areas indicate that visitors are increasingly seeking a more diverse range of recreational activities,
particularly for families, that includes year-round opportunities and more adventurous options.
Reflecting these two factors, the purpose and need for the proposed action are to:
• Update and renovate ski area infrastructure, particularly run-down base facilities, to meet current
standards and the expectations of today’s recreation market.
• Improve balance on several levels: between lift and run capacity, between on-mountain and base-
area capacity, and between overall ski area capacity and growing recreational demand from Las
Vegas and the surrounding area.
• Develop year-round recreational opportunities to meet increasing demand by recreationists of
various types and skill levels.
Review of the Forest Plan indicated the need to amend two standards, on a project-specific basis, to bring
the proposed action and alternatives other than the no-action alternative into compliance. The proposed
action could not be revised, or an alternative developed, in a way that complied with these standards and
still met the stated purpose and need for action.
DECISIONS TO BE MADE
In consideration of the stated purpose and need and the analysis of environmental effects documented in
this EIS, the responsible official will review the proposed action and alternatives in order to make the
following decisions:
• Whether to authorize the proposed action or an alternative, including the required no-action
alternative, all or in part;
• What design criteria and mitigation measures to require as a condition of the authorization;
• What evaluation methods and documentation to require for monitoring project implementation and
mitigation effectiveness; and
• Whether to authorize a project-specific Forest Plan amendment exempting the project from
standards 0.31 and 11.57.
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RELATIONSHIP TO THE FOREST PLAN

The Forest Plan provides primary guidance for management of HTNF resources, including those within the
ski area permit boundary (Forest Service 1986a). The Forest Plan indicates that the ski area lies within
management area (MA), MA 11 – Developed Canyons, which is subject to MA-specific standards and
guidelines as well as SMNRA-wide direction and some Forest-wide and standards and guidelines.
The Forest Plan directs how recreation factors into SMNRA management activities, recognizing that
recreation use of the Forest and the SMNRA is extremely high. The Forest Plan includes this Forest-wide
goal: “The Toiyabe will increase the quality and quantity of developed and dispersed recreation
opportunities with particular emphasis in the Sierra Nevada and the Spring Mountains of southern Nevada”
(p. IV-1).
When the Forest Plan was written, the SMNRA accounted for nearly 22 percent of recreation visitor-days
on the Forest. A decade later, the GMP recognized the SMNRA’s unique resources as the management
priority, listing the following SMNRA-wide goals. The proposed action serves, in part, to implement these
goals and associated objectives:
• Conserve the health, diversity, integrity, and beauty of the ecosystem.
• Protect American Indian cultural uses and heritage resources.
• Avoid disruptions to current uses and users of the Spring Mountains.
• Where consistent with the above, provide additional opportunities for recreation.
Supporting these SMNRA-wide goals, objective 0.43 is to “Manage lands within the SMNRA to provide a
range of developed recreation opportunities, with an emphasis on opportunities not available on private
lands.”
This direction carries over to MA 11 with this objective: “(11.7) Manage the area for a variety of high
quality, public recreational activities for both summer and winter, with an emphasis on those that are not
available on private lands” and this desired future condition (p. 28) “The ski area is providing additional
winter recreation opportunities (p. 31).”
PUBLIC INVOLVEMENT
The scoping period began on March 23, 2017, when a notice of intent to prepare an environmental impact
statement (NOI) was published in the Federal Register (Vol. 82, No. 55, p. 14865). The scoping period
closed 45 days later on May 8, 2017. Comment letters were received from five agencies, six organizations,
and 89 individuals (including multiple letters from single individuals). The issues identified for in-depth
analysis are indicated below in Table S-1.
Following completion of the Draft EIS, a Notice of Availability (NOA) was published in the Federal
Register on August 17, 2018, initiating a 45-day comment period, in accordance with 36 CFR 218 Sub-
parts A and B. Comments were received from 9 agencies, 8 organizations, and 344 individuals. A report
was prepared identifying commenters, detailing the comments received, and providing HTNF responses to
substantive comments.
ALTERNATIVES
NEPA mandates that an EIS address a reasonable range of alternatives to the proposed action. An EIS must
address the alternative of no action to provide a benchmark for comparison of the magnitude of
environmental effects of the proposed action and action alternatives. Action alternatives should achieve the
same purpose and need, and they should include alternatives that address issues raised and avoid or
otherwise mitigate adverse environmental effects associated with the proposed action.
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No-Action Alternative
The no-action alternative is defined as maintaining the status quo in terms of infrastructural development
at Lee Canyon. Under this alternative, current operations would continue but no further development would
occur.
Bristlecone Trail Alternative

The popular Bristlecone Trail (BCT), a multi-use Forest Service trail, passes through a less developed
portion of the ski area. Reflecting concern over impacts on the recreational experience of BCT users, this
alternative (the BCT alternative) moves several elements of the proposed action away from the trail.
Specifically, this alternative makes adjustments to four elements of the proposed action:
• Chair 8 pod.
• Snowmaking system.
• Zip line.
All other elements of the proposed action not listed above, including the project-specific Forest Plan
amendment, are included in this alternative unchanged from the proposed action.
COMPARISON OF ENVIRONMENTAL EFFECTS

Table S-1 summarizes and compares the direct and indirect environmental effects of the proposed action
and alternatives.
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Table S-1. Summary and comparison of environmental effects.

Issue No-Action Alternative Proposed Action BCT Alternative
Soil, Water, and Watershed Resources:
Issue 1 – Stormwater Runoff: No change from current The proposed action would initially result in a Under all modeled scenarios, peak runoff
How would the proposed conditions would occur under small increase in peak runoff for the 25- and 100- under the BCT alternative would be 1–5
infrastructure affect the this alternative. Intense summer year storms and a substantial reduction in peak percent lower than the proposed action.
timing, intensity, and quantity storms would continue to cause runoff for the most common 2-year storm. Once Therefore, the potential for downslope
of stormwater runoff? downslope flooding. disturbed areas were fully rehabilitated, peak flooding would be further reduced
runoff would be reduced below no-action relative to the proposed action.
alternative levels for all modeled storms. Under
most modeled scenarios, and all long-term
modeled scenarios, potential for downslope
flooding would be reduced relative to the no-
action alternative.
Issue 2 – Soil Erosion and No change from current Due to the highly erosive nature of the soils in the Relative to the proposed action, this
Stability: How would the conditions would occur under area, the proposed 129.8 acres of disturbance alternative would cause 8.6 acres less
proposed infrastructural this alternative. Intense summer would cause erosion potential to increase in the surface disturbance. Because of this
development affect the extent storms would continue to cause short-term relative to the no-action alternative. Ski reduction in total surface disturbance, the
and severity of soil erosion? erosion. runs in the Chair 5 and Chair 8 pods would retain a short-term increase in erosion potential
moderate erosion potential rating until and the acreage rated as moderate before
revegetation occurred, when their rating would fall revegetation would be reduced.
to low.
Issue 3 – Snow Accumulation No tree cutting would occur Relative to the no-action alternative, the clearing Relative to the proposed action, this
and Snowmelt: How would under this alternative, and there or glading of 92.7 acres of trees would represent alternative would reduce the area
tree removal affect the would be no change with regard an approximately 9 percent reduction in forest subjected to clearing and increase the area
timing, rate, and quantity of to snowmelt. cover for the ski area subwatershed. The small subjected to glading for a total of 107
snowmelt? magnitude of this change would make effects on acres of clearing and glading. Overall, the
snowmelt patterns undetectable in the context of impacts at the watershed level would be
watershed behavior. similar to the proposed action.
Vegetation:
Issue 1 – Special-status Since there would be no ground- The proposed action would have no impact on Relative to the proposed action the
Species: How would the disturbing or habitat-altering rough angelica, Charleston pussytoes, Spring amount of impacted habitat for all species
proposed infrastructure affect elements under this alternative, Mountains rockcress, upswept moonwort, dainty would be reduced but the determinations
special-status plant species? there would be no impact on moonwort, slender moonwort, moosewort, would remain the same for all species
Forest Sensitive species, Wasatch draba, Jaeger’s draba, Charleston, other than Clokey’s eggvetch.
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Table S-1 (cont’d). Summary and comparison of environmental effects.

Management indicator species Mountain draba, Nevada willowherb, Clokey’s Impacts on Clokey’s eggvetch would be
(MIS), Conservation Agreement greasebush, Jaeger’s ivesia, Jaeger’s beardtongue substantially reduced relative to the
for the Spring Mountains Charleston tansy, Charleston Mountain kittentails, proposed action, and the determination
National Recreation Area – Charleston violet, or Lemmon’s rubberweed, for this species would be: may impact
Clark and Nye Counties, Nevada because no occupied habitat for these species individuals but it not likely to cause a
(CA) species of concern, or would be disturbed directly or indirectly. trend toward federal listing or loss of
Clark County Multiple Species The proposed action may impact individuals but is viability.
Habitat Conservation Plan not likely to cause a trend toward federal listing or
(MSHCP) covered species. loss of viability of King’s rosy sandwort,
Charleston Mountain goldenbush, Hitchcock’s
bladderpod, Charleston beardtongue, Charleston
ground-daisy, Clokey’s paintbrush, quaking aspen,
Clokey’s thistle, Clokey’s mountain sage, inch
high fleabane, and Charleston pinewood lousewort
because occupied habitat is present for these
species in the proposed action disturbance area.
The proposed action may impact individuals and
may cause a trend toward federal listing or loss of
viability of Clokey’s eggvetch. The observed
numerical and spatial variation in the population
make the magnitude of potential impact difficult to
accurately assess.
Issue 2: Invasive Species: No change from current Occurrences of three invasive plant species Relative to the proposed action, the
How would the proposed conditions would occur under (prostrate knotweed, African mustard, and acreage of disturbance within prostrate
infrastructural development this alternative. The ski area common mullein) overlap the disturbance area for knotweed populations would grow, due
affect the introduction and would treat existing weed the proposed action. Risk assessment for elements primarily to relocation of the mountain
spread of noxious and non- infestations with the objective of of the proposed action identified several elements coaster. The mountain coaster risk rating
native invasive species? either controlling or eradicating as having moderate risk for spread of undesirable would increase from none to low, so the
known occurrences, consistent plant species. Implementation of BMPs and mountain coaster project could still
with the terms of their special monitoring, with control treatments initiated on proceed as planned, with control
use permit. any undesirable plant populations that establish in treatments initiated on any undesirable
the area, would be required for these elements. plant populations that establish in the
These measures should effectively control invasive area.
species.
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Wildlife:
Issue – Special-status Since there would be no ground- The proposed action may affect and is likely to Relative to the proposed action the
Species: How would the disturbing or habitat-altering adversely affect the Mount Charleston blue amount of impacted habitat for all species
proposed infrastructural elements of this alternative, there butterfly (MCBB) because habitat is present in the would be reduced under this alternative
development affect special- would be no impact on Forest disturbance area and short-term effects are likely but the determinations would remain the
status wildlife species? Service sensitive species, MIS, to be detrimental. Beneficial habitat effects are same for all species.
CA species of concern, or possible as natural forb communities are re-
MSHCP covered species. established in previously forested areas.
The proposed action would have no impact on
spotted bats because no roosting habitat would be
impacted, and the value of the area as foraging
habitat would not be changed.
The proposed action may impact individuals but is
not likely to result in a trend toward federal listing
or loss of viability for the following species:
Spring Mountains dark blue butterfly, Morand’s
checkerspot, Spring Mountains icarioides blue
butterfly, pale Townsend’s big-eared bat, northern
goshawk, peregrine falcon, flammulated owl,
Spring Mountains comma skipper, Charleston ant,
Nevada admiral, Carole’s silverspot, western
small-footed myotis, long-eared myotis, long-
legged myotis, fringed myotis, and silver-haired
bat because habitat is present for these species in
the proposed action disturbance area but impacts
are not substantial relative to available habitat in
the area.
The proposed action would not alter the existing
trend for Forest-level populations of Palmer’s
chipmunk or brown-headed cowbird on the Forest
because habitat for Palmer’s chipmunks is
ubiquitous and brown-headed cowbirds are rare in
the project area, a positive indicator.
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Cultural Resources:
Issue 1 – Historic Properties: The identified prehistoric site is No direct impact on the prehistoric site would Same as proposed action.
How would proposed not in an area impacted by occur because no proposed project elements are in
construction disturbance current ski area operations or the area. Additional dispersed use of upper Lee
affect cultural sites in the activities but is being impacted Canyon spurred by new summer activities at the
area? by dispersed recreation use in ski area could potentially result in indirect effects,
upper Lee Canyon. but recommended mitigation is anticipated to
avoid any adverse effect on the site.
Issue 2 – Historic Integrity of No historic properties from the Same as no-action alternative. Same as proposed action.
the Ski Area: How would the ski area’s early years exist, so its
proposed infrastructure affect historic integrity has been lost.
the historic integrity of the
ski area?
Issue 3 – Native American Tribal involvement in ski area Analysis of the proposed action included active Generally the same as proposed action,
Concerns: How would the operations would remain participation with the Nuwuvi Working Group in but relocation of the mountain coaster and
proposed construction and negligible. Physical and less identifying and assessing cultural concerns and zip line, and shifting pod 8 development
increased human activity tangible impacts of ski area developing responsive mitigation. These efforts set up slope, away from the BCT, would
affect Tribal cultural operations on Nuwuvi culture the stage for increased recognition of Nuwuvi reduce the effects of visitor numbers,
concerns for the area as a and cultural values would culture and its relationship to the Spring ground disturbance, tree removal, visual
whole or for specific continue due to lack of Mountains. Nevertheless, cumulative impacts due impact, and noise on this culturally
traditional cultural places awareness of these people and to increased visitation and development without sensitive area.
(TCP)? their relationship with the Spring cultural awareness are substantial. Design criteria
Mountains. in place would prevent any impacts on unknown
cultural resources.
Scenery Resources:
Issue – Scenic Integrity: How No development would occur at Bringing the BEIG into effect would improve This alternative would reduce the visual
would the proposed the ski area under this integration of the built and natural environments impact of the zip line, mountain coaster,
infrastructure alter the alternative. However, Built under the proposed action, but not to a large and Chair 8 pod on BCT users, but these
landscape and affect the Environment Image Guide degree. changes would not alter the conclusions
area’s scenic integrity? (BEIG) criteria would not be The lower and mid-mountain base areas would regarding VQO or ROS relative to the
met, retaining the built continue to be consistent with the VQO of proposed action.
environment’s departure from Modification, but a positive trend would be All other impacts would be the same as
the natural landscape. established due to implementation of the BEIG. the proposed action.
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The mid-mountain and lower The proposed on-mountain infrastructure would, in
base areas would remain general, be more of the same type of development
consistent with the VQO of currently evident at the ski area. The greater extent
Modification that best matches would be offset in part by the design criteria
current baseline conditions, and identified to reduce contrast with the natural
the rest of the ski area would setting. These additions would result in an
meet the VQO of Partial acceptable degree of change from the natural
Retention. landscape, consistent with the VQO of Partial
The base areas would also Retention.
continue to reflect the Rural Regarding ROS classifications, the base areas
ROS criteria, as current would continue to reflect the Rural classification.
conditions do, and the remainder The slopes above would remain consistent with the
of the permit would retain Roaded Natural classification.
Roaded Natural characteristics.
Recreation:
Issue 1 – Impacts on BCT No change from current In terms of impacts on the trail’s viewscape, the Under this alternative, most summer
Users: How would the conditions would occur under main impacts would be associated with proposed infrastructure would be moved away from
proposed infrastructure affect this alternative, except that summer recreation infrastructure. This the BCT where it would be less visible
the recreational experience population growth may increase infrastructure would be in use during the same and disruptive to BCT users. The Chair 8
provided by the BCT? trail use over time. season that BCT use peaks, adding to its impact. pod would be shortened, moving ski runs
Sounds from the mountain coaster would reach and lifts away from the BCT.
noticeable levels on large segments of the BCT. Relative to the proposed action, noise
Use of the BCT is projected to increase by levels from the mountain coaster would
approximately 40 to 58 percent, respectively, on be substantially reduced and likely not
weekdays and weekends due to the increased noticeable on the majority of the trail.
number of people visiting the ski area during the Increased use of the BCT in summer
summer. under this alternative would be similar to
During winter, the introduction of snowcats and the proposed action.
downhill skiers on the trail section shared by the The winter trail user interaction level
Chair 8 access road/skiway might not be strictly would be reduced back to no-action
incompatible given the trail’s multi-use alternative levels under this alternative
designation, but it would certainly alter the due to shifting the Chair 8 pod egress
experience of winter trail users. upslope.
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Issue 2 - Climate Change and No development would occur Expanded snowmaking capability and new Same as proposed action.
Ski Area Viability: How under this alternative, and the ski summer activities under the proposed action would
would climate change affect area would remain vulnerable to help the ski area adapt to future climate change.
the future viability of this the impacts of climate change.
area as a winter recreation
site?
Safety:
Issue 1 – Collision Hazard: No change from current The proposed action would create mountain bike Under this alternative, summer trail
How would the proposed conditions would occur under trails crossing the BCT in summer and downhill collision risk would be the same as the
infrastructure affect collision this alternative, except that skier traffic on the lower BCT in the winter. Both proposed action.
hazards for trail and ski run population growth may increase could result in collisions with BCT users. In the winter, relocation of the Chair 8
users? trail use and associated conflicts Implementation of mitigation measures for trail pod egress further upslope, collision risk
over time. intersections would reduce the risk potential in would be similar to the levels under the
summer, to levels similar to the no-action no-action alternative.
alternative. However, the potential for winter
collisions would increase due to a portion of the
BCT being used as the egress route for the Chair 8
pod.
Issue 2 – Emergency No change from current Under the proposed action, the new ski patrol/first Same as proposed action.
Services: How would conditions would occur under aid building and associated staff would provide
visitation associated with the this alternative, except that substantially improved facilities, including a
proposed infrastructure affect population growth may increase dedicated ambulance-loading area. Ambulance
provision of emergency demand for emergency services. service, provided by Mount Charleston Fire
services? Protection District (MCFPD) or a contract service,
would still be needed to transport more serious
cases to valley medical facilities.
A projected increase of 87 MCFPD responses per
year once buildout of all proposed infrastructure
was complete and peak visitation was reached
(~10 years), would likely tax the existing resources
of the MCFPD. An ambulance may need to be
stationed at the ski area more frequently to provide
timely transportation to Las Vegas medical
facilities. Nevada Department of Transportation
efforts to improve traffic flow on SMNRA
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highways under their management could also
alleviate this issue.
Traffic:
Issue – Traffic Congestion: No change from current Under the proposed action, visitors to the ski area Same as proposed action.
How would winter visitation conditions would occur under would remain an important source of traffic on SR
associated with the proposed this alternative, except that 156 but less important than regional population
infrastructure contribute to regional population growth may growth. The additional parking at the ski area may
traffic congestion on SR 156? increase traffic on SR 156 over reduce parking-related congestion in the upper
time. canyon to some degree, and the proposed
improvements may draw an increasing proportion
of canyon visitors to the ski area.
Land Use:
Issue – Adjacent Land Uses: No change from current With mitigation measures such as signage and Same as proposed action.
How would year-round conditions. Any existing fencing in place, the proposed action would not
visitation associated with the problems related to property result in a substantial increase in the incidence of
proposed infrastructure affect damage or disruption would property damage or disruption at Camp Lee
adjacent land uses? remain. Canyon or McWilliams Campground.
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TABLE OF CONTENTS
Executive Summary .................................................................................................................................. S-1
Introduction ....................................................................................................................................... S-1
Proposed Action ................................................................................................................................ S-1
Purpose and Need ............................................................................................................................. S-2
Decisions to Be Made ....................................................................................................................... S-2
Relationship to the Forest Plan ......................................................................................................... S-3
Public Involvement ........................................................................................................................... S-3
Alternatives ....................................................................................................................................... S-3
No-Action Alternative .................................................................................................................. S-4
Bristlecone Trail Alternative......................................................................................................... S-4
Comparison of Environmental Effects .............................................................................................. S-4
Table of Contents ........................................................................................................................................... i
List of Figures ...................................................................................................................................... vi
List of Tables ...................................................................................................................................... vii
List of Appendices ................................................................................................................................ v
List of Acronyms ............................................................................................................................... viii
Chapter 1: Purpose and Need ........................................................................................................................ 1
1.1 Introduction ............................................................................................................................................. 1
1.2 Organization of Document ...................................................................................................................... 3
1.3 Proposed Action ...................................................................................................................................... 3
1.4 Purpose and Need ................................................................................................................................... 4
1.5 Decisions to be Made .............................................................................................................................. 5
1.6 Relationship to the Forest Plan ............................................................................................................... 5
1.7 Scoping and Identification of Issues ....................................................................................................... 7
1.7.1 Issues Carried into In-depth Analysis .......................................................................................... 7
1.7.1.1 Soil, Water, and Watershed Resources ................................................................................. 7
1.7.1.2 Vegetation ............................................................................................................................. 8
1.7.1.3 Wildlife ................................................................................................................................. 8
1.7.1.4 Cultural Resources ................................................................................................................ 9
1.7.1.5 Scenery Resources ................................................................................................................ 9
1.7.1.6 Recreation ............................................................................................................................. 9
1.7.1.7 Safety .................................................................................................................................. 10
1.7.1.8 Traffic ................................................................................................................................. 10
1.7.1.9 Land Use ............................................................................................................................. 10
1.7.2 Concerns Identified but not Analyzed In Depth ........................................................................ 10
1.7.2.1 Soil, Water, and Watershed Resources ............................................................................... 10
1.7.2.2 Vegetation ........................................................................................................................... 11
1.7.2.3 Wildlife ............................................................................................................................... 11
1.7.2.4 Recreation ........................................................................................................................... 11
1.7.2.5 Socioeconomics .................................................................................................................. 12
1.7.2.6 Litter.................................................................................................................................... 12
1.7.2.7 Wilderness........................................................................................................................... 12
1.7.2.8 Inventoried Roadless Areas ................................................................................................ 12
1.8 Project Record....................................................................................................................................... 13
1.9 Other Permits and Authorizations ......................................................................................................... 13
Chapter 2: Proposed Action and Alternatives ............................................................................................. 15
2.1 Introduction ........................................................................................................................................... 15
i
2.2 Proposed Action .................................................................................................................................... 15

2.2.1 Lifts and Ski Runs ...................................................................................................................... 15
2.2.1.1 Lift 4.................................................................................................................................... 15
2.2.1.2 Chair 5 Pod ......................................................................................................................... 15
2.2.1.3 Chair 8 Pod ......................................................................................................................... 16
2.2.1.4 Tree and Glade Skiing ........................................................................................................ 20
2.2.2 Snowmaking Coverage .............................................................................................................. 20
2.2.3 Summer Activities...................................................................................................................... 20
2.2.3.1 Mountain Coaster ................................................................................................................ 20
2.2.3.2 Mountain Bike Trails .......................................................................................................... 21
2.2.3.3 Hiking Trail......................................................................................................................... 21
2.2.3.4 Zip Line............................................................................................................................... 22
2.2.4 Facilities ..................................................................................................................................... 22
2.2.4.1 Equipment Rental/Food & Beverage Building ................................................................... 22
2.2.4.2 First Aid/Ski Patrol Building .............................................................................................. 22
2.2.4.3 Vault Toilet Facility at Overflow Parking Lot .................................................................... 23
2.2.4.4 New Parking Lot ................................................................................................................. 23
2.2.4.5 Gate House .......................................................................................................................... 23
2.2.4.6 Water Tank.......................................................................................................................... 23
2.2.5 Project-specific Forest Plan Amendment ................................................................................... 23
2.2.6 Timing ........................................................................................................................................ 24
2.3 Alternative Formulation ........................................................................................................................ 24
2.4 Alternatives Analyzed in Depth ............................................................................................................ 24
2.4.1 No-Action Alternative................................................................................................................ 24
2.4.2 Bristlecone Trail Alternative...................................................................................................... 25
2.4.2.1 Chair 8 Pod ......................................................................................................................... 25
2.4.2.2 Tree and Glade Skiing ........................................................................................................ 25
2.4.2.3 Mountain Coaster ................................................................................................................ 25
2.4.2.4 Snowmaking System ........................................................................................................... 27
2.4.2.5 Zip Line............................................................................................................................... 27
2.5 Alternatives Considered but Not Analyzed in Depth ............................................................................ 27
2.5.1 No Development Outside Previously Developed Areas ............................................................ 27
2.5.2 Conservation Alternative ........................................................................................................... 27
2.5.3 Parking Garage........................................................................................................................... 27
2.5.4 Narrower Ski Runs ..................................................................................................................... 27
2.5.5 Winter Only Alternative............................................................................................................. 28
2.5.6 Elimination of Chair 8 Pod ........................................................................................................ 28
2.5.7 No Development East of Chair 2 ............................................................................................... 28
2.5.8 Alternative Location for Vault Toilet ........................................................................................ 28
2.5.9 Cross-Country Mountain Bike Trails ......................................................................................... 29
2.5.10 Alternative Zip Lines ............................................................................................................... 29
2.5.11 Shuttle Service ......................................................................................................................... 29
2.6 Design Criteria and Mitigation Measures ............................................................................................. 29
2.7 Summary and Comparison of Environmental Effects .......................................................................... 31
2.8 Agency’s Preferred Alternative ............................................................................................................ 31
Chapter 3: Affected Environment and Environmental Consequences ........................................................ 39
3.1 Introduction ........................................................................................................................................... 39
3.2 Disturbance Types and Areas ............................................................................................................... 39
3.3 Cumulative Actions .............................................................................................................................. 42
3.4 Soil, Water, and Watershed................................................................................................................... 43
3.4.1 Scope of Analysis....................................................................................................................... 43
ii
3.4.1.1 Background and Methods ................................................................................................... 44

3.4.2 Affected Environment ................................................................................................................ 46
3.4.2.1 Issue 1 – Stormwater Runoff .............................................................................................. 46
3.4.2.2 Issue 2 – Soil Erosion and Stability .................................................................................... 50
3.4.2.3 Issue 3 – Snow Accumulation and Snowmelt ..................................................................... 52
3.4.3 Direct and Indirect Effects ......................................................................................................... 53
3.4.3.1 Alternative 1 – No Action ................................................................................................... 53
3.4.3.2 Proposed Action .................................................................................................................. 54
3.4.3.3 Bristlecone Trail Alternative............................................................................................... 64
3.4.4 Cumulative Effects..................................................................................................................... 68
3.4.4.1 Issue 1 – Stormwater Runoff .............................................................................................. 68
3.4.4.2 Issue 2 – Soil Erosion and Stability .................................................................................... 71
3.4.4.3 Issue 3 – Snow Accumulation and Snowmelt ..................................................................... 71
3.4.5 Mitigation ................................................................................................................................... 72
3.5 Vegetation ............................................................................................................................................. 74
3.5.1 Scope of Analysis....................................................................................................................... 74
3.5.2 Affected Environment ................................................................................................................ 74
3.5.2.1 Special-Status Species ........................................................................................................ 75
3.5.2.2 Invasive Species .................................................................................................................. 86
3.5.3 Direct and Indirect Effects ......................................................................................................... 90
3.5.3.1 No-Action Alternative ........................................................................................................ 90
3.5.3.2 Proposed Action .................................................................................................................. 90
3.5.3.3 Bristlecone Trail Alternative............................................................................................... 96
3.5.4 Cumulative Effects..................................................................................................................... 99
3.5.4.1 Special-Status Species ........................................................................................................ 99
3.5.4.2 Invasive Species ................................................................................................................ 101
3.5.5 Mitigation ................................................................................................................................. 101
3.5.6 Forest Plan Compliance ........................................................................................................... 101
3.6 Wildlife ............................................................................................................................................... 102
3.6.1 Scope of Analysis..................................................................................................................... 102
3.6.2 Affected Environment .............................................................................................................. 102
3.6.2.1 Threatened, Endangered, and Candidate Species ............................................................. 105
3.6.2.2 Forest Service Sensitive Species ....................................................................................... 109
3.6.2.3 Management Indicator Species ......................................................................................... 111
3.6.2.4 Spring Mountains Conservation Agreement Species of Concern ..................................... 112
3.6.2.5 Clark County Multiple Species Habitat Conservation Plan Covered Species .................. 114
3.6.2.6 Migratory Birds ................................................................................................................. 114
3.6.3 Direct and Indirect Effects ....................................................................................................... 114
3.6.3.1 No-Action Alternative ...................................................................................................... 114
3.6.3.2 Proposed Action ................................................................................................................ 114
3.6.3.3 Bristlecone Trail Alternative............................................................................................. 123
3.6.4 Cumulative Effects................................................................................................................... 128
3.6.4.1 Threatened, Endangered, and Candidate Wildlife Species ............................................... 128
3.6.4.2 Forest Sensitive, CA, and MSHCP Covered Wildlife Species ......................................... 129
3.6.4.3 Wildlife Management Indicator Species ........................................................................... 130
3.6.5 Mitigation ................................................................................................................................. 130
3.6.6 Forest Plan Compliance ........................................................................................................... 131
3.7 Cultural Resources .............................................................................................................................. 132
3.7.2.1 Historic Properties ............................................................................................................ 132
3.7.2.2 Historic Integrity of the Ski Area ...................................................................................... 137
iii
3.7.2.3 Native American Concerns ............................................................................................... 138

3.7.3.2 Proposed Action ................................................................................................................ 140
3.7.5 Mitigation ................................................................................................................................. 143
3.7.5.1 Historic Properties ............................................................................................................ 143
3.7.5.2 Native American Concerns ............................................................................................... 143
3.8 Scenery Resources .............................................................................................................................. 143
3.8.1.1 Background and Methods ................................................................................................. 143
3.8.3.2 Proposed Action ................................................................................................................ 148
3.8.5 Mitigation ................................................................................................................................. 150
3.9 Recreation ........................................................................................................................................... 159
3.9.1.1 Background and Methods ................................................................................................. 159
3.9.2.1 Impacts on BCT Users ...................................................................................................... 160
3.9.2.2 Climate Change and Ski Area Viability ............................................................................ 162
3.9.3.2 Proposed Action ................................................................................................................ 163
3.9.5 Mitigation ................................................................................................................................. 166
3.10 Safety ................................................................................................................................................ 166
3.10.1 Scope of Analysis................................................................................................................... 166
3.10.2 Affected Environment ............................................................................................................ 166
3.10.2.1 Collision Hazard ............................................................................................................. 166
3.10.2.2 Emergency Services ........................................................................................................ 167
3.10.3 Direct and Indirect Effects ..................................................................................................... 167
3.10.3.1 No-Action Alternative..................................................................................................... 167
3.10.3.2 Proposed Action .............................................................................................................. 168
3.10.3.3 Bristlecone Trail Alternative ........................................................................................... 169
3.10.4 Cumulative Effects................................................................................................................. 169
3.10.5 Mitigation ............................................................................................................................... 169
3.11 Traffic ............................................................................................................................................... 170
3.11.3.2 Proposed Action .............................................................................................................. 171
3.11.5 Mitigation ............................................................................................................................... 172
3.12 Land Use ........................................................................................................................................... 173
iv

3.12.3.2 Proposed Action .............................................................................................................. 174
3.12.5 Mitigation ............................................................................................................................... 175
3.13 Other Disclosures .............................................................................................................................. 175
3.13.1 Healthy Forest Restoration Act .............................................................................................. 175
3.13.2 Forest Plan Amendment ......................................................................................................... 175
3.13.3 Short-Term Uses and Long-Term Productivity ..................................................................... 175
3.13.4 Unavoidable Adverse Effects................................................................................................. 176
3.13.4.1 Soil, Water, and Watershed Resources ........................................................................... 176
3.13.4.2 Vegetation ....................................................................................................................... 176
3.13.4.3 Wildlife ........................................................................................................................... 177
3.13.3.4 Cultural Resources .......................................................................................................... 177
3.13.4.5 Scenery Resources .......................................................................................................... 177
3.13.4.6 Recreation ....................................................................................................................... 178
3.13.4.7 Safety .............................................................................................................................. 178
3.13.4.8 Traffic ............................................................................................................................. 178
3.13.4.9 Land Use ......................................................................................................................... 179
3.13.5 Irreversible and Irretrievable Commitments of Resources .................................................... 179
3.13.6 Incomplete and Unavailable Information............................................................................... 179
3.13.7 Energy Requirements and Conservation ................................................................................ 179
3.13.8 Pollinators .............................................................................................................................. 180
3.14 Consistence with Laws, Regulations, Policies, and Procedures ....................................................... 180
3.14.1 Endangered Species Act......................................................................................................... 180
3.14.2 Clean Water Act ..................................................................................................................... 180
3.14.3 Americans with Disabilities Act ............................................................................................ 181
3.14.4 Executive Order 11644 - Use of Off-Road Vehicles on Public Lands .................................. 181
3.14.5 Executive Orders 11988 and 11990 - Protection of Floodplains and Wetlands .................... 181
3.14.6 Executive Order 13186 - Protection of Migratory Birds........................................................ 181
3.14.7 Executive Order 12898 - Environmental Justice ................................................................... 182
3.14.8 USDA Civil Rights Policy ..................................................................................................... 182
3.14.9 Prime Farmland, Rangeland, and Forest Land ....................................................................... 182
Chapter 4: List of Preparers ...................................................................................................................... 183
Chapter 5: Consultation and Coordination................................................................................................ 184
5.1 Public Scoping .................................................................................................................................... 184
5.2 Notice and Comment on the Draft EIS ............................................................................................... 185
5.3 Other Consultation .............................................................................................................................. 185
5.3.1 Endangered Species Act Section 7........................................................................................... 185
5.3.2 National Historic Preservation Act Section 106 ...................................................................... 186
5.3.3 Tribal Consultation .................................................................................................................. 186
Chapter 6: References ............................................................................................................................... 187
LIST OF APPENDICES
Appendix A: Forest Service Standards and Guidelines ............................................................................ 195
Appendix B: Mitigation Measures ............................................................................................................ 198
v
Soil, Water, and Watershed............................................................................................................... 198

Vegetation ......................................................................................................................................... 200
Wildlife ............................................................................................................................................. 200
Cultural Resources ............................................................................................................................ 202
Scenic Resources .............................................................................................................................. 202
Recreation ......................................................................................................................................... 202
Safety ................................................................................................................................................ 202
Traffic ............................................................................................................................................... 202
Land Use ........................................................................................................................................... 203
Appendix C: Response to Comments on the Draft EIS ............................................................................ 204
The Comment Process .............................................................................................................................. 204
Results ....................................................................................................................................................... 204
Processing of Comments........................................................................................................................... 221
Comments and Responses......................................................................................................................... 222
Process .............................................................................................................................................. 222
Scope of the Analysis.................................................................................................................... 222
Collaborative Planning.................................................................................................................. 223
Purpose and Need ......................................................................................................................... 223
Proposed Action ............................................................................................................................ 224
Alternatives ................................................................................................................................... 227
Mitigation...................................................................................................................................... 231
Notice and Comment .................................................................................................................... 232
Implementation Schedule.............................................................................................................. 233
Other Permits and Approvals ........................................................................................................ 233
Resource Disciplines ......................................................................................................................... 235
Soil, Water, and Watershed Resources ......................................................................................... 235
Vegetation ..................................................................................................................................... 239
Wildlife ......................................................................................................................................... 242
Cultural Resources ........................................................................................................................ 250
Scenery Resources ........................................................................................................................ 250
Recreation ..................................................................................................................................... 251
Safety ............................................................................................................................................ 252
Traffic and Parking ....................................................................................................................... 257
Air Quality .................................................................................................................................... 260
Opinion ......................................................................................................................................... 261
General .......................................................................................................................................... 261
In Favor ......................................................................................................................................... 261
Opposed ........................................................................................................................................ 265
LIST OF FIGURES
Figure 1-1. Vicinity map. .............................................................................................................................. 2
Figure 2-1. Proposed action – lifts, ski runs, and snowmaking. ................................................................. 17
Figure 2-2. Proposed action – summer activities. ....................................................................................... 18
Figure 2-3. Proposed action – facilities. ..................................................................................................... 19
Figure 2-4. BCT alternative – changes from the proposed action. ............................................................. 26
Figure 3-1. Daily maximum rainfall recorded at Lee Canyon Snow Telemetry (SNOTEL) site.. ............. 47
Figure 3-2. Soil and watershed resources in the permit area. ..................................................................... 49
Figure 3-3. Three viewpoints. ................................................................................................................... 147
Figure 3-4. Viewpoint 1, no-action alternative. ........................................................................................ 151
vi
Figure 3-7. Viewpoint 2, proposed action................................................................................................. 154

Figure 3-8. Viewpoint 3, proposed action................................................................................................. 155
Figure 3-9. Viewpoint 2, Bristlecone Trail alternative. ............................................................................ 156
Figure 3-10. Viewpoint 3, Bristlecone Trail alternative. .......................................................................... 157
LIST OF TABLES
Table S-1. Summary and comparison of environmental effects. .............................................................. S-5
Table 1-1. Permits and approvals that may be required for implementation of the proposed action or an
action alternative. .............................................................................................................. 13
Table 2-1. Summary and comparison of environmental effects. ................................................................ 32
Table 3-1. Typical disturbance dimensions1 by project element type......................................................... 40
Table 3-2. Disturbance types and acres disturbed under the proposed action. ........................................... 40
Table 3-3. Disturbance types and acres disturbed under the BCT alternative. ........................................... 41
Table 3-4. Cumulative actions considered in this analysis. ........................................................................ 42
Table 3-5. Soil properties in the permit area (NRCS 2017c). ..................................................................... 51
Table 3-6. Peak runoff estimates under current conditions from the East, Center, and Bristlecone
drainages (Figure 3-2).1 .................................................................................................... 53
Table 3-7. Landcover in the permit area under existing conditions. ........................................................... 54
Table 3-8. Peak runoff estimates (cubic feet per second) under the proposed action in response to a 24-
hour design storm. 1 .......................................................................................................... 55
Table 3-9. Landcover in the permit area under existing conditions and the proposed action. .................... 56
Table 3-10. Proposed action CDA table. .................................................................................................... 59
Table 3-11. Peak runoff estimates (cubic feet per second) under the proposed action and BCT alternative
in response to a 24-hour design storm. 1 ........................................................................... 65
Table 3-12. Landcover in the permit area under existing conditions, proposed action, and the BCT
alternative.......................................................................................................................... 66
Table 3-13. BCT alternative CDA table (only elements that would change from the proposed action). ... 69
Table 3-14. Special-status plant species1 occurring or suspected to occur on the Spring Mountains
National Recreation Area, Humboldt-Toiyabe National Forest, and their level of analysis
for this project. .................................................................................................................. 76
Table 3-15. Land type association communities in the disturbance area and their associated management
indicator species. ............................................................................................................... 84
Table 3-16. Noxious and non-native invasive plant species occurring on the Spring Mountains National
Recreation Area, Humboldt-Toiyabe National Forest and their level of analysis for this
project. .............................................................................................................................. 88
Table 3-17. Noxious and non-native invasive species risk assessment ratings. ......................................... 89
Table 3-18. Noxious and non-native invasive species risk assessment determinations.............................. 89
Table 3-19. Acres of occupied special-status plant species habitat affected by the proposed action. ........ 91
Table 3-20. Noxious and non-native weed species risk assessment results for the proposed action. ......... 96
Table 3-21. Acres of occupied special-status plant species habitat affected by the BCT alternative. ........ 97
Table 3-22. Special-status species with the potential to occur in the project area. ................................... 103
Table 3-23. Land type association communities in the disturbance area and their associated management
indicator species. ............................................................................................................. 111
Table A-1. Relevant standards and guidelines from HTNF Forest Plan Amendment 5, General
Management Plan for the SMNRA. ................................................................................ 195
vii
LIST OF ACRONYMS
ABAAS Architectural Barriers Act Accessibility Standard
ACDP Air Contaminant Discharge Permit
ADA Americans with Disabilities Act of 1990
BA Biological Assessment
BCR33 Sonoran and Mojave Deserts Bird Conservation Region
BCT Bristlecone Trail
BE Biological Evaluation
BEIG Spring Mountains National Recreation Area Built Environment Image Guide
BMP best management practice
BO biological opinion
BP before present
CA 1998 Conservation Agreement for the Spring Mountains National Recreation Area – Clark
and Nye Counties, Nevada
CDA connected disturbed area
COE U.S. Army Corps of Engineers
EIS environmental impact statement
EMT emergency medical technicians
EPA Environmental Protection Agency
ESA Endangered Species Act
FSM Forest Service Manual
FWS U.S. Fish and Wildlife Service
GMP General Management Plan for the Spring Mountains National Recreation Area,
Amendment 5 to the Land and Resource Management Plan, Toiyabe National Forest
HTNF Humboldt-Toiyabe National Forest
ID Team Interdisciplinary Team
IRA inventoried roadless areas
LOS level of service
LTA land type association
LVSSR Las Vegas Ski and Snowboard Resort
MA management area
MCBB Mount Charleston blue butterfly
MCFPD Mount Charleston Fire Protection District
MDP master development plan
MIS management indicator species
MSHCP Clark County Multiple Species Habitat Conservation Plan
NDEP Nevada Department of Environmental Protection
NEPA National Environmental Policy Act of 1969
NFMA National Forest Management Act
NFS National Forest System
NHPA National Historic Preservation Act
NOA Notice of Availability
NOI Notice of Intent to Prepare an Environmental Impact Statement
NNHP Nevada Natural Heritage Program
NPDES National Pollutant Discharge Elimination System
NRCS USDA Natural Resources Conservation Service
NRHP National Register of Historic Places
NWG Nuwuvi Working Group
permit area ski area’s special use permit area
PFA post fledging-family area
PHTF Pollinator Heath Task Force
pph person-per-hour
viii
RN Roaded Natural
ROD Record of Decision
ROS Recreation Opportunity Spectrum
SHPO State Historic Preservation Office
SMNRA Spring Mountains National Recreation Area
SNOTEL snowpack telemetry
SOPA schedule of proposed actions
SPCC spill prevention, control and countermeasure
SPNM Semi-primitive Non-motorized
SWPPP Storm Water Pollution Prevention Plan
TCP traditional cultural places
TEC threatened, endangered, or candidate
UFAS Uniform Federal Accessibility Standards
VMS Visual Management System
VQO visual quality objective
WUI wildland urban interface
x
xi
CHAPTER 1: PURPOSE AND NEED

1.1 INTRODUCTION
On December 6, 2016, the Humboldt-Toiyabe National Forest (HTNF) received a proposal from Lee
Canyon ski area (Lee Canyon), requesting authorization to implement Phase 1 of improvements included
in their master development plan (MDP). The MDP documents analysis of current conditions at the resort
and, based on that analysis, outlines anticipated development and management of the resort over the next
10 years. The elements of Phase 1 are intended to enhance the year-round recreational opportunities
available at the resort and on the HTNF. They are the result of a collaborative, multi-year process involving
input from Lee Canyon, the Forest Service, and the U.S. Fish and Wildlife Service (FWS; see Chapter 5).
Lee Canyon is located in the Spring Mountains National Recreation Area (SMNRA), 30 miles northwest
of Las Vegas, Nevada (Figure 1-1), in Clark County, T19S, R56E, Sections 10, 11, 14, 15, 16, 21, and 22.
The ski resort operates under a special use permit (permit) issued by the USDA Forest Service (Forest
Service) and administered by the HTNF. The Land and Resource Management Plan, Toiyabe National
Forest, as amended (including the General Management Plan [GMP] for the SMNRA, hereafter referred to
collectively as the Forest Plan; Forest Service 1986a), provides primary guidance for management of HTNF
resources, including those within the ski area. This environmental impact statement (EIS) is tiered to the
Forest Plan, and the associated NEPA analysis is incorporated by reference.
Under the terms of the Ski Area Permit Act of 1986, development and operation of ski areas on National
Forest System (NFS) lands is guided by MDPs, which describe existing conditions, identify physical,
environmental, and socio-economic opportunities and constraints, establish the permittee’s conceptual
vision for the ski area, and outline near-to-long-term plans for achieving that vision. As a condition of
permit issuance, the Forest Service must review and accept, modify, or deny a ski area’s MDP. MDPs are
intended to be dynamic documents, amended or revised periodically to reflect changes in operational
opportunities and constraints, recreation-market demands, or agency management requirements.
One component of an MDP is planned development of the ski area’s physical infrastructure, some or all of
which may lie on NFS land and thus require agency approval. When development plans move from the
conceptual to the concrete realm, the permittee submits a proposal to the Forest Service describing specific
elements that are proposed for implementation, and the agency makes a determination whether to accept
the proposal and initiate our decision-making process. If the proposal has the potential to significantly
impact the human environment, the agency must analyze and disclose those environmental impacts, in
accordance with the National Environmental Policy Act of 1969 (NEPA).
As Lee Canyon operates entirely on NFS land, all the proposed infrastructural improvements require Forest
Service approval prior to implementation. As this project (hereafter referred to as the proposed action) has
the potential to impact the human environment, it is reviewed in this EIS. Based on this EIS and associated
documentation, the responsible official will determine whether, and under what conditions, the Forest
Service will authorize this project or any of its elements.
1
Figure 1-1. Vicinity map.
2
1.2 ORGANIZATION OF DOCUMENT

The HTNF has prepared this EIS in accordance with NEPA and Forest Service regulations regarding its
implementation (36 CFR Part 220). The document is organized as follows:
Chapter 1 – Purpose and Need. This chapter introduces the proposed action and the EIS process.
Specifically, it:
• Summarizes the proposed action.

• Outlines the purpose of and need for action.
• Identifies the decisions to be made on the basis of this EIS.
• Discusses the relationship of the proposed action to the Forest Plan.
• Describes the scoping process and the environmental issues addressed in this EIS.
• Discusses the project record.
• Lists other permits and authorizations that may be required.
Chapter 2 – Proposed Action and Alternatives. This chapter describes the proposed action, including
associated design criteria and mitigation measures, then outlines the alternative formulation process, lists
alternatives considered but not analyzed in depth, describes the alternatives considered in depth, then
summarizes and compares the environmental impacts of the proposed action and alternatives.
Chapter 3 – Affected Environment and Environmental Consequences. This chapter documents the
environmental impact analysis. It is organized by resource area, and each resource section begins with the
issues addressed, as identified through public scoping and internal, interdisciplinary review. The affected
environment is described next to provide context for the discussion of environmental consequences that
follows. The direct, indirect, and cumulative effects of the no-action alternative, proposed action, and the
action alternative are outlined in that order. The section concludes with discussion of other required
disclosures.
Chapter 4 – List of Preparers. This chapter identifies the HTNF and contractor personnel involved in
preparation of this EIS.
Chapter 5 – Consultation and Coordination. This chapter identifies the agencies and other entities consulted
during the development of this EIS.
Chapter 6 – References. This chapter contains an alphabetized list of the documents referenced in this EIS.
Appendices. The appendices provide more detailed information supporting the analyses presented in this
EIS.
Additional documentation is available in the project record available at the SMNRA Office in Las Vegas,
NV. (See section 1.8 below.)
1.3 PROPOSED ACTION

Lee Canyon’s current MDP, Las Vegas Ski and Snowboard Resort Master Development Plan 2011 (Ecosign
2011), was accepted by the HTNF in June 2011. The infrastructural improvements included in the MDP
have the potential to impact NFS resources, and HTNF authorization is required for their implementation.
These improvements, described in detail in section 2.2, comprise the proposed action addressed in this EIS.
They can be summarized as follows:
Lifts and Ski Runs:
• Lift 4: A new carpet lift along the skier’s left edge of the Rabbit Peak run. This would be a portable
installation involving no excavation or permanent structure.
3
• Chair 5 pod: A new fixed-grip quad chairlift on the slope east of the existing beginner area, with
three new novice-level ski runs and a conveyor lift (Lift 6) from the bottom of Chair 3 to the bottom
of Chair 5.
• Chair 8 pod: A new fixed-grip quad chairlift accessing several new higher-elevation novice-to-
intermediate ski runs southwest of Chair 2.
• Glading (i.e., selective tree removal to open dense forest patches) between Chairs 1 and 5, above
the snow-making pond, and between Chairs 2 and 8 to create off-piste (i.e., off cleared and groomed
ski run) skiing opportunities.
Snowmaking Coverage:
• Additional snowmaking lines and a pump house to provide flexibility in snowmaking coverage.
Summer Activities:
• Hiking trail.
• Mountain bike trail system.
• Zip line.
Facilities:
• Equipment rental/food & beverage building at the upper base area.
• First aid/ski patrol building near the bottom of the new Lift 4.
• Vault toilet facility at the overflow parking lot.
• Parking lot below the beginner area.
• Gate house on the access road.
• Culinary water tank near the snowmaking reservoir.
Project-specific Forest Plan Amendment:
• Forest Plan amendment exempting the project from standards 0.31 and 11.57.
All the proposed infrastructural improvements would be within Lee Canyon’s current permit boundary. No
expansion beyond that boundary is proposed.
1.4 PURPOSE AND NEED

Two factors underlie the purpose and need for action at Lee Canyon: the length of time since the ski area’s
facilities have been upgraded and emerging trends in ski-area recreation.
In 1964, the Forest Service issued the first special use permit for Lee Canyon ski area to the Clark County
Board of Commissioners, with two rope tows, a cable ski sled, and a warming hut operated by the Las
Vegas Ski Club. Over the next 20 years, ownership changed and the existing Chair 1 (Sherwood) lift and
lifts in the approximate locations of Chairs 2 and 3 (Bluebird and Rabbit Peak) were constructed. The
existing base-area structures were also built and expanded during this time period. Powdr Corp. acquired
an ownership interest in Lee Canyon in 2004. Since that time Chairs 2 and 3 were replaced and the
snowmaking reservoir was built, but the overall character of the ski area remains dated.
In May 2011, Lee Canyon submitted an MDP to the Forest Service addressing the goals of modernizing the
ski area and developing underutilized portions of the permit area. The Forest Service accepted the MDP in
June of 2011.
4
Regarding emerging recreation trends, extensive customer surveys conducted by Lee Canyon and other ski
areas indicate that visitors are increasingly seeking a more diverse range of recreational activities,
particularly for families, that includes year-round opportunities and more adventurous options. The Forest
Service response to this trend includes our 2012 introduction of the Framework for Sustainable Recreation,
which sets goals for providing a diverse array of recreational opportunities aimed at connecting people with
the outdoors and promoting healthy lifestyles, in partnership with other public and private recreation
providers.
Also, passage of the Ski Area Recreational Opportunity Enhancement Act of 2011 provides direction on
the types of summer activities the Forest Service should consider authorizing to round out the range of
opportunities provided to the public at permitted mountain resorts.
Reflecting these factors, the purpose and need for the proposed action are to:
• Update and renovate ski area infrastructure, particularly run-down base facilities, to meet current
standards and the expectations of today’s recreation market.
• Improve balance on several levels: between lift and run capacity, between on-mountain and base-
area capacity, and between overall ski area capacity and growing recreational demand from Las
Vegas and the surrounding area.
• Develop year-round recreational opportunities to meet increasing demand by recreationists of
various types and skill levels.
Review of the Forest Plan indicated the need to amend two standards, on a project-specific basis, to bring
the proposed action and alternatives other than the no-action alternative into compliance. The proposed
action could not be revised, or an alternative developed, in a way that complied with these standards and
still met the stated purpose and need for action. The amendments are discussed in detail below in section
1.6 – Relationship to the Forest Plan.
1.5 DECISIONS TO BE MADE

In consideration of the stated purpose and need and the analysis of environmental effects documented in
this EIS, the responsible official will review the proposed action and alternatives in order to make the
following decisions:
• Whether to authorize the proposed action or an alternative, including the required no-action
alternative, all or in part;
• What design criteria and mitigation measures to require as a condition of the authorization; and
• What evaluation methods and documentation to require for monitoring project implementation and
mitigation effectiveness.
• Whether to authorize a project-specific Forest Plan amendment exempting the proposed action or
action alternative from standards 0.31 and 11.57.
The responsible official will document his decision and rationale in a Record of Decision (ROD). The
responsible official is William Dunkelberger, the HTNF Forest Supervisor.
1.6 RELATIONSHIP TO THE FOREST PLAN

As noted above (section 1.1), the Forest Plan, provides primary guidance for management of HTNF
resources, including those within the ski area permit boundary. The Forest Plan indicates that the ski area
lies within management area (MA), MA 11 – Developed Canyons, which is subject to MA-specific
standards and guidelines as well as SMNRA-wide direction and some Forest-wide and standards and
guidelines. The GMP replaces previous direction for MA 11.
5
The Forest Plan and GMP direct how recreation factors into SMNRA management activities, recognizing
that recreation use of the Forest and the SMNRA is extremely high. The Forest Plan includes this Forest-
wide goal: “The Toiyabe will increase the quality and quantity of developed and dispersed recreation
opportunities with particular emphasis in the Sierra Nevada and the Spring Mountains of southern Nevada”
(p. IV-1).
on the Forest. A decade later, the GMP recognized the SMNRA’s unique resources as the management
priority, listing the following SMNRA-wide goals. The proposed action serves, in part, to implement these
goals (p. 7) and associated objectives:
Supporting these SMNRA-wide goals, objective 0.43 is to “Manage lands within the SMNRA to provide a
range of developed recreation opportunities, with an emphasis on opportunities not available on private
lands.”
This direction carries over to MA 11 with this objective: “(11.7) Manage the area for a variety of high
quality, public recreational activities for both summer and winter, with an emphasis on those that are not
available on private lands” and this desired future condition (p. 28) “The ski area is providing additional
winter recreation opportunities (p. 31).”
As noted above in section 1.4 – Purpose and Need, a Forest Plan amendment would be needed to bring the
proposed action and alternatives other than the no-action alternative into compliance. The amendment
would be project-specific, not affecting any future management action. It would exempt the proposed action
and alternatives other than the no-action alternative from the following Forest Plan standards:
SMNRA-wide Standards and Guidelines: (0.31) New roads, administrative facilities,
and developed recreation sites other than low-impact facilities (trails, trailhead parking,
signs, restrooms, etc.) will be outside a 100-yard buffer zone around known Clokey’s
eggvetch and rough angelica populations or potential habitat, and outside biodiversity
hotspots (defined as areas of particular diversity or sensitivity).
Management Area 11: (11.57) Allow limited expansion of ski area in Lee Canyon and
enhancement of skiing opportunities and facilities within the scope of an approved master
development plan and under the following constraints:
1. Expansion occurs within the existing sub-basin.
2. Does not impact any threatened, endangered, or sensitive species or species of
concern or its habitat.
3. Expansion is commensurate with development of additional parking in the lower
Lee Canyon area and shuttle services.
4. Expansion incorporates defensible space design and fire safe facilities.
5. Where consistent with other standards and guidelines.
In regard to standard 0.31, the entire ski area permit boundary falls within a biodiversity hotspot identified
in the GNP, and under both the proposed action and the action alternative new service roads and ski area
facilities would be developed within a 100-yard buffer around potential habitat for Clokey’s eggvetch.
As to standard 11.57, the proposed action and action alternative do not comply with constraints 2 and 3.
Regarding constraint 2, the project area supports numerous special-status plant and wildlife species,
6
including the Mount Charleston blue butterfly (MCBB) which was federally listed as endangered in 2015.
As discussed in detail below in section 2.2 – Proposed Action, enhancement of habitat for MCBB, and
accordingly of its host and nectar plants and other plants and animals sharing its habitat, was an important
factor in development of the proposed action. Sections 3.5 and 3.6 thoroughly analyze and disclose
numerous impacts, both positive and negative, on these and other special-status species.
Regarding constraint 3, the proposed action and alternatives other than the no-action alternative include a
new 500-vehicle parking lot at the ski area (section 2.2.4.4), precluding any need for down canyon parking
with shuttle service.
In short, the infrastructural development necessary to meet the stated purpose and need for action could not
occur in compliance with these standards, and the proposed amendment is necessary in order for any
development to occur at the ski area.
Pertinent Forest Plan direction and compliance issues are further discussed in resource-specific sections of
Chapter 3. A full review of the relevant Forest Plan standards and guidelines is found in Appendix A. The
ROD will address Forest Plan consistency and make the definitive determination.
1.7 SCOPING AND IDENTIFICATION OF ISSUES

On March 23, 2017, the HTNF issued a public scoping notice summarizing the proposed action and inviting
comments regarding the scope of the associated NEPA review.
Information regarding the scoping period, available materials for review, and a public meeting was sent to
the agencies, organizations, and individuals on the HTNF mailing list. The scoping notice was posted on
the HTNF website at https://www.fs.usda.gov/project/?project=50649 and made available on CD or in
hard-copy form to anyone requesting it.
The scoping period began on March 23, 2017, when a Notice of Intent to Prepare an Environmental Impact
Statement (NOI) was published in the Federal Register (Vol. 82, No. 55, p. 14865). The scoping period
closed 45 days later on May 8, 2017. Comment letters were received from five agencies, six organizations,
and 89 individuals (including multiple letters from single individuals). The scoping notice, NOI, and
comment letters are included in the project record.
A scoping report was prepared that assessed all comments received to determine which affected the scope
of the analysis documented in this EIS. A copy of the report is included in the project record (Forest Service
2017). The Interdisciplinary Team (ID Team) assembled to complete this EIS reviewed and discussed the
proposed action to determine the scope of the analysis.
Collectively, public and government-to-government scoping and internal, interdisciplinary review
identified the following issues to be addressed in this EIS. They begin with the physical environment, move
to the biological environment, and conclude with the human environment.
The issues may be addressed by analysis and disclosure of effects, development of project design criteria
or mitigation measures, or alternative development. The potential effects of proposed developments in the
vicinity of the Bristlecone Trail (BCT) were identified as an alternative-driving issue (section 2.4.2).
1.7.1 ISSUES CARRIED INTO IN-DEPTH ANALYSIS

These issue statements introduce each resource-specific section in Chapter 3, where they are followed by
the indicators used to identify the direct, indirect, and cumulative effects.
1.7.1.1 Soil, Water, and Watershed Resources

Issue 1 – Stormwater Runoff: The permit area is subject to localized, high-intensity summer thunderstorms.
Coupled with steep, rugged terrain, this results in periodic, sudden runoff events, and gullying.
Development of the proposed infrastructure would alter ground cover and soil permeability and could
7
influence the timing, intensity, and quantity of stormwater runoff. Downgradient wells could be damaged
if wellheads were flooded or groundwater was contaminated.
Indicator: A model-based analysis of runoff from high-intensity thunderstorms under pre- and post-project
scenarios, with and without mitigation. Model results and other factors are considered in assessing potential
effects on downgradient wells.
Issue 2 – Soil Erosion and Stability: The permit area is characterized by steep slopes, erosive soils, and
sparse ground cover. Construction of the proposed ski area infrastructure would involve substantial
clearing, grading, and excavation. On trails, soil surfaces would be kept bare by subsequent maintenance
and use. These actions may affect the extent and severity of soil erosion.
Indicator: An erosion and sedimentation risk rating for each element based on soil type, disturbance area,
intensity of disturbance, slope, presence of a runoff pathway, distance to a water body, and efficacy of
proposed mitigation, and a qualitative assessment of how any increase in runoff and sedimentation would
affect wells lower in the watershed.
Issue 3 – Snow Accumulation and Snowmelt: The permit area supports extensive forest vegetation. Clearing
and glading of currently forested areas to develop ski runs would entail tree removal. This in turn would
increase exposure of the snowpack to sunlight and wind. As a result, tree removal may affect the timing,
rate, and quantity of snowmelt.
Indicator: A mostly qualitative discussion of the anticipated change in timing, rate, and quantity of
snowmelt runoff based on the acreages involved and best available science regarding clearing effects.
1.7.1.2 Vegetation
Issue 1 – Special-status Species: The SMNRA is a unique ecosystem, and the permit area includes habitat
for a number of special-status species, including Forest Service sensitive species, Spring Mountains
Conservation Agreement species of concern (CA species), and species covered in the Clark County
Multiple Species Habitat Conservation Plan (MSHCP). There are no federally listed plant species in the
project area, nor is there any habitat for federally listed plant species. Development and subsequent use of
the proposed infrastructure would result in temporary habitat disruption during construction, permanent
habitat conversion, and increased levels of human activity year round. These changes may affect special-
status plant species or their habitats.
Indicators: Species-specific determinations of potential individual- and population-level impacts, based
primarily on surveys, published information on the species’ distribution and population status, and the
efficacy of design criteria and proposed mitigation. These determinations are based on the laws, regulations,
and policies regarding management of each category of species.
Issue 2 – Invasive Species: Noxious and non-native invasive species pose an ongoing threat to the permit-
area’s ecosystem. Construction-related soil disturbance would create habitat conditions favorable to many
such species, and construction equipment could introduce their seeds. Use of hiking and biking trails could
also introduce seeds and spread established infestations. As a result, these activities may affect the
introduction and spread of these undesirable plant species.
Indicators: Assessment of the current invasive species scenario in the permit area and analysis of the
efficacy of design criteria in place and proposed mitigation. Compliance with applicable County regulations
will provide an assessment criterion.
1.7.1.3 Wildlife
Issue – Special-status Species: The SMNRA is a unique ecosystem, and the permit area includes habitat for
a number of special-status species, including federally listed species, Forest Service sensitive species, CA
species, species covered in the MSHCP, and migratory birds. Development and subsequent use of the
proposed infrastructure would result in temporary habitat disruption during construction, permanent habitat
8
conversion, and increased levels of human activity year-round. These changes may affect special-status
wildlife species or their habitats.
Indicators: Species-specific determinations of the potential individual- and population-level impacts, based
primarily on surveys, published information on the species’ habitat distribution and population status, and
the efficacy of design criteria and proposed mitigation. The determinations are based on the laws,
regulations, and policies regarding management of each category of species.
1.7.1.4 Cultural Resources

Issue 1 – Historic Properties: The Spring Mountains have a rich pre-history and history, including Native
American use dating back to the Paleoindian era. Construction of the proposed infrastructure would entail
grading and excavation which could inadvertently damage cultural sites.
Indicator: Assessment of the potential for project-related disturbance to affect historic properties through
identification of properties and determination of proximity to ground-disturbing project elements.
Issue 2 – Historic Integrity of the Ski Area: Lee Canyon ski area dates back to 1964. While most of the
facilities were developed more recently, some may date back to over 50 years ago. How would construction
and use of the proposed infrastructure affect historic properties in the permit area that relate to the historic
integrity of the ski area?
Indicators: Assessment of the potential for any project-associated activity to affect the historic integrity of
the ski area through identification of any structures eligible for listing on the National Register of Historic
Places (NRHP) and determination of effects of project disturbance.
Issue 3 – Native American Concerns: The Spring Mountains remain an important feature in the culture of
local and regional Tribal groups. Nuvagantu (literally “where snow sits,” or the Spring Mountains
landscape) is sacred to some and considered to be the site of their creation. Construction-related disturbance,
the resulting permanent, physical changes, and the increased level of year-round human activity may affect
Tribal cultural concerns for the area as a whole.
Indicator: Government-to-government consultation with Native American Tribes of concern regarding this
proposed action and providing Tribal entities with the results of the NHPA Section 106 compliance process.
Assessment of how the proposed development could affect any Native American concerns.
1.7.1.5 Scenery Resources

Issue – Scenic Integrity: The permit area landscape has been affected by more than 50 years of ski-area
development but generally retains its natural character. The proposed addition of more infrastructure at the
base area and on the mountain may alter the landscape and may adversely affect the area’s scenic integrity.
Indicators: Analysis of effects using the methods prescribed in the Forest Service Visual Management
System (VMS), in accordance with the TNF Forest Plan and GMP. Recreation Opportunity Spectrum
(ROS) classifications are used as a reference.
1.7.1.6 Recreation
Issue 1 – Impacts on BCT Users: The upper BCT passes through the permit area, and the upper trailhead is
within the permit area. This trail is one of the most heavily used in the SMNRA, and use occurs year round.
The proposed Chair 8 and associated ski runs, mountain coaster, zip line, and mountain bike trails would
all intersect the BCT, altering the viewscape, generating noise, bringing more people to the area, and overall
shifting to a less natural setting. This may affect the recreational experience provided by the BCT.
Indicators: A qualitative assessment of current recreational use of the BCT and how visual character, noise,
and use levels would change. ROS classifications are used as a reference.
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Issue 2 – Climate Change and Ski Area Viability: Reductions in snowpack due to climate change are a
major concern for the ski industry. Lee Canyon could be particularly vulnerable given its southern location.
Climate change could affect the future viability of this area as a winter recreation site.
Indicators: A review of recent research on regional climate change and its effects on resources and resource
uses, specifically snowpack depth and duration and developed winter sports sites, to assess likely effects
on Lee Canyon.
1.7.1.7 Safety
Issue 1 – Collision Hazard: The proposed action includes mountain bike trails and a dual-use, hiking and
biking trail. Some of the mountain bike trails cross the BCT, as do some of the proposed ski runs. This mix
of trail types and uses may result in collision hazards for trail and ski run users.
Indicators: An assessment of collision risk on multiple-use trails based on use levels and the efficacy of
design criteria and proposed mitigation.
Issue 2 – Emergency Services: Most medical and fire services in the SMNRA are based in Kyle Canyon,
and the distance to Lee Canyon, coupled with traffic congestion, can result in slow response times. As a
result, additional, year-round visitation associated with the proposed infrastructure may affect provision of
emergency services.
Indicators: A quantitative assessment of the estimated increase in demand for emergency services and an
evaluation of the ability of new and existing infrastructure to accommodate any increase.
1.7.1.8 Traffic
Issue – Traffic Congestion: The road network serving the SMNRA provides adequate service with one
exception. On winter weekends and holidays, people flock to the SMNRA for the novel snow-play
opportunity. The Lee Meadows area is especially popular, and County-provided parking is insufficient. As
a result, traffic flow is often impaired by vehicles parked on the roadway, drivers slowing to find parking
places, and overall congestion. As a result, additional winter visitation associated with the proposed
infrastructure may contribute to traffic congestion.
Indicators: An assessment of existing and expected traffic volumes and patterns, and how these patterns
would affect the level of service on Lee Canyon road (SR 156), based on existing information.
1.7.1.9 Land Use

Issue – Adjacent Land Uses: The ski area adjoins or is in close proximity to other permitted facilities (i.e.,
Camp Lee Canyon and McWilliams Campground). Additional year-round visitation associated with the
proposed infrastructure may result in property damage, disruption, or other adverse effects on these adjacent
land uses.
Indicators: A qualitative assessment of the potential for property damage or disruption of permitted uses
and the effectiveness of design criteria and proposed mitigation.
1.7.2 CONCERNS IDENTIFIED BUT NOT ANALYZED IN DEPTH

Issue 1: Effects of increased water use for snowmaking.
Rationale: The proposed action does not include increased water use for snowmaking. The ski area employs
snowmaking to supplement natural snow and maintain coverage for a safe and enjoyable skiing experience,
not to extend the ski season. The snowmaking system draws from the existing reservoir, which is filled with
water from two spring complexes above the reservoir within the ski area boundary. Two wells are also
pumped as needed to fill the snowmaking reservoir.
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Water use is determined primarily by climatic conditions – i.e., the adequacy of natural snow coverage and
whether temperatures allow snowmaking when additional coverage is needed. Water use is not limited by
the extent of snowmaking system coverage but by the ski area’s ability to fill the snowmaking reservoir
(i.e., flow from the springs, production of the two wells, and pump/pipe capacity), none of which would
change under the proposed action. The proposed snowmaking system expansion is intended to provide the
ski area the flexibility to use the currently available water to make snow where it is most needed at any
given time. The water supply would not change.
The water rights associated with the ski area are held by the Forest Service, and those rights are for
significantly more water than the ski area has ever used. Phase 2 of the MDP includes a second snowmaking
reservoir that would bring more of the existing water rights into active use. However, the second reservoir
has not been proposed. The ski area has been actively investigating alternative sources for snowmaking
water, beyond Three Springs and the existing wells, but none have been identified. As a result, no additional
water sources have been proposed, and increased water use is outside the scope of this analysis.
Issue 2: Effects on wetlands and riparian areas.
Rationale: Water resources in the permit area are limited. While there are wetland and riparian areas within
the permit area, none occur in areas that would be directly or indirectly affected by the proposed
infrastructure. This issue is outside the scope of this analysis.
1.7.2.2 Vegetation
Issue: Effect of tree removal on the ecology of Lee Canyon.
Rationale: This EIS addresses the direct, indirect, and cumulative impacts of the proposed action and
alternatives. Aside from effects in those categories, the ecology of Lee Canyon is outside the scope of this
analysis.
1.7.2.3 Wildlife
Issue: Effect on wild horses and burros.
Rationale: Wild horses and burros are managed within the SMNRA in accordance with other regulations,
laws, and higher-level decisions beyond the scope of this analysis.
1.7.2.4 Recreation
Issue 1: Benefits of proposed infrastructure to winter recreation.
Rationale 1: These benefits are the basis of the purpose and need for the proposed action and are
summarized in Chapter 1 under that heading. It would not be useful to address them again in the analysis
of recreation effects.
Issue 2: Whether the zip line and mountain coaster at the ski area would be appropriate uses of NFS land.
Rationale: The Ski Area Recreational Opportunity Enhancement Act of 2011 directs the Forest Service to
authorize summer activities that:
• “Encourage outdoor recreation and enjoyment of nature;
• to the extent practicable –
o harmonize with the natural environment of the NFS land on which the activity or facility
is located; and
o be located within the developed portions of the ski area;
• be subject to such terms and conditions as the Secretary determines to be appropriate; and
• be authorized in accordance with –
o the applicable land and resource management plan; and
11
o applicable laws (including regulations).”

Zip lines are cited as an example of activities that may meet these criteria, and a number of mountain
coasters have been permitted under this law. The proposed zip line and mountain coaster would provide an
interpretive forest experience, complementing and taking advantage of ski area infrastructure. In processing
the MDP amendment that includes these facilities, we reviewed and accepted them as consistent with the
Forest Plan and applicable laws and regulations. This issue is outside the scope of this analysis.
Issue 3: Whether charging for parking in ski area lots would reduce public access to NFS land.
Rationale: The parking fees charged by the ski area in the winter are intended to cover the cost of snow
removal. Without that snow removal, the parking lots would be unusable much of the winter. No fees for
summer parking are proposed. The proposed action would not affect this issue, and it is addressed by other
regulations, laws, or higher-level decisions
1.7.2.5 Socioeconomics
Issue: Socioeconomic effects.
Rationale: The substantive socioeconomic issues identified through scoping and internal, interdisciplinary
review are addressed under more specific headings in this EIS. For example, effects on emergency services
are addressed under Safety. Effects on adjacent permitted activities are addressed under Land Use, and
effects on users of the BCT are addressed under Recreation.
Other socioeconomic issues raised during scoping were determined to not affect the scope of the analysis
for reasons detailed in the scoping report or were considered but not carried into in-depth analysis for
reasons outlined above.
1.7.2.6 Litter
Issue: Effect of increased visitation on litter.
Rationale: Littering is a serious issue along roadways and in high-use areas of Lee Canyon. The ski areas
efforts to provide signage, receptacles, and semi-annual staff and volunteer clean-up days reduce the
problem somewhat within the permit boundary. Based on these considerations, the issue of litter in the
canyon is beyond the scope of this decision.
1.7.2.7 Wilderness
Issue: Effects on Wilderness.
Rationale: The upper end of Lee Canyon, including the ski area, is adjoined on three sides by the 56,819-
acre Mt. Charleston Wilderness. However, the rugged intervening terrain blocks both views and sounds of
the ski area from most vantage points within the Wilderness. The proposed development would be visible
from some points on the North Loop Trail where it traverses the ridgeline Wilderness boundary south of
the ski area. Beyond that, it could not be seen from Wilderness trails. Similarly, this analysis (section 3.9)
indicates that noise from the proposed mountain coaster would not be discernible from background sound
levels at distances beyond 2 miles. In short, the proposed development would only affect the wilderness
experience of hikers traversing the boundary adjoining the ski area itself, an area already subject to the
sights and sounds of developed recreation.
1.7.2.8 Inventoried Roadless Areas

Issue: Effect on inventoried roadless areas (IRAs).
Rationale: The nearest IRA, Charleston-Carpenter, is about 2 miles west of the ski area on the opposite side
of the range. It would not be affected directly or indirectly by the proposed development.
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1.8 PROJECT RECORD

The project record contains the technical documentation used to support the analysis and conclusions in
this EIS. The project record is available for review at the SMNRA Office, 4701 N. Torrey Pines Drive, Las
Vegas, Nevada, 89130.
1.9 OTHER PERMITS AND AUTHORIZATIONS

Table 1-1 lists the permits and authorizations, beyond HTNF authorization, that may be required in order
for Lee Canyon to implement the proposed action or an action alternative.
Table 1-1. Permits and approvals that may be required for implementation of the proposed action
or an action alternative.
Agency Type of Action Description of Permit or Action

Federal
Forest Service Approval of Construction Plans. Prior to any construction on NFS lands,
Endangered Species Act (ESA) construction plans must be submitted to and
Section 7 consultation. approved by the HTNF.
National Historic Preservation If NEPA review identifies impacts on species listed
Act (NHPA) Section 106 under the ESA, the Forest Service must complete
consultation. the appropriate consultation process with the FWS.
If impacts on resources eligible for listing under the
NHPA, or eligible resources on Tribal land, or
resources with Tribal cultural significance are
identified, the Forest Service must complete the
appropriate consultation process with the State
Historic Preservation Office (SHPO) or Tribal
group.
U.S. Army Corps of Clean Water Act, Section 404 The COE issues permits required for the discharge
Engineers (COE) Permit. of dredged or fill materials into waters of the U.S.,
including wetlands. Nationwide or individual
permits may be involved if any such discharge is
identified.
Environmental Review and comment regarding: Under NEPA, the EPA is required to review and
Protection Agency - Clean Air Act, as amended, 42 comment on “major federal actions that have a
(EPA) U.S.C.A. Section 7410-762 (PL substantial impact on the human environment.”
95-604, PL 95-95). The EPA's responsibility and role is to provide
scoping comments, review EISs, and provide
- Federal Water Pollution
information and appropriate technical assistance
Control Act, as amended by the
during and following the environmental analysis
Clean Water Act, 33 U.S.C.A.
process.
Section 1251-1376 (PL 92-500,
PL 95-217). Specific environmental legislation for which the
EPA is responsible and which may be applicable to
- Safe Drinking Water Act, 452
this proposed action is shown to the left.
U.S.C.A. Section 300F-300J-10
Administrative and enforcement responsibilities
(PL 93-523).
have been delegated to the State of Nevada for all
- Clean Water Act, Section 404 four acts. The EPA may be involved in 404
Permit. permitting in association with the COE.
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Table 1-1 (cont’d). Permits and approvals that may be required for implementation of the
proposed action or an action alternative.
Agency Type of Action Description of Permit or Action

Fish and Wildlife ESA Section 7 Consultation. If impacts on federally listed species are identified,
Service (FWS) Fish and Wildlife Coordination the FWS will consult with the Forest Service and
Act consultation. issue a letter of concurrence or Biological Opinion.
Section 404 Permit consultation.
State of Nevada
Department of Review and comment regarding: The Division of Environmental Protection’s review
Conservation and - Air Contaminant Discharge ensures that state and federal air and water quality
Natural Resources: Permit (ACDP). standards are not exceeded through issuance of
Division of various permits.
- National Pollutant Discharge
Environmental Elimination System (NPDES)
Protection permit.
- Storm Water Pollution
Prevention Plan (SWPPP)
Department of Review and comment. The Department of Wildlife is responsible for
Wildlife management and protection of state fish and
wildlife resources and may comment accordingly.
Division of Water Review and comment. The Division of Water Resources is responsible for
Resources determining adequacy of water supply and
cumulative impacts on water supply and may
comment accordingly.
Department of State highway projects. The Department must review and approve any state
Transportation highway redesign or access improvement.
Nevada State Parks, NHPA, Section 106 compliance The SHPO encourages the preservation,
Natural Heritage process. documentation, and use of cultural resources. They
Program, State are a partner in assisting federal, state and local
Historic Preservation governments meet their historic preservation
Office obligations.
Southern Nevada Septic system permitting. The Southern Nevada Health District must review
Health District and approve any new septic systems.
Clark County
Building Department Building permits. The Building Department provides construction
plan review, consultation, and permitting to ensure
compliance with state and federal building codes.
Department of Air Dust control permit. The Department of Air Quality oversees air quality
Quality regulations for construction activities within the
county.
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CHAPTER 2: PROPOSED ACTION AND

ALTERNATIVES
2.1 INTRODUCTION
This chapter details the proposed action, including associated design criteria, then outlines the alternative
formulation process, lists alternatives considered but not analyzed in depth, describes the alternatives
considered in depth, then summarizes the environmental impacts of the proposed action and alternatives.
Currently the Bristlecone Trail alternative (section 2.4.2) is the Preferred Alternative. The proposed action
(section 2.2) and no-action (section 2.4.1) alternatives are presented as points of comparison to the Preferred
Alternative.
2.2 PROPOSED ACTION

The elements of the proposed action are described in detail below. Figure 2-1 illustrates proposed lifts, ski
runs, and snowmaking. Figure 2-2 displays summer activities, and Figure 2-3 shows facilities. If authorized,
the elements described below are slated for construction within 5 years following approval, but full
implementation could take longer (see section 2.2.6, Timing, below).
Section 3.2 provides additional detail on the projected disturbance associated with each element of the
proposed action. Table 3-1 in section 3.2 shows the basic dimensions of disturbance associated with various
types of elements. These dimensions were used in calculating element-specific disturbance areas in Table
3-2.
In the descriptions below the terms “run” or “ski run” refer to wider ski routes where the skier is moving
primarily down the fall line. The term “traverse” refers to a narrower ski route where the skier is moving
primarily across the fall line. The purpose of ski runs is recreation whereas the purpose of a traverse is
access from one place to another. The term “trail” refers to a very narrow route that is used for hiking or
biking, or both. As the term is used below, recreational use of trails occurs primarily in the summer.
2.2.1 LIFTS AND SKI RUNS

2.2.1.1 Lift 4
Lift 4 would be designed for first-time skiers, providing them the opportunity to get a feel for being on skis
or boards, riding a lift, and sliding on a very mild grade – a “bunny hill.” It would be a moving carpet lift
about 450 feet long, with a vertical rise of 80 feet, running along the length of the beginner slope, along the
skier’s left edge. It would be installed on a raised berm on ties or concrete blocks. No additional clearing
or grading would be needed, as the alignment lies on the edge of the existing beginner run. It would be
electrically powered, drawing from an existing transformer in the mid-mountain area. In addition to use by
beginner skiers, the lift would also serve a staging function (i.e., transporting guests from the lower parking
lot to the mid-mountain base area) and may be used for tubing, replacing the current cable lift.
2.2.1.2 Chair 5 Pod

The Chair 5 pod (i.e., a ski lift and the runs it serves) would be the next step up from the bunny hill,
providing beginners and low intermediate skiers the opportunity to transition to a chairlift and ski a variety
of longer “green” (i.e., easier or beginner) runs. Chair 5 would be an 1,800 person-per-hour (pph) fixed-
grip quad chairlift with a loading conveyor. The lift would be 1,400 feet long, with a vertical rise of 310
feet. It would be a top-drive lift with approximately 7 towers. The lift would be powered from a transformer
at the maintenance shop. The power line would be trenched into the Chair 5 top terminal access road,
running up the skier’s right side of the pod, from the shop to the upper terminal.
15
In order to access the Chair 5 bottom terminal, a new 500-foot conveyor, Lift 6, would be installed from
near the bottom terminal of Chair 3 to near the bottom terminal of Chair 5. Utility lines for the conveyor
would be trenched from the maintenance building into the pod 5 egress skiway to the bottom of the
conveyor.
As shown in Figure 2-1, there would be three runs in this pod. These runs were laid out to maximize
potential benefits to MCBB habitat extent, quality, and connectivity. While the proposed runs were
designed to work with existing topography as much as possible, grading of portions would be necessary to
create a suitable surface and fall-lines for skier safety and flow (see section 3.2). Since the actual extent of
grading will not be known until final engineering, the 14.4 acres of grading found in Table 3-2 reflects the
conservative assumption that each entire run would be graded.
New ski runs would incorporate design features to make them less visually striking, including feathered
edges, tree islands, and strategic placement to make them less visible from sensitive viewpoints.
Final engineering could result in alteration of the proposed run alignments. In that case, the same
adjustments to benefit MCBB habitat, work with existing topography, and reduce visual impact would be
required.
The primary construction access for the lift and runs would be up the Chair 5 top terminal access road.
Trees would be cut using mechanized equipment and hauled out on the access road by truck. Footings for
the terminals and towers would be dug using an excavator with concrete transported by truck, excavator,
or helicopter, depending on accessibility. Towers would be installed on the footings by helicopter.
Maintenance of the Chair 5 pod and other lift pods would involve periodic grading and repair of access
roads to repair erosion damage, repair of erosion control features on ski runs and access roads, repair of
erosion damage to ski runs, and cutting of encroaching forest vegetation taller than 4 inches on ski runs and
access roads. This work would take place, as needed, within the original disturbance area.
The alignment of this pod differs from the one in the scoping notice issued on March 23, 2017. The changes
were necessitated when review of the proposed action identified engineering problems that made the
originally proposed alignment infeasible.
2.2.1.3 Chair 8 Pod

Similar to existing Chair 2, Chair 8 would be a step up in difficulty from Chair 5, accessing mostly
intermediate runs with some easier and some more difficult terrain within that category. It would be a fixed-
grip quad chairlift with a capacity of 1,800 pph, 2,200 feet long, with a vertical rise of 650 feet. It would be
a bottom drive lift with approximately 16 towers. A power line would be trenched into a new access road
from the mid-mountain area to the lower terminal of Chair 8. Skiers would use Chair 2 to access the Chair
8 pod.
As shown in Figure 2-1, there would be seven runs in this pod, including the Snake run which is technically
in the Chair 2 pod. These runs were designed based on the same considerations for MCBB habitat,
conformity with existing topography, and visual impact reduction outlined for the Chair 5 pod, and any
realignment resulting from final engineering would be subject to the same considerations.
The primary construction access for the lift and runs would be up the Chair 8 bottom and top terminal
access roads. Trees would be cut using mechanized equipment and hauled out on the bottom terminal access
road by truck. Footings for the terminals and towers would be dug using an excavator with concrete
transported by truck, excavator, or helicopter, depending on accessibility. Towers would be installed on the
footings by helicopter.
Maintenance requirements would be similar to those outlined above for the Chair 5 pod.
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Figure 2-1. Proposed action – lifts, ski runs, and snowmaking.
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Figure 2-2. Proposed action – summer activities.
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Figure 2-3. Proposed action – facilities.
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2.2.1.4 Tree and Glade Skiing

Tree and glade skiing (i.e., skiing off of cleared runs in areas where trees are spaced widely enough to allow
skiing among them) are increasingly popular. Glading is the process of removing trees to open up areas that
are currently too densely forested for most skiers to navigate comfortably. At Lee Canyon, increasing tree
canopy cover also limits understory growth, posing a constraint to MCBB habitat. By opening canopy
cover, glading also encourages understory growth.
Three areas with the potential for both tree skiing and MCBB habitat improvement as a result of glading
have been identified (Figure 2-1). One, a parcel of about 5.5 acres, is a tree island between Keno and
Blackjack runs, in the Chair 1 pod. The second, about 16 acres, lies above the snowmaking reservoir,
accessed from Chairs 1 and 2. The third, about 5 acres, is in the lower portion of the wooded area between
the Chair 2 pod and the Chair 8 pod, with access from Chair 8. These three areas were prioritized because,
in addition to their skiing prospects, they comprise potential or historic MCBB habitat, or could provide
connectivity between habitat areas if tree cover were reduced. Smaller trees, diseased or damaged trees,
and white fir trees would be the priorities for removal. Design criteria 11 requires consultation with the
Forest Service as to which trees would be removed for glading projects in order to address forest health
issues such as disease or insect infestation.
Work would be done by hand or, in some areas, using equipment such as feller-bunchers. Trees cut in the
tree island between Keno and Blackjack and in the parcel above the snowmaking pond would be dropped
in place and laid across the fall line to serve as water bars to reduce erosion. Trees cut in the area between
pods 2 and 8 would be hauled out on the Chair 8 bottom terminal access road by truck.
2.2.2 SNOWMAKING COVERAGE

Snowmaking is currently limited to primary runs in each pod – Keno off of Chair 1, The Strip off of Chair
2, The Line off of Chair 2, and Rabbit Peak off of Chair 3. Expanding the snowmaking system would create
the option to use available water to make snow wherever it was needed most. It would not require more
water; it would just provide more flexibility in water use.
This proposal entails expanding system coverage to the other existing, cleared runs in the Chair 1 and Chair
2 pods initially (except Slot Alley, Grandma’s, Grandpa’s, Blackjack, and Bimbo), then to all cleared runs
in the Chair 5 and Chair 8 pods when those pods are developed (Figure 2-2). The amount of water available
is a factor determining the pace of snowmaking expansion, and the 2010 expansion of the snowmaking
pond created new options.
The infrastructure necessary to complete this system expansion includes buried water and electric lines,
surface hydrants to connect snowmaking guns, and an additional pump house (roughly 600 square feet)
when snowmaking in the Chair 8 pod is developed. Approximately 3.5 miles of trench would be required
for the collocated water and electric lines. The alignments of snowmaking lines have been adjusted to avoid
MCBB habitat wherever possible.
Maintenance of the snowmaking system would involve excavating and repairing broken lines and hydrants
as necessary. This work would take place within the original disturbance area.
2.2.3 SUMMER ACTIVITIES

2.2.3.1 Mountain Coaster
Mountain coasters are a relatively new type of recreation at mountain resorts, used primarily during the
summer but popular during winter as well when conditions allow. Gravity-powered cars holding individual
riders or pairs travel on a dual-rail metal track. They start at a loading/unloading terminal at the bottom, are
pulled up to the top of the circuit on a straight uphill segment, and then are released onto a downhill segment
with turns, climbs, and dips. The track averages 4 to 6 feet above ground level, but peaks can be up to 20
feet high. The coasters are quiet. They are not an amusement park-style development but a recreational
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amenity developed specifically to provide an exhilarating experience in the mountain environment, and that
environment is central to their concept and popularity.
This mountain coaster would be installed west of the base area (Figure 2-2). The top of the circuit would
be near the summit of the 9,270-foot peak above the BCT, and the downhill track would run down the slope
to the southeast. The loading/unloading terminal would be in the mid-mountain area. Overall the track
would be approximately 1.2 miles long. The mountain coaster would pass over the top of trails and butterfly
habitat with bridge spans to minimize collisions of trail users with supports, or habitat impacts on the
ground.
Construction of the mountain coaster would be done primarily by hand, with materials transported to the
site by light equipment (e.g., mini excavator, ATV, or truck) via existing and proposed access roads and
along the mountain coaster corridor. No new roads would be constructed specifically for this element. In
areas where concrete footings were required (i.e., loops and sharp corners), the footings would be poured
in place at accessible sites or prefabricated in another location and hauled into place with a mini excavator.
Maintenance of the coaster would include clearing of encroaching forest vegetation and repair or adjustment
of footings damaged by erosion or settling.
2.2.3.2 Mountain Bike Trails

Mountain biking has increased steadily in popularity for a number of years, and it was one of the first
summer activities authorized at ski areas on NFS land. While mountain biking is allowed on the SMNRA’s
BCT, including the portion passing through the ski area, Lee Canyon has offered no dedicated mountain
bike facilities to date. This proposal includes construction of a 13-mile system including technical and flow
trails of various difficulties. See Figure 2-2 for conceptual trail locations.
In terms of construction, flow trails would be wider and would include features (e.g., jumps, bridges,
seesaws) built of earth or rock sourced from project elements requiring excavation, or wood sourced
partially from elements requiring tree removal. Technical trails would be narrower, with more turns around
natural features like roots and rocks. The average width of flow trails would be 4 feet, while the technical
trails would average 2 feet. There would likely be a 3:2 ratio of flow trails to technical trails, respectively.
For purposes of this analysis, we assume all trails would be the wider flow trails in order to estimate impacts
conservatively. The ratio of flow trails to technical trails has changed since the March 23, 2017, scoping
notice due to input from the local mountain biking community. All trails, with the exception of the dual-
use trail described in the next section, would be restricted to downhill bicycle traffic. Uphill access for lift
served mountain biking would be via Chair 2.
The mountain bike trail system was designed to avoid areas of currently suitable MCBB habitat. Currently
the conceptual trails pass through areas of suitable MCBB habitat. This will not be allowed per mitigation
measure 10 (see section 3.6.5). Therefore, the conceptual mountain bike trail locations on Figure 2-2 are
provided for context and visualization purposes. The locations presented should not be interpreted in the
context of their impacts on existing MCBB habitat.
Construction of bike trails would be done with a combination of hand tools and mini excavators. Access
routes would be along existing or proposed access roads and along trail corridors. No new roads would be
constructed specifically for this element.
Maintenance would involve grading and repair of the trail surface to repair damage from erosion and use,
repair of erosion control features, cutting of encroaching vegetation, and watering flow trails to reduce dust.
This work would take place, as needed, within the original disturbance area.
2.2.3.3 Hiking Trail

Hiking would be allowed on one of the mountain bike trails descending from the upper terminal of Chair 2
to the mid-mountain base area (Figure 2-2). Lift rides have been popular with summer visitors, who
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subsequently make their own way down the mountain. The designated trail would be easier for visitors to
use and would reduce the resource impacts of dispersed hiking.
The dual-use hiking/biking trail would be 1 mile long, one of the easier-rated technical trails for bicycles.
It would be constructed with three times the width (6 feet wide) of other technical trails with designated
sides for hikers and bikers, reducing collision hazard.
Construction of the dual-use hiking/biking trail would be done with a combination of hand tools and mini
excavators. Access routes would be along existing or proposed access roads and along the trail corridor. No
new roads would be constructed specifically for this element.
Maintenance would involve grading and repair of the trail surface to repair damage from erosion and use,
repair of erosion control features, and cutting of encroaching vegetation. This work would take place, as
needed, within the original disturbance area.
2.2.3.4 Zip Line

A zip line is, simply put, a pulley and brake system on an inclined cable which allows the rider, suspended
from the pulley in a harness, to traverse the length of the cable at a controllable speed. Zip lines provide an
opportunity to experience the forest canopy while having an exciting ride at the same time. The proposed
zip line would descend from a launch station in the upper portion of Chair 2 pod to a final landing station
toward the bottom of the new Chair 5 pod. The entire experience would involve two segments of zip line
with an interpretive trail between segments. This trail would be 200 to 300 feet long and would include
signage featuring native flora and fauna. A similar interpretive trail would be constructed to bring riders
from the landing near the bottom of the Chair 5 pod back to the base area.
Installation would require a 30-foot cleared corridor, but much of the alignment would lie above treetop
height, in natural openings, or along cleared ski trails. In areas where the zip line corridor was greater than
15 feet above the treetops, no trees would need to be removed. Construction of the terminals would require
access by light equipment (e.g., mini excavator, ATV, or truck). Access routes would be along existing or
proposed access roads and along bike trail corridors. No new roads would be constructed specifically for
this element.
Only launch and landing towers would be required, as the cable between them would be a free, unsupported
span. The four steel launch and landing towers would be up to 25 feet high, and the cable height would
range up to 150 feet above the ground, depending on the ground contour. Required maintenance would
include clearing trees encroaching on the zip line corridor, as needed.
2.2.4 FACILITIES
2.2.4.1 Equipment Rental/Food & Beverage Building
This building would replace the existing equipment rental/administration building at the upper base area. It
would provide approximately 20,000 square-feet of floor space, split between two or possibly three levels
(Figure 2-3). Specific functions would include ski and snowboard rental, food and beverage service,
group/banquet space, restrooms, and storage. It would be designed and constructed to reflect a consistent
architectural theme for the resort.
2.2.4.2 First Aid/Ski Patrol Building

This structure would house key public safety and administrative functions at the lower base area (Figure 2-
3). These would include ski patrol headquarters, first aid services, employee offices, and meeting space. It
would comprise about 10,000 square feet on two levels. Power and water would be brought in from the
existing maintenance building, and a septic system would be installed in an island in the new parking lot to
the northeast.
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2.2.4.3 Vault Toilet Facility at Overflow Parking Lot

The overflow lot is used by the general public as well as ski area visitors. It is roughly a 15-minute walk
from the nearest restroom facilities, which are at the mid-mountain base area. The addition of toilet facilities
at the overflow parking lot is necessary to improve the experience of year-round visitors. The facility has
been sited to avoid impacts on MCBB habitat adjacent to the parking area (Figure 2-3).
This facility would be a simple, pre-cast structure, with men’s and women’s sides. It would be installed on
a 12-foot-by-20-foot pad adjacent to the parking area.
2.2.4.4 New Parking Lot

Parking capacity at Lee Canyon is not sufficient for projected peak-day conditions. This proposal addresses
the shortfall primarily through development of a new parking lot at the lower base area (Figure 2-3). The
3.6-acre paved lot would accommodate about 500 cars, or 1,250 visitors at the industry standard of 2.5 per
car. In combination with existing lots, this would accommodate the 2,800-person comfortable carrying
capacity of the resort following this expansion.
The new parking lot would also be designed to serve as a stormwater runoff detention basin. The impacts
of this design are described in section 3.4. Essentially, the detention basin would serve to reduce peak flows
from stormwater runoff below the ski area. The new parking lot would not be used during the summer
months.
A new, two-way access road, about 1,500 feet long with a 20-foot-wide, paved surface, would be developed
from the existing overflow lot. It would run along the western edge of the parking lot, with entries to the
lot near the northwest corner and the southwest corner.
Maintenance would involve the repair and resurfacing of the parking lot. This work would take place, as
needed, within the original disturbance area.
2.2.4.5 Gate House

A small (roughly 6 feet by 10 feet) gate house would be constructed between the inbound and outbound
lanes of the Lee Canyon access road, at the site of the existing gate, below the entrance to the overflow
parking lot (Figure 2-3). The purpose of this structure would be to control parking access and collect parking
fees during the winter. The Forest Service authorizes Lee Canyon to charge for winter parking to offset the
cost of snow removal work done by the ski area.
2.2.4.6 Water Tank

The ski area’s current culinary water storage tank is insufficient in capacity and in need of replacement. A
new 120,000-gallon steel, above-ground tank would be installed west of the snowmaking reservoir, in a
grove of trees on the skier’s left side of Snake ski run (Figure 2-3). This site is accessible, adjacent to in-
place piping, and partially screened by vegetation. The existing concrete tank would be filled with sand and
abandoned in place, as it is buried beneath occupied MCBB habitat on the Bimbo run.
2.2.5 PROJECT-SPECIFIC FOREST PLAN AMENDMENT

As discussed in section 1.6 – Relationship to the Forest Plan, a project-specific Forest Plan amendment
would be needed to exempt the proposed action, as well as any alternatives other than the no-action
alternative, from standards 0.31 and 11.57 in the GMP. Specifically:
• SMNRA-wide Standard 0.31 in the GMP would be amended by the addition of the following: New
service roads and developed recreation sites authorized in the Lee Canyon ski area MDP Phase I
ROD may be placed within the 100-yard buffer zone around known Clokey’s eggvetch and rough
angelica populations or potential habitat, and within biodiversity hotspots in the Lee Canyon
Special Use Permit Boundary.
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• Management Area 11 Standard 11.57 in the GMP would be amended by the addition of the
following: Projects authorized in the Lee Canyon ski area MDP Phase I ROD are exempt from the
requirements under constraints 2 and 3.
2.2.6 TIMING
Implementation of these project elements is anticipated to begin within 5 years following authorization, but
full implementation may take longer. The following implementation stages reflect the ski area’s priorities:
• Stage 1. Mountain bike and hiking trails; new parking lot, including vault toilet and gate house;
equipment rental/food & beverage building; and first aid/ski patrol building.
• Stage 2. Chair 5 and Chair 8 pods, including lifts, ski runs, and snowmaking; water tank; and zip
line.
• Stage 3. Mountain coaster and glading.
2.3 ALTERNATIVE FORMULATION

NEPA mandates that an EIS address a reasonable range of alternatives to the proposed action. These
alternatives should achieve the same purpose and need, and they should include alternatives that address
issues raised and avoid or otherwise mitigate adverse environmental effects associated with the proposed
action. Alternatives that would not be reasonable, either because they would not be consistent with purpose
and need or because of other considerations, need not be analyzed in depth, but the rationale for not
analyzing them should be explained. An EIS must also address the no-action alternative, disclosing the
outcome of not undertaking the federal action comprised by the proposed action and action alternatives.
The following sections discuss alternatives considered but not analyzed in depth – the required no–action
alternative and the action alternative.
An EIS must address the alternative of no action (40 CFR 1502.14 [d]) to provide a benchmark for
comparison of the magnitude of environmental effects of the proposed action and action alternatives. The
no-action alternative does not meet the purpose and need for action. In this case, the no-action alternative
is defined as maintaining the status quo in terms of infrastructural development at Lee Canyon. Under this
alternative, no further development would occur, with the minor exceptions described in section 2.4.1.
The process of formulating action alternatives began with the scoping exercise described in Chapter 1.
Scoping commenters suggested five alternatives stemming from concerns regarding development of
undeveloped areas, impacts on the environment, and recreational conflicts.
As the next step in alternative formulation, the Forest Service ID team evaluated these issues in conjunction
with the full range of potential resource impacts associated with the proposed action in order to determine
which could be mitigated and which, if any, were more effectively addressed with an alternative. Based on
the ID team’s recommendations, the responsible official decided to carry one action alternative into detailed
analysis. That alternative is comprised of elements of several of the alternatives suggested in scoping
comments (see section 2.4.2). The other suggested alternatives were not carried into in-depth analysis for
the reasons discussed in section 2.5.
2.4 ALTERNATIVES ANALYZED IN DEPTH

2.4.1 NO-ACTION ALTERNATIVE
Under the no-action alternative, no further infrastructural development would take place at Lee Canyon.
Year-round recreational facilities and opportunities would remain as they are today. An exception would
be the construction of the previously approved skier services building at the mid-mountain base area, as
authorized in a Decision Memo dated June 6, 2018 (Forest Service 2018).
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2.4.2 BRISTLECONE TRAIL ALTERNATIVE

Reflecting concern over impacts on the recreation experience of users on the BCT, this alternative (the BCT
alternative) moves several elements of the proposed action away from the trail. Specifically, this alternative
makes adjustments to five elements of the proposed action (see Figure 2-4) while still meeting the purpose
and need for action:
• Chair 8 pod.
• Tree and glade skiing.
• Snowmaking system.
• Zip line.
All other elements of the proposed action not listed above, including the project-specific Forest Plan
amendment, are included in this alternative unchanged from their descriptions in the proposed action.
Section 3.2 provides additional detail on the projected disturbance associated with each element of this
alternative. Table 3-1 in section 3.2 provides basic dimensions of disturbance associated with various types
of elements. These dimensions were used in calculating element-specific disturbance areas in Table 3-3.
2.4.2.1 Chair 8 Pod

Based on scoping comments and internal interdisciplinary review, there are several changes to the Chair 8
pod under this alternative. The bottom terminal would be shifted approximately 250 feet upslope to the
southeast relative to the alignment described under the proposed action. Ski runs in the pod would be
shortened by up to 200 feet to keep them from intersecting the BCT and realigned in order to accommodate
the shorter length and new bottom terminal location. A new skiway/summer road would be constructed
from mid-mountain base area to the bottom terminal to provide skier egress, summer maintenance access,
and a utility corridor. The summer access road to the top terminal would be moved downslope and shortened
by approximately 400 feet relative to the proposed action. All other details and methods of construction and
maintenance would be similar to those described for the proposed action.
2.4.2.2 Tree and Glade Skiing

Based on the changes to the Chair 8 pod described above, the shape of the gladed area adjacent to and
within the Chair 8 pod would change under this alternative. The goals of this gladed area would remain the
same: 1) to open a corridor between MCBB habitat on the western side of the ski area to habitat on the
Bimbo ski run, and 2) to provide additional skiing opportunities in this area.
2.4.2.3 Mountain Coaster

The alignment of the mountain coaster was one of the most frequently addressed elements in scoping
comments and internal interdisciplinary review. Under this alternative, the mountain coaster would be
situated in the Chair 5 pod area. The top of the circuit would be near the top terminal of Chair 5, and the
downhill track would run down the slope to the west, below the pod 5 ski runs. The loading/unloading
terminal would be in the mid-mountain area, to the east of the Chair 3 top terminal, and a 100-foot elevated
walkway would be used to access this area. Under this alternative, the track would be approximately 0.8
miles long. All other details and methods of construction and maintenance would be similar to those
described for the proposed action.
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Figure 2-4. BCT alternative – changes from the proposed action.
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2.4.2.4 Snowmaking System

Under this alternative, snowmaking lines and the pump house would be moved to accommodate the changes
in pod 8 ski runs. Additional lines would be added so that all runs in pod 8 would have snowmaking system
coverage. All other details and methods of construction and maintenance would be similar to those
2.4.2.5 Zip Line

Under this alternative, the zip line would descend from a launch station in the upper portion of Chair 1 pod
to a final landing station east of the mid-mountain base area. In this alignment, no connecting trails would
be necessary. All other details and methods of construction and maintenance would be similar to those
2.5 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN

DEPTH
Public scoping and internal, interdisciplinary review identified the following alternatives, which were not
carried into in-depth analysis for the reasons noted.
2.5.1 NO DEVELOPMENT OUTSIDE PREVIOUSLY DEVELOPED AREAS

Commenters suggested an alternative limiting new activities and infrastructure to previously developed
locations at the ski area. This alternative would not meet the purpose and need for this proposed action
because the infrastructure necessary to meet the stated purpose and need could not be accommodated within
the existing development footprint. All developed areas are in use currently.
2.5.2 CONSERVATION ALTERNATIVE

Commenters suggested the analysis of a conservation-focused alternative. The proposed action was
developed with conservation, including the habitat requirements of the MCBB, in mind. A thorough survey
of existing habitat conditions for special-status plants and wildlife was completed. Proposed infrastructure
was sited to avoid high quality habitat; and clearing and glading were proposed in locations where overstory
removal and/or soil surface disturbance might improve conditions for host and nectar plants required by the
MCBB and/or provide linkages between higher quality habitat patches. Throughout the process of
developing the proposed action, biologists with the Forest Service and FWS provided input on how and
where the developments might provide the most conservation value. In sum, the proposed action was
developed with conservation priorities on the SMNRA in mind and represents the best conservation-minded
alternative that would meet the purpose and need for the proposed action.
2.5.3 PARKING GARAGE

Commenters suggested that the new parking lot described in section 2.2.4.5 be replaced with a parking
garage in order to accommodate more cars in a smaller space. While a parking garage might provide some
advantages, financial considerations make it infeasible at this time. In the future, the space where the new
parking lot would be constructed could be developed as a parking garage if the financial situation changed
to make it practical.
2.5.4 NARROWER SKI RUNS

Commenters suggested making narrower ski runs in the Chair 5 and 8 pods in order to cut fewer trees. The
suggested width of 10 to 20 feet is not viable for a host of safety and operational reasons. The ski runs
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proposed are mostly narrower than the industry standard of approximately 150 feet in an attempt to
minimize the visual impacts of the new ski runs.
2.5.5 WINTER ONLY ALTERNATIVE

Commenters suggested inclusion of an alternative that retained winter activities and infrastructure while
removing all summer activities and their associated infrastructure in order to reduce impacts on the MCBB.
This alternative would not meet the purpose and need for this proposed action because development of
year-round recreational opportunities is one of the three primary tenants of purpose and need raised in
section 1.4. Beyond that, the analysis did not identify sufficient adverse effects due to the proposed summer
activities to warrant a winter-only alternative. For example, only 1.5 acres of the 17.4 acres of MCBB
habitat disturbance associated with the construction of BCT alternative is due to summer activities (see
Table 4 in Forest Service 2019a). Furthermore, section 1.5, Decisions to be Made, states that any of the
alternatives addressed could be selected “all or in part.” Based on the analysis provided in the EIS and
project record, which describes the effects of individual project elements, the responsible official could
choose to authorize winter recreational developments only. For additional discussion of this alternative see
Appendix C.
2.5.6 ELIMINATION OF CHAIR 8 POD

Commenters suggested an alternative eliminating the Chair 8 pod due to concerns over the viability of
skiing in this area in light of climate change and also to reduce impacts on users of the BCT. Regarding the
viability of pod 8, exposures in this area range from north to northwest, not significantly different from
those in the existing pods, and its higher elevation would keep snow longer. The DEIS addresses the
implications of climate change (DEIS section 3.9). As discussed in DEIS section 2.2.1.3, pod 8 is an
important element of the proposed action, providing a logical step up in terrain difficulty as well as
accommodating the needs of a growing recreational market with a diversity of terrain.
Regarding impacts on BCT users, the BCT alternative was developed to reduce impacts on BCT users. It
includes a buffer between the trail and pod 8 development and moves the more intrusive summer elements
to other parts of the ski area. Neither the mountain coaster nor the zip line would cross the BCT. The
analysis indicates that this would substantially reduce impacts on trail users (FEIS section 3.9.3.3.1), but
some impact is unavoidable because the trail passes through the permit area of an existing developed ski
area. We should also point out that the Forest Plan assigns the project area to Management Area 11 –
Developed Canyons, which provides for this type of developed recreation (section 1.6).
Furthermore, section 1.5, Decisions to be Made, states that any of the alternatives addressed could be
selected “all or in part.” Based on the analysis provided in the EIS and project record, which describes the
effects of individual project elements, the responsible official could choose not to authorize the Chair 8
pod.
2.5.7 NO DEVELOPMENT EAST OF CHAIR 2

One commenter suggested curtailing development east of Chair 2 due to concerns over impacts on hiking.
Most of the current ski area infrastructure is east of Chair 2, and most hiking in the area involves the BCT,
which is west of Chair 2. Under the BCT alternative, many of the proposed improvements are moved east
of Chair 2 to reduce impacts on BCT users.
2.5.8 ALTERNATIVE LOCATION FOR VAULT TOILET

One commenter suggested moving the vault toilets to a location more convenient to users of the BCT. The
vault toilet is proposed to provide facilities for ski area visitors as well as the general public. Its location
was determined to assist those needing facilities in the overflow parking lot which is a long walk from the
mid-mountain base area. While some BCT users will likely utilize the vault toilets by walking or driving
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from the trailhead to the overflow parking lot, the facility is not intended solely to meet the needs of BCT
users.
2.5.9 CROSS-COUNTRY MOUNTAIN BIKE TRAILS

Commenters suggested the addition of cross-country bike trails so uphill riders would have options for
utilizing the trails constructed by the ski area. Cross-country bike trails pose a number of management
issues at ski areas (e.g., difficulty segregating uses, limiting use to paying customers, and overall congestion
when combined with other trail types, with associated impact on MCBB habitat). As a result, Lee Canyon
has not proposed cross-country trails.
2.5.10 ALTERNATIVE ZIP LINES

Commenters suggested different concepts for the use of zip lines at Lee Canyon. Suggestions were more in
line with what is typically seen at ropes courses or aerial adventure courses, rather than what Lee Canyon
has proposed. At this time, Lee Canyon has not proposed such activities.
2.5.11 SHUTTLE SERVICE

One commenter suggested shuttle services to the ski area in order to alleviate parking limitations. The
parking area proposed along with the existing parking and overflow lot is expected to meet the projected
comfortable carrying capacity of the resort with some excess parking space. As discussed in the section
3.11, the additional 500-car parking lot would bring the ski area total to 1,228 spaces. The additional lot
may reduce the number of illegally parked cars by providing non-skiing visitors with more legal options.
A shuttle system has been attempted by Lee Canyon in the past, but that experience and similar experiences
at other ski areas suggest that a shuttle system would not be highly used and thus do little to reduce traffic
or parking issues.
2.6 DESIGN CRITERIA AND MITIGATION MEASURES

Design criteria are measures to avoid or reduce adverse environmental effects that are identified prior to
NEPA review. This analysis incorporates a number of design criteria developed on the basis of experience
at Lee Canyon and other ski areas. Reducing soil erosion and adverse effects on water quality, protecting
wildlife habitat and other native vegetation, maintaining visual quality, ensuring appropriate access to
facilities, and protecting buried heritage resources are the concerns addressed by the following design
criteria. They are considered to be in place in the analysis of environmental consequences discussed in
Chapter 3.
Erosion Control
1. Lee Canyon ski area will prepare a Storm Water Pollution Prevention Plan (SWPPP) that will apply
to all authorized elements. The SWPPP is a condition of Nevada’s Construction Stormwater
General Permit and will include appropriate BMPs for erosion control, sediment control, site
stabilization, operational controls, and provisions for maintenance and inspection.
2. The SWPPP will include appropriate BMPs from National Best Management Practices for Water-
Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical
Guide (Forest Service 2012a), Ski Area BMPs (Best Management Practices) Guidelines for
Planning, Erosion Control, and Reclamation (Forest Service 2001), Lee Canyon’s Las Vegas Ski
and Snowboard Resort Master Erosion and Sediment Control Plan (Stantec 2008), Nevada BMP
handbooks and field guides including Nevada Contractors Field Guide for Construction Site Best
Management Practices (Nevada DEP 2008) and Best Management Practices Handbook (Nevada
Conservation Commission 1994) Pertinent watershed BMPs are listed in section 3.4.5 and
Appendix B.
29
Vegetation Management
3. Soil disturbance will be minimized, and existing topsoil will be conserved for replacement.
4. Where possible, native vegetation will be retained.
5. In cleared and graded areas, mechanized equipment may be used to fell and remove trees. Disposal
will be in accordance with applicable Forest Service permit requirements.
6. Slash created by tree removal will be disposed of either through utilization, burning, chipping,
mastication, lopping and scattering, or removal from the site within a specified timeframe. Disposal
will be in accordance with applicable Forest Service and state permit requirements.
7. Lee Canyon will follow Forest Service policy (FSM 2070) and use genetically appropriate native
materials for any rehabilitation and restoration. A qualified Forest Service botanist will be involved
in development, review, and/or approval of plant materials selected for use in site rehabilitation
and restoration.
8. All construction equipment and vehicles used will be cleaned and certified free of noxious weeds
and their seeds prior to entrance onto the HTNF. This restriction will include equipment and
vehicles intended for both on- and off-road use, whether they are owned, leased, or borrowed by
either contractors or subcontractors.
9. Any fill material proposed for the project, including any imported topsoil, will come from an on-
site or in-canyon location.
10. Any straw bales, chips, or other imported mulch used in conjunction with construction or
rehabilitation activities will come from a certified weed-free source.
11. Prior to conducting glading operations, consult with the Forest Service to obtain a glading
prescription in order to address forest health issues such as disease or insect infestation.
Wildlife Protection
12. Do not clear, cut, burn, drive on, or park equipment on vegetation that may harbor nesting birds
during the breeding season (May 15–July 15). If this is not possible, survey for nesting birds no
more than 10 days prior to commencing work. If no nests are found, project activities may proceed.
If nests are found, contact the Forest Service permit administrator.
13. Avoid suitable MCBB habitat in the design phase wherever possible.
Scenic Integrity
14. Permanent structures will be designed and built in compliance with the Spring Mountains National
Recreation Area Built Environment Image Guide (Forest Service 2007). Ensuring that architectural
style, building materials, size, and color are consistent and meet the adopted scenery objectives.
Compliance will be confirmed through Forest Service engineering review prior to construction.
15. The edges of cleared ski runs will be feathered to appear more like natural openings in forest cover,
flowing with the topography and blending with the natural vegetation.
Accessibility
16. All buildings will be designed and constructed in accordance with the Accessibility Guidebook for
Ski Areas Operating on Public Lands – 2012 Update (Forest Service 2012b). Compliance will be
confirmed through Forest Service engineering review prior to construction.
Undiscovered Heritage Resources
17. If any previously unidentified prehistoric or historic cultural resources are identified or encountered
at any time during construction, efforts shall be made to protect the resource(s) until the Forest
30
Service permit administrator is notified and the Forest Service fulfills its consultation requirements,
including consultation with the appropriate Tribal representatives.
18. If unmarked human remains are encountered at any time during construction, all work in the
vicinity of the find shall cease, the County Sheriff shall be notified, the remains shall be protected
in place, and the Forest Service permit administrator shall be notified immediately to begin proper
notification and consultation procedures with the Nevada State Historic Preservation Office, Native
American Tribes, and other local officials as needed (e.g., County Coroner) to determine to what
time period and ethnic group the skeletal material may be ascribed and the appropriate treatment.
19. The HTNF is consulting with the tribes and other groups in accordance with laws, regulations and
policy (i.e. 36 CFR 800, FSH 27309, FSH 1560). As a result, if any previously unidentified
Traditional Cultural Places or sacred sites are identified or encountered at any time during
construction, efforts shall be made to protect the resource until the Forest Service permit
administrator is notified and the Forest Service fulfills its consultation requirements, including
consultation with the appropriate Tribal representatives.
Chapter 3 also identifies any additional project-specific mitigation measures beyond these design criteria.
Mitigation measures are compiled in Appendix B. The responsible official’s decision to authorize the
proposed action or an alternative, all or in part, will identify specific design criteria and mitigation measures
required as a condition of approval.
2.7 SUMMARY AND COMPARISON OF ENVIRONMENTAL

EFFECTS
Table 2-1 summarizes and compares the direct and indirect environmental effects of the proposed action
and alternatives.
2.8 AGENCY’S PREFERRED ALTERNATIVE

The agency’s preferred alternative is the BCT alternative. The BCT alternative would fulfill the HTNF
statutory mission and responsibilities, and is consistent with economic, environmental, technical, and other
factors. The BCT alternative also meets the purposes and needs identified above. This alternative would
include the same project-specific Forest Plan amendment described in section 2.2.5.
31
Table 2-1. Summary and comparison of environmental effects.

Soil, Water, and Watershed Resources:
Issue 1 – Stormwater Runoff: No change from current The proposed action would initially result in a Under all modeled scenarios, peak runoff
How would the proposed conditions would occur under small increase in peak runoff for the 25- and 100- under the BCT alternative would be 1–5
infrastructure affect the this alternative. Intense summer year storms and a substantial reduction in peak percent lower than the proposed action.
timing, intensity, and quantity storms would continue to cause runoff for the most common 2-year storm. Once Therefore, the potential for downslope
of stormwater runoff? downslope flooding. disturbed areas were fully rehabilitated, peak flooding would be further reduced
runoff would be reduced below no-action relative to the proposed action.
alternative levels for all modeled storms. Under
most modeled scenarios, and all long-term
modeled scenarios, potential for downslope
flooding would be reduced relative to the no-
action alternative.
Issue 2 – Soil Erosion and No change from current Due to the highly erosive nature of the soils in the Relative to the proposed action, this
Stability: How would the conditions would occur under area, the proposed 129.8 acres of disturbance alternative would cause 8.6 acres less
proposed infrastructural this alternative. Intense summer would cause erosion potential to increase in the surface disturbance. Because of this
development affect the extent storms would continue to cause short-term relative to the no-action alternative. Ski reduction in total surface disturbance, the
and severity of soil erosion? erosion. runs in the Chair 5 and Chair 8 pods would retain a short-term increase in erosion potential
moderate erosion potential rating until and the acreage rated as moderate before
revegetation occurred, when their rating would fall revegetation would be reduced.
to low.
Issue 3 – Snow Accumulation No tree cutting would occur Relative to the no-action alternative, the clearing Relative to the proposed action, this
and Snowmelt: How would under this alternative, and there or glading of 92.7 acres of trees would represent alternative would reduce the area
tree removal affect the would be no change with regard an approximately 9 percent reduction in forest subjected to clearing and increase the area
timing, rate, and quantity of to snowmelt. cover for the ski area subwatershed. The small subjected to glading for a total of 107
snowmelt? magnitude of this change would make effects on acres of clearing and glading. Overall, the
snowmelt patterns undetectable in the context of impacts at the watershed level would be
watershed behavior. similar to the proposed action.
Vegetation:
Issue 1 – Special-status Since there would be no ground- The proposed action would have no impact on Relative to the proposed action the
Species: How would the disturbing or habitat-altering rough angelica, Charleston pussytoes, Spring amount of impacted habitat for all species
proposed infrastructure affect elements under this alternative, Mountains rockcress, upswept moonwort, dainty would be reduced but the determinations
special-status plant species? there would be no impact on moonwort, slender moonwort, moosewort, would remain the same for all species
Forest Sensitive species, Wasatch draba, Jaeger’s draba, Charleston other than Clokey’s eggvetch.
32
Table 2-1 (cont’d). Summary and comparison of environmental effects.

management indicator species Mountain draba, Nevada willowherb, Clokey’s Impacts on Clokey’s eggvetch would be
(MIS), Conservation Agreement greasebush, Jaeger’s ivesia, Jaeger’s beardtongue, substantially reduced relative to the
for the Spring Mountains Charleston tansy, Charleston Mountain kittentails, proposed action, and the determination
National Recreation Area – Charleston violet, or Lemmon’s rubberweed, for this species would be: may impact
Clark and Nye Counties, Nevada because no occupied habitat for these species individuals but it not likely to cause a
(CA) species of concern, or would be disturbed directly or indirectly. trend toward federal listing or loss of
Clark County Multiple Species The proposed action may impact individuals but is viability.
Habitat Conservation Plan not likely to cause a trend toward federal listing or
(MSHCP) covered species. loss of viability of King’s rosy sandwort,
Charleston Mountain goldenbush, Hitchcock’s
bladderpod, Charleston beardtongue, Charleston
ground-daisy, Clokey’s paintbrush, quaking aspen,
Clokey’s thistle, Clokey’s mountain sage, inch
high fleabane, and Charleston pinewood lousewort
because occupied habitat is present for these
species in the proposed action disturbance area.
The proposed action may impact individuals and
may cause a trend toward federal listing or loss of
viability of Clokey’s eggvetch. The observed
numerical and spatial variation in the population
make the magnitude of potential impact difficult to
accurately assess.
Issue 2: Invasive Species: No change from current Occurrences of three invasive plant species Relative to the proposed action, the
How would the proposed conditions would occur under (prostrate knotweed, African mustard, and acreage of disturbance within prostrate
infrastructural development this alternative. The ski area common mullein) overlap the disturbance area for knotweed populations would grow, due
affect the introduction and would treat existing weed the proposed action. Risk assessment for elements primarily to relocation of the mountain
spread of noxious and non- infestations with the objective of of the proposed action identified several elements coaster. The mountain coaster risk rating
native invasive species? either controlling or eradicating as having moderate risk for spread of undesirable would increase from none to low, so the
known occurrences, consistent plant species. Implementation of BMPs and mountain coaster project could still
with the terms of their special monitoring, with control treatments initiated on proceed as planned, with control
use permit. any undesirable plant populations that establish in treatments initiated on any undesirable
the area, would be required for these elements. plant populations that establish in the
These measures should effectively control invasive area.
species.
33

Wildlife:
Issue – Special-status Since there would be no ground- The proposed action may affect and is likely to Relative to the proposed action the
Species: How would the disturbing or habitat-altering adversely affect the MCBB because habitat is amount of impacted habitat for all species
proposed infrastructural elements of this alternative, there present in the disturbance area and short-term would be reduced under this alternative
development affect special- would be no impact on Forest effects are likely to be detrimental. Beneficial but the determinations would remain the
status wildlife species? Service sensitive species, MIS, habitat effects are possible as natural forb same for all species.
CA species of concern, or communities are re-established in previously
MSHCP covered species. forested areas.
The proposed action would have no impact on
spotted bats because no roosting habitat would be
impacted and the value of the area as foraging
habitat would not be changed.
The proposed action may impact individuals but is
not likely to result in a trend toward federal listing
or loss of viability for the following species:
Spring Mountains dark blue butterfly, Morand’s
checkerspot, Spring Mountains icarioides blue
butterfly, pale Townsend’s big-eared bat, northern
goshawk, peregrine falcon, flammulated owl,
Spring Mountains comma skipper, Charleston ant,
Nevada admiral, Carole’s silverspot, western
small-footed myotis, long-eared myotis, long-
legged myotis, fringed myotis, and silver-haired
bat because habitat is present for these species in
the proposed action disturbance area but impacts
are not substantial relative to available habitat in
the area.
The proposed action would not alter the existing
trend for Forest-level populations of Palmer’s
chipmunk or brown-headed cowbird on the Forest
because habitat for Palmer’s chipmunks is
ubiquitous and brown-headed cowbirds are rare in
the project area, a positive indicator.
34

Cultural Resources:
Issue 1 – Historic Properties: The identified prehistoric site is No direct impact on the prehistoric site would Same as proposed action.
How would proposed not in an area impacted by occur because no proposed project elements are in
construction disturbance current ski area operations or the area. Additional dispersed use of upper Lee
affect cultural sites in the activities but is being impacted Canyon spurred by new summer activities at the
area? by dispersed recreation use in ski area could potentially result in indirect effects,
upper Lee Canyon. but recommended mitigation is anticipated to
avoid any adverse effect on the site.
Issue 2 – Historic Integrity of No historic properties from the Same as no-action alternative. Same as proposed action.
the Ski Area: How would the ski area’s early years exist, so its
proposed infrastructure affect historic integrity has been lost.
the historic integrity of the
ski area?
Issue 3 – Native American Tribal involvement in ski area Analysis of the proposed action included active Generally the same as proposed action,
Concerns: How would the operations would remain participation with the Nuwuvi Working Group in but relocation of the mountain coaster and
proposed construction and negligible. Physical and less identifying and assessing cultural concerns and zip line, and shifting pod 8 development
increased human activity tangible impacts of ski area developing responsive mitigation. These efforts set up slope, away from the BCT, would
affect Tribal cultural operations on Nuwuvi culture the stage for increased recognition of Nuwuvi reduce effects of visitor numbers, ground
concerns? and cultural values would culture and its relationship to the Spring disturbance, tree removal, visual impact,
continue due to lack of Mountains. Nevertheless, cumulative impacts due and noise on this sensitive area.
awareness of these people and to increased visitation and development without
their relationship with the Spring cultural awareness are substantial. Design criteria
Mountains. in place would prevent any impacts on unknown
cultural resources.
Scenery Resources:
Issue – Scenic Integrity: How No development would occur at Bringing the BEIG into effect would improve This alternative would reduce the visual
would the proposed the ski area under this integration of the built and natural environments impact of the zip line, mountain coaster,
infrastructure alter the alternative. However, Built under the proposed action, but not to a large and Chair 8 pod on BCT users, but these
landscape and affect the Environment Image Guide degree. changes would not alter the conclusions
area’s scenic integrity? (BEIG) criteria would not be The lower and mid-mountain base areas would regarding VQO or ROS relative to the
met, retaining the built continue to be consistent with the VQO of proposed action.
environment’s departure from Modification, but a positive trend would be All other impacts would be the same as
the natural landscape. established due to implementation of the BEIG. the proposed action.
35

The mid-mountain and lower The proposed on-mountain infrastructure would, in
base areas would remain general, be more of the same type of development
consistent with the VQO of currently evident at the ski area. The greater extent
Modification that best matches would be offset in part by the design criteria
current baseline conditions, and identified to reduce contrast with the natural
the rest of the ski area would setting. These additions would result in an
meet the VQO of Partial acceptable degree of change from the natural
Retention. landscape, consistent with the VQO of Partial
The base areas would also Retention.
continue to reflect the Rural Regarding ROS classifications, the base areas
ROS criteria, as current would continue to reflect the Rural classification.
conditions do, and the remainder The slopes above would remain consistent with the
of the permit would retain Roaded Natural classification.
Roaded Natural characteristics.
Recreation:
Issue 1 – Impacts on BCT No change from current In terms of impacts on the trail’s viewscape, the Under this alternative, most summer
Users: How would the conditions would occur under main impacts would be associated with proposed infrastructure would be moved away from
proposed infrastructure affect this alternative, except that summer recreation infrastructure. This the BCT where it would be less visible
the recreational experience population growth may increase infrastructure would be in use during the same and disruptive to BCT users. The Chair 8
provided by the BCT? trail use over time. season that BCT use peaks, adding to its impact. pod would be shortened, moving ski runs
Sounds from the mountain coaster would reach and lifts away from the BCT.
noticeable levels on large segments of the BCT. Relative to the proposed action, noise
Use of the BCT is projected to increase by levels from the mountain coaster would
approximately 40 to 58 percent, respectively, on be substantially reduced and likely not
weekdays and weekends due to the increased noticeable on the majority of the trail.
number of people visiting the ski area during the Increased use of the BCT in summer
summer. under this alternative would be similar to
During winter, the introduction of snowcats and the proposed action.
downhill skiers on the trail section shared by the The winter trail user interaction level
Chair 8 access road/skiway might not be strictly would be reduced back to no-action
incompatible given the trail’s multi-use alternative levels under this alternative
designation, but it would certainly alter the due to shifting the Chair 8 pod egress
experience of winter trail users. upslope.
36

Issue 2 - Climate Change and No development would occur Expanded snowmaking capability and new Same as proposed action.
Ski Area Viability: How under this alternative, and the ski summer activities under the proposed action would
would climate change affect area would remain vulnerable to help the ski area adapt to future climate change.
the future viability of this the impacts of climate change.
area as a winter recreation
site?
Safety:
Issue 1 – Collision Hazard: No change from current The proposed action would create mountain bike Under this alternative, summer trail
How would the proposed conditions would occur under trails crossing the BCT in summer and downhill collision risk would be the same as the
infrastructure affect collision this alternative, except that skier traffic on the lower BCT in the winter. Both proposed action.
hazards for trail and ski run population growth may increase could result in collisions with BCT users. In the winter, relocation of the Chair 8
users? trail use and associated conflicts Implementation of mitigation measures for trail pod egress further upslope, collision risk
over time. intersections would reduce the risk potential in would be similar to the levels under the
summer, to levels similar to the no-action no-action alternative.
alternative. However, the potential for winter
collisions would increase due to a portion of the
BCT being used as the egress route for the Chair 8
pod.
Issue 2 – Emergency No change from current Under the proposed action, the new ski patrol/first Same as proposed action.
Services: How would conditions would occur under aid building and associated staff would provide
visitation associated with the this alternative, except that substantially improved facilities, including a
proposed infrastructure affect population growth may increase dedicated ambulance-loading area. Ambulance
provision of emergency demand for emergency services. service, provided by Mount Charleston Fire
services? Protection District (MCFPD) or a contract service,
would still be needed to transport more serious
cases to valley medical facilities.
A projected increase of 87 MCFPD responses per
year once buildout of all proposed infrastructure
was complete and peak visitation was reached
(~10 years), would likely tax the existing resources
of the MCFPD. An ambulance may need to be
stationed at the ski area more frequently to provide
timely transportation to Las Vegas medical
facilities. Nevada Department of Transportation
37

(NDOT) efforts to improve traffic flow on
SMNRA highways under their management could
also alleviate this issue.
Traffic:
Issue – Traffic Congestion: No change from current Under the proposed action, visitors to the ski area Same as proposed action.
How would winter visitation conditions would occur under would remain an important source of traffic on SR
associated with the proposed this alternative, except that 156 but less important than regional population
infrastructure contribute to population growth may increase growth. The additional parking in the upper
traffic congestion on SR 156? traffic on SR 156 over time. canyon may reduce parking-related congestion to
some degree, and the proposed improvements may
draw an increasing proportion of canyon visitors to
the ski area.
Land Use:
Issue – Adjacent Land Uses: No change from current With mitigation measures such as signage and Same as proposed action.
How would year-round conditions. Any existing fencing in place, the proposed action would not
visitation associated with the problems related to property result in a substantial increase in the incidence of
proposed infrastructure affect damage or disruption would property damage or disruption at Camp Lee
adjacent land uses? remain. Canyon or McWilliams Campground.
38
CHAPTER 3: AFFECTED ENVIRONMENT AND

ENVIRONMENTAL CONSEQUENCES
3.1 INTRODUCTION
This chapter discloses the environmental consequences of the proposed action and alternatives. It is
organized by resource area, beginning with the physical and biological environment, shifting to the human
environment, and then to other required disclosures. The information under each resource-specific heading
begins with a summary of the scope of the analysis (i.e., the environmental issues addressed, indicators
employed, and analysis area). The affected environment for each issue is then described to provide context
for the environmental consequences discussion that follows. That discussion focuses first on direct and
indirect effects of the no-action alternative to establish a baseline, then addresses the proposed action and
the BCT alternative. The effects analysis includes application of the design criteria and mitigation measures
introduced in section 2.6. Each resource-specific section ends with a discussion of cumulative effects.
Information on two topics is relevant to some or all of the resource-specific analyses in this chapter. It is
presented here to avoid duplication in those sections, and it includes the following:
• Disturbance Types and Areas
• Cumulative Actions
3.2 DISTURBANCE TYPES AND AREAS

Table 3-1 provides basic dimensions of disturbance associated with various types of project elements. These
dimensions were used in calculating disturbance areas for each project element. Tables 3-2 and 3-3 show
the amount of disturbance for the proposed action and BCT alternative. Disturbance types, from least
intensive to most intensive, are as follows:
• Glading – removal of trees, according to Forest Service prescription per design criteria 11, to
achieve a target spacing of 15 – 25 feet. May involve hand tools or equipment such as feller-
bunchers. Trees chipped or stacked and burned on site or collected and removed to an off-site
location.
• Clearing – removal of all trees and tall shrubs using tracked or wheeled equipment. Trees and
slash chipped or burned on site or collected and removed to an off-site location.
• Grading – recontouring and smoothing the soil surface using caterpillars or other heavy
equipment.
• Excavation – subsurface soil work using excavators or other heavy equipment, generally to
construct building or tower foundations.
Note that the disturbance amounts presented in Tables 3-1, 3-2, and 3-3 indicate only the highest intensity
of disturbance occurring at any given location. For example, a site would be cleared before being excavated,
but reporting it as being both cleared and excavated would over-represent the extent of disturbance.
39
Table 3-1. Typical disturbance dimensions1 by project element type.

Project Element Type Disturbance Dimensions Disturbance Type2
Buildings Footprint plus 50-foot construction buffer Excavation
Conveyor Lifts 25 foot width Grading
Chairlifts
Alignment Clearing 60-foot-width Clearing
Terminals 0.5 acre disturbance area Excavation
Towers 20-foot-diameter circle Excavation
Ski Run Actual with plus 10 foot grading buffer Grading
Utility Lines (snowmaking, power, sewer, and 15-foot-width Excavation
utility)
Mountain Bike Trails 6-foot-width Grading
Hiking Trail 12-foot-width Grading
Mountain Coaster 20-foot-width Excavation
Parking Lot 10-foot construction buffer Grading
Water Tank Footprint plus 50-foot construction buffer Excavation
Zip-line
Alignment Clearing 30-foot-width Clearing
Towers 20-foot-diameter circle Excavation
1These are the dimensions of construction-related disturbance, not the finished dimensions of projects.
2 Indicates maximum disturbance intensity (e.g., excavation disturbance also includes clearing and grading).
Table 3-2. Disturbance types and acres disturbed under the proposed action.
Disturbance Category and Acres Disturbed1
Project Element Glading Clearing Grading Excavation Project Element Total
Lift 4 -- -- 0.2 0.1 0.3
Chair 5 Pod -- 0.1 14.4 1.8 16.3
Chair 8 Pod -- 0.9 59.6 1.9 62.4
Tree and Glade 23.4 -- -- -- 23.4
Skiing
Snowmaking -- -- -- 6 6
Mountain Coaster -- -- -- 2.8 2.8
Mountain Bike -- -- 7.9 -- 7.9
Trails
Hiking Trails -- -- 1.8 -- 1.8
40
Table 3-2 (cont’d). Disturbance types and acres disturbed under the proposed action.
Project Element Glading Clearing Grading Excavation Project Element Total
Zip Line -- 2.1 -- > 0.1 2.1
Equipment -- -- -- 0.7 0.7
Rental/Food &
Beverage Building
First Aid/Ski patrol -- -- -- 0.8 0.8
Building
Vault Toilet Facility -- -- -- 0.3 0.3
at Overflow Parking
Lot
New Parking Lot -- -- 4.6 -- 4.6
Gate House -- -- -- 0.2 0.2
Water Tank -- -- -- 0.3 0.3
Total Disturbance 129.9
1Acreages include a disturbance buffer; the amount of actual ground disturbance may be less than the buffered distance. Areas of
overlap, such as where the disturbance buffers for two different elements coincide, have only been counted one time.
Disturbance acres have been rounded to the nearest tenth acre.
Table 3-3. Disturbance types and acres disturbed under the BCT alternative.
Project Element Name Glading Clearing Grading Excavation Project Element Total
Lift 4 -- -- 0.2 0.1 0.3
Chair 5 Pod -- 0.1 14.2 1.8 16.1
Chair 8 Pod -- 0.1 45.7 2.0 47.8
Tree and Glade Skiing 28.9 -- -- -- 28.9
Snowmaking -- -- -- 7.0 7.0
Mountain Coaster -- -- -- 2.0 2.0
Mountain Bike Trails -- -- 7.7 -- 7.7
Hiking Trails -- -- 1.8 -- 1.8
Zip Line -- 2.5 -- > 0.1 2.5
Equipment Rental/Food &
-- -- -- 0.8 0.8
Beverage Building
First Aid/Ski patrol Building -- -- -- 0.8 0.8
Vault Toilet Facility at
-- -- -- 0.3 0.3
Overflow Parking Lot
41
Table 3-3 (cont’d). Disturbance types and acres disturbed under the BCT alternative.
Project Element Name Glading Clearing Grading Excavation Project Element Total
New Parking Lot -- -- 4.6 -- 4.6
Gate House -- -- -- 0.2 0.2
Water Tank -- -- -- 0.3 0.3
Total Disturbance 121.1
1
Acreages include a disturbance buffer; the amount of actual ground disturbance may be less than the buffered
distance. Areas of overlap, such as where the disturbance buffers for two different elements coincide, have only been
counted one time. Disturbance acres have been rounded to the nearest tenth acre.
The total disturbance of 129.9 acres under the proposed action represents 16.5 percent of the total permit
area of 785 acres. The total disturbance of 121.1 acres under the BCT alternative represents 15.4 percent of
the total permit area.
3.3 CUMULATIVE ACTIONS

The cumulative actions considered in this analysis are past, present, and reasonably foreseeable future
projects included on the HTNF Schedule of Proposed Actions (SOPA) that could have temporally and
spatially overlapping impacts on the same resources affected directly or indirectly by the actions analyzed
in this EIS. Table 3-4 describes the cumulative actions considered in this analysis. There are two past
projects, one current project, and one reasonably foreseeable project that meet these criteria.
Table 3-4. Cumulative actions considered in this analysis.

Project Name Project Description
Past Projects
Dolomite- Location: Lee Canyon, along SR 156, with McWilliams Campground adjoining the ski area
McWilliams-Old Mill boundary.
Campgrounds Description: This project involved modifications and maintenance of three campgrounds in
Reconstruction Lee Canyon. Modifications included new roads and trails, restrooms, and campsites.
Project Maintenance items included replacement of fire rings, picnic tables, grills, repaving roads,
and vegetation management. This project was authorized in January of 2013 and
implemented in 2013 and 2014.
Implementation Date: 2013–2014
Foxtail Group Picnic Location: Lee Canyon, Along SR 156 approximately 16 miles west of intersection SR 156
Area Reconstruction with I-95.
Project Description: Recreation facilities were expanded to accommodate various group sizes.
These modifications included: replacing all roads and parking areas, addition of an entrance
station, implementation of a vegetation management plan, tree removal as needed,
construction of a large picnic shelter and additional restrooms. In addition to these
recreational improvements, these facilities are maintained throughout the summer and
parking lots are plowed during winter.
Implementation Date: 2012–2014
42
Table 3-4 (cont’d). Cumulative actions considered in this analysis.

Project Name Project Description
Current Projects
Old Mill Wildland Location: Kyle and Lee canyons and along Deer Creek Highway.
Urban Interface Description: This was a fuel reduction project to treat approximately 1,514 acres of NFS
(WUI) Hazardous lands adjacent to sensitive areas. Treatments included: mastication, hand thinning, and
Fuels Treatment burning. The purpose of this project was to reduce the hazard of a severe wildfire by
reducing the forest fuel loads.
Since it was initially authorized, the acreage proposed for treatment has been reduced due to
constraints related to equipment access to much of the originally proposed area. The work to
be completed in Lee Canyon has been reduced to 10 acres of hand thinning and piling and
52 acres of lop and scatter. Each of these treatments will be followed by burning of cut
material.
Implementation Date: Ongoing
Future Projects
Lee Canyon Fuels Location: Upper Lee Canyon, including lands within and adjacent to the ski area permit
Reduction Project1 boundary.
Description: The project area comprises 600 acres. The goals of this project are to improve
firefighter and public safety, protect private property, and improve forest health by
preventing beetle-related tree mortality. Proposed actions include removal of smaller trees
to reduce fuel loading, hand piling of slash for pile burning, lop and scatter of slash, and
broadcast burning for initial removal of vegetation and cost-effective maintenance.
Implementation Date: Summer 2019
1
This project is not listed on the HTNF SOPA at this time but is expected to be posted to the SOPA by the time a
final EIS is published. As a result, it is included in this analysis.
3.4 SOIL, WATER, AND WATERSHED

3.4.1 SCOPE OF ANALYSIS
Issue 1 – Stormwater Runoff: The permit area is subject to localized, high-intensity summer thunderstorms.
Coupled with steep, rugged terrain, this results in periodic, sudden runoff events, and gullying.
Development of the proposed infrastructure would alter ground cover and soil permeability and could
influence the timing, intensity, and quantity of stormwater runoff. Downgradient wells could be damaged
if wellheads were flooded or groundwater was contaminated.
Indicator: A model-based analysis of runoff from high-intensity thunderstorms under pre- and post-project
scenarios, with and without mitigation. Model results and other factors are considered in assessing potential
effects on downgradient wells.
Issue 2 – Soil Erosion and Stability: The permit area is characterized by steep slopes, erosive soils, and
sparse ground cover. Construction of the proposed ski area infrastructure would involve substantial
clearing, grading, and excavation. On trails, soil surfaces would be kept bare by subsequent maintenance
and use. These actions may affect the extent and severity of soil erosion.
Indicator: An erosion and sedimentation risk rating for each element based on soil type, disturbance area,
intensity of disturbance, slope, presence of a runoff pathway, distance to a water body, and efficacy of
proposed mitigation, and a qualitative assessment of how any increase in runoff and sedimentation would
affect wells lower in the watershed.
43
Issue 3 – Snow Accumulation and Snowmelt: The permit area supports extensive forest vegetation. Clearing
and glading of currently forested areas to develop ski runs would entail tree removal. This in turn would
increase exposure of the snowpack to sunlight and wind. As a result, tree removal may affect the timing,
rate, and quantity of snowmelt.
Indicator: A mostly qualitative discussion of the anticipated change in timing, rate, and quantity of
snowmelt runoff based on the acreages involved and best available science regarding clearing effects.
3.4.1.1 Background and Methods

3.4.1.1.1 Issue 1 – Stormwater Runoff
In general, surface runoff from rainfall events can be estimated using precipitation and watershed
characteristics, specifically topography, soil type, and landcover. Changes in runoff resulting from
management alternatives can also be modeled by adjusting factors that would change (e.g. landcover) from
existing conditions under each scenario.
The USDA Natural Resources Conservation Service (NRCS) developed a widely accepted method to
estimate the amount of direct surface runoff from storm events (i.e., peak flood events) in a particular area
(NRCS 2004). Data inputs needed for this method include landcover and other surface characteristics that
influence runoff. Precipitation from a design storm (i.e., known precipitation depth, duration, and
probability of occurrence) is also used in the model. The model output is a runoff estimate that accounts for
local factors, expressed in terms of surface runoff and any shallow subsurface flow that enters the targeted
stream channel in response to a storm event. The NRCS runoff-method was incorporated by the EPA into
the Stormwater Management Model (EPA 2015) to simplify calculations and standardize runoff
estimations.
The model does not account for baseflow contributions from deep groundwater. Stream channels in the
permit area do not support base flow, but they do transport runoff following intense storm events and some
minor intermittent flows during spring snowmelt. As a result, this method is an appropriate and efficient
way to estimate impacts on runoff from land-use changes in the permit area.
Watershed models include assumptions to account for variability and interactions that occur on different
spatial and temporal scales. Assumptions provide a practical way to account for variability in situations
where actual measurements are unavailable or difficult to collect. Conservative assumptions allow
characterization of worst-case conditions and capturing of potential maximum impacts. A reasonable level
of conservative assumptions was used to model runoff in the permit area in order to estimate the potential
magnitude of peak runoff. In this case, our assumptions incorporated a large amount of variability in the
study area (e.g., small-scale variations in soil properties and the distribution of precipitation) in order to
create scenarios suitable for modeling.
In most situations, the best application of model results is to examine relative differences between modelled
scenarios (e.g., existing conditions versus proposed changes), rather than the absolute value and accuracy
of a single scenario. This approach is particularly true when examining infrequent, short-duration events
and processes. Although model results based on conservative assumptions may overestimate actual runoff
somewhat, the difference between model scenarios is an accurate and defendable method to identify the
impact of action alternatives relative to existing conditions. If proposed projects are approved, additional
modeling is recommended using site-specific data to identify environmental impacts at greater spatial and
temporal resolution which would also minimize conservative assumptions and construction costs.
The computer model used to estimate peak runoff from the permit area (InfoSWMM) is a modified version
of the Stormwater Management Model (EPA 2015) that can estimate peak runoff from design storms.
InfoSWMM can be applied in both urban and rural settings and uses precipitation combined with GIS data
to account for spatial variability in soils, topography and surface cover. A total of seven cover types were
identified in the permit area.
44
For modeling purposes, runoff from the permit area is captured in five drainages. Four of these drainages
discharge to Camp Lee Canyon, where property damage from stormwater runoff has been a concern. One
of these contributes negligible flow, and runoff from the fifth drainage bypasses the Camp to the west. As
a result, runoff modeling was completed for the three drainages that would be expected to have a measurable
runoff into the area of the camp. These drainages are unnamed, but for purposes of the analysis they are
called the East, Center, and Bristlecone drainages (Figure 3-2). The total area in these three drainages is
about 918 acres, including 717 acres in the permit area itself.
Peak runoff was estimated with InfoSWMM under existing conditions as well as the proposed action and
BCT alternative (JUB 2017). Runoff estimates were determined for design-storm events, including storms
with a 2-year (2.6 inches in 24 hours), 25-year (5.6 inches), and 100-year (7.3 inches) probability of
occurrence (Bonnin et al. 2011). These recurrence intervals indicate the statistical probability of a storm of
that magnitude occurring once in any given year. For example, there is a 1 in 100 chance of a 7.3-inch storm
occurring in any given year in the permit area. This statistic is based on the long-term average time between
storm events (Holmes and Dinicola 2010). However, intense storm events happen on an irregular basis and
could occasionally happen more frequently than the recurrence interval, and even occur multiple times in
the same year.
Peak runoff under the proposed action and the BCT alternative was estimated for the three drainages that
flow to Camp Lee Canyon. Several different scenarios were modeled to determine the effect of 1)
disturbance only (i.e., no BMPs), 2) physical BMPs only (including water bars and flow diversion
structures), and 3) full recovery including physical BMPs and full vegetation regrowth on disturbed areas.
The need for additional mitigation of flow increases was recognized early in the analysis, and the influence
of a detention basin was also estimated for each scenario. This detention basin utilizes the proposed parking
lot to capture a peak volume of 19.5 acre-feet of runoff. This is the estimated peak runoff amount (based
on conservative assumptions) from a 100-year precipitation only event (i.e., not a rain-on-snow scenario).
Actual runoff from this type of storm could potentially yield less runoff and additional project-specific
modeling after projects are approved could be done to improve accuracy of estimates and possibly require
less extensive mitigation, such as a smaller detention basin.
Potential effects on infrastructure and water quality were assessed based on model output regarding volume
and intensity of stormwater runoff coupled with information on location of wells and other infrastructure,
type and location of fuels and other potential contaminants at the ski area, and relationships between surface
and groundwater. Climate change information from recent Forest Service assessments for the West
(Halofsky et al. 2018) and the HTNF (Tausch 2011) was considered projecting potential effects.
3.4.1.1.2 Issue 2 – Soil Erosion and Stability
Erosion and transport of sediment are focal points in the analysis for Issue 2. Natural erosion processes are
part of soil development. However, prior to stabilization, erosion from areas disturbed by construction can
occur at an accelerated rate. The method used here to assess erosion and sedimentation hazard resulting
from proposed development is the connected disturbed area (CDA) approach (Furness et al. 2000; Forest
Service 2006). It involves the following steps for each proposed project element:
1. Determining the pre-mitigation erosion potential based on the erosion hazard of the affected soil
types, the size of disturbance, the intensity of disturbance (i.e., clearing through excavation), the
slope of the disturbed area, and the distance to the closest drainage channel or other runoff pathway
(road or trail).
2. Identifying appropriate BMPs to mitigate erosion and sedimentation hazard.
3. Assessing the post-mitigation erosion risk based on the efficacy of the identified BMPs.
Based on the factors listed in point 1, project elements are assigned a pre-mitigation risk rating of high,
medium, or low for erosion and sedimentation. Generally, elements are assigned a high risk rating if they
have two or more of the following attributes: large disturbance area (greater than 1 acre), steep slopes
(greater than 50 percent), and proximity to a runoff pathway. Elements are assigned a moderate risk rating
45
if they have one of these attributes and a low risk rating if they have none. The other two factors, soil erosion
hazard and intensity of disturbance, are considered to resolve border-line risk ratings.
The CDA approach prescribes “disconnecting” disturbed areas. If sediment sources are disconnected from
the “easy pathways” down the mountain, the total sediment yield to runoff pathways can be greatly reduced
(Furniss et al. 2000).
Specific BMPs to reduce erosion, disconnect disturbed areas from erosion pathways, and minimize the
watershed and water quality impacts of each element are identified in the CDA analysis for the proposed
action. These measures are described in more detail in section 3.4.5, following the discussion of direct and
indirect effects, and in section 2.6. Most of these BMPs are core measures recommended by state and
federal agencies. A more detailed discussion of these measures is available in Appendix B as well as the
references cited with these measures.
3.4.1.1.3 Issue 3 – Snow Accumulation and Snowmelt
A literature review was conducted to identify recent, pertinent research regarding differential snow
accumulation and snowmelt behavior between forested and non-forested areas. Climatological data from
2008 to 2017 was obtained from the Lee Canyon and BCT SNOTEL sites to assess local weather patterns.
A qualitative assessment of the potential effects of tree clearing under the proposed action on snow
accumulation and melt was developed based on parameters discussed in the literature. Acreage that could
be affected by the proposed action or the BCT alternative was obtained from GIS.
3.4.2 AFFECTED ENVIRONMENT

The area of analysis for soil, water, and watershed resources is defined as the ski area’s special use permit
area (permit area). It consists of 785 acres in the Spring Mountains northeast of Las Vegas, Nevada. At
11,289 feet, Lee Peak is the major topographic feature in the area.
The permit area is located at the upper end of the Lee Canyon subwatershed and is part of the greater Las
Vegas Wash Sub-basin. Three unnamed drainage channels convey most runoff from the permit area and
converge near Camp Lee Canyon. Most facilities at Camp Lee Canyon are located in the bottom of a narrow
valley or swale that receives flow from these three upslope drainages.
3.4.2.1 Issue 1 – Stormwater Runoff

Climate in the Spring Mountains is influenced primarily by geographic setting, topographic relief, and
atmospheric circulation patterns (Moreo et al. 2014). These mountains are in the rain shadow of the Sierra
Nevada Mountains to the west. Although winter storms moving east over the Sierra Nevada are generally
low-pressure and low-intensity, they account for the majority of annual precipitation. Based on area-
weighted averages (1981–2010), mean annual temperature and precipitation depth for the permit area is
40.3 ºF and 21.6 inches, respectively (PRISM 2017).
Depending on the time of year, precipitation in the permit area can occur as either rain or snow. Local
precipitation records are available from two locations, the Lee Canyon and BCT Snowpack Telemetry
(SNOTEL) sites (NRCS 2017a, NRCS 2017b). Mean annual precipitation depths at these sites are 23.4 and
21.9 inches, respectively, based on the 2009–2016 data record. More details on snow accumulation,
snowmelt patterns, and timing of snowmelt are provided below under Issue 3, but the focus of analysis
under this issue is intense summer rain storms.
Extensive analysis completed by the Forest Service addressing the HTNF (Tausch 2011) and the western
U.S. (Halofsky et al. 2018) provides the best projections currently available on climate change and its
effects on precipitation and runoff. While these broad studies do not provide detailed data to support in-
depth site-specific analysis and conclusions, they do provide meaningful insight into this issue. The studies
indicate that projected temperature changes are considerably more consistent than precipitation changes,
particularly in mountainous areas. As a result, the studies conclude that warmer winters will result in less
snow and more rain, with more intense winter storms, but they make few predictions about summer
46
precipitation – the concern in this analysis. The Halofsky et al. (2018) study does suggest that spring and
early summer precipitation may be reduced somewhat over time in the Southwest (p. 61). In short, based
on these studies, climate change is not anticipated to affect the magnitude or frequency of high-intensity
summer storms at Lee Canyon and is not discussed further here.
Figure 3-1 reflects the daily maximum depth from rain events only during 2008–2017. Most of these events
occur from July–November of each year. Summer precipitation events in the Spring Mountains are
influenced by monsoonal air flow from the south that creates localized, high-intensity and short-duration
storms (Moreo et al. 2014). It is not uncommon to have summer storms (and resulting surface runoff) affect
one drainage in the permit area while adjacent drainages remain dry (Hooper 2017).
Lee Canyon SNOTEL site

Daily Maximum Rainfall (2008 - 2017)
5
4.5
4
3.5
Precipitation (in.)
3
2.5
2
1.5
1
0.5
0
Jan
Jan
Nov
Nov
Dec
Dec
Feb
Feb
Apr
Apr
Apr
Sep
Aug
Aug
Mar
Mar
May
May
Oct
Oct
Oct
Jun
Jun
Jul
Jul
Precipitation (in.)
Figure 3-1. Daily maximum rainfall recorded at Lee Canyon Snow Telemetry (SNOTEL) site. Values
shown are based on days where average temperature was greater than 32º F.
Intense summer storms occurred in 2008 and 2017, generating runoff that damaged buildings, roads, and
other infrastructure in the base area and at Camp Lee Canyon. During the two 2017 storms the Lee Canyon
SNOTEL site recorded 2.2 inches of precipitation on July 24, and 4.6 inches on August 4. These storms
lasted 12 hours and 3 hours, respectively, and produced significant runoff in the base area and Camp Lee
Canyon (Hooper 2017, Bernhardt 2017). Soil surfaces with minimal or no vegetation or other surface cover
were particularly susceptible to erosion. The 2.2-inch storm and the 4.6-inch storm generated approximately
the same precipitation amounts as the 2-year and the 25-year design storms used in our modeling,
respectively.
Lee Meadows is located downstream from the permit area and Camp Lee Canyon, adjacent to the main
stream channel in Lee Canyon. This meadow was inundated during the intense storms in 2017 across the
entire width of the Canyon. The area functioned as a floodplain to buffer peak stream velocities and remove
sediment loads that would normally settle in downstream channel segments.
47
Effects of these storms dissipated quickly below Lee Meadows and were generally highly localized and
short-lived overall. This was due to physical factors (e.g., geology, soils, and topography) and biological
conditions (e.g., vegetation and other ground cover) that drive hydrologic functioning in the Spring
Mountains.
Ephemeral channels are present in the upper watershed areas and contain flow during intense storm events,
but most water in these channels is quickly lost to groundwater recharge through the underlying alluvium.
Measured water levels from wells in Lee Canyon indicate that alluvial material near the surface is rarely
saturated. It is not uncommon to have years where no flow is present in stream channels in the Spring
Mountains (Moreo et al. 2014, Hooper 2017).
No flow records are available for channels in the permit area. While many of the larger storm events shown
in Figure 3-1 likely generated some surface runoff, flow quickly infiltrated rather than contributing to
downstream flows. One USGS stream gage (9419610 – Lee Canyon near Charleston Park, Nevada) is
located in upper Lee Canyon, approximately 3 miles downstream of the permit area. The gage has been
inactive since 1994. The drainage area contributing flow to the channel at this location is 9.2 square miles.
The stream gage record includes 11,323 days (1963–1994), during which measurable flow occurred on only
49 days. Maximum instantaneous peak flow during this period was 880 cubic feet per second, with a mean
daily streamflow of 0.018 cubic feet per second (USGS 2017). This data record provides historic evidence
of the extremely limited amount of surface flow in the permit area and the subwatershed.
Runoff from the permit area is generated from land inside the permit area boundary and areas upslope of
the boundary. These drainages total approximately 1,080 acres, including all 785 acres of the permit area.
Landcover in these drainages is primarily forested (95 percent). The remaining 5 percent is covered by a
combination of avalanche chutes, cliffs and scree, ski runs, buildings, roads, and trails. Manmade features
(e.g., roads, trails, and water bars) and natural stream channels can act as runoff pathways by concentrating
surface runoff. Concentrated flow has a higher velocity and greater ability to generate gully erosion
compared to dispersed surface runoff. However, BMPs used in parts of the permit area are designed to
disperse surface runoff from ski runs, roads, and trails into forested areas where flow energy is dissipated
and water can infiltrate into the soil.
Both surface vegetation and soil characteristics influence surface runoff. Any properties that increase the
bulk density of soil including roots and other organic material, gravel, rock fragments, etc., also promote
infiltration, which in turn reduces runoff. In general, these physical factors are relatively constant within a
given year. Wildland fire can change the composition of surface vegetation and structure of near surface
soil layers. However, the timing, extent, and intensity of wildland fire impacts in and around the ski area
cannot be defined in detail, given the periodic nature of these events. The low density of forest and
understory cover in and around the permit area would generally support low- to moderate-intensity fires
with less impact occurring on ski runs where overstory vegetation is absent.
In terms of potential effects on downgradient wells, three groundwater wells are located in the permit area,
and one additional well is located downslope at Camp Lee Canyon (Figure 3-2; Bernhardt 2017, Hooper
2017). These wells are used for culinary purposes and for snowmaking at the ski area. Two permit-area
wells are located on slopes that drain away from the wellhead. The third permit-area well is located on flat
ground protected by a berm that diverts upslope runoff away from the wellhead.
The siting of these three wells protects them from potential damage due to surface stormwater flows, but
the well at Camp Lee Canyon is more exposed. A primary source of culinary water for the camp, it is
located in a swale that receives surface runoff from upslope drainages in the permit area. The wellhead is
protected by low soil berms located on the south and west sides of a fenced enclosure. This arrangement
has successfully diverted flow from past runoff events, but it requires routine maintenance and upkeep
(Bernhardt 2017).
48
Figure 3-2. Soil and watershed resources in the permit area.
49
Surface runoff from intense storm events could possibly contaminate this well if runoff and transported
debris covered the wellhead, damaged the structure, and flowed into the well casing itself. The borehole
casing for this well is grouted to prevent surface flow from moving down the outside of the casing into the
aquifer. However, the top of the wellhead is set below the ground surface inside a manhole large enough
for camp personnel to enter and complete routine maintenance and water sampling. This enclosure could
potentially fill with surface runoff and submerge the wellhead if runoff were to flow over the protective soil
berms.
Beyond that, there is some potential for groundwater contamination that could affect this and other area
wells. As discussed above, runoff does not travel far before percolating into the soil profile, potentially to
groundwater. It could carry with it any surface contaminants present. Snowmelt runoff rather than
stormwater is likely a greater concern, since it provides approximately 90 percent of the total annual
recharge volume (Winograd et al. 1998).
Parking areas are a source of some contaminants (e.g., oil, antifreeze, and highway ice melting products)
which can be mobilized by runoff and potentially affect groundwater, and parking lots are used primarily
in winter. In addition, hazardous fluids are stored and used in the permit area. Potential contamination is
managed according to the ski area’s Spill Prevention, Control and Countermeasure (SPCC) Plan. The SPCC
plan complies with existing state and federal regulations pertaining to pollution prevention of receiving
water bodies, and it addresses all relevant measures applicable to the permit area. Hazardous fluids stored
and used in the permit area include fuel, oil, lubricants, solvents, paint, etc., that are necessary for normal
ski area operations. With the exception of fuel, these fluids are kept in containers up to 55 gallons, stored
in compliance with applicable regulations. Three large fuel storage tanks (two underground and one above
ground) are located near the maintenance facility. All underground tanks are equipped with continuous
monitoring systems, and above-ground tanks are located inside secondary containment structures. There
have been no spill events in the permit area under current management and since the SPCC was
implemented.
In the event that contaminants are released at the surface, the soil matrix acts as a filter to remove suspended
sediment and adsorb dissolved chemicals. In general, depth to groundwater is 400 feet or more near the
mouth of Lee Canyon and about 130–300 feet in the upper watershed (Plume 1989). Based on the limited
amount of contaminants likely to be released and the depth to groundwater, there is very limited potential
for surface runoff to produce impacts on groundwater quality through the process of groundwater recharge.
Groundwater wells in Nevada used for culinary purposes are protected by federal regulations that require
monthly monitoring and public notification if contamination by coliform, hydrocarbons, or other pollutants
occurs (EPA 2009, EPA 2010a, EPA 2010b). A sample from a permit-area well measured positive for E.
coli in 2016. Following monitoring protocol, an additional sample was collected the following day and the
results were negative (Hooper 2017). No other possible contamination has been identified by past
monitoring of the culinary well at Camp Lee Canyon (Bernhardt 2017).
3.4.2.2 Issue 2 – Soil Erosion and Stability

Soil information on the permit area was obtained from the national Soil Survey Geographic Database
(NRCS 2017c) and a soil survey of Clark County, Nevada (NRCS 2006). There are three soil types in the
permit area (Figure 3-2 and Table 3-5), and the proposed developments under the proposed action and the
BCT alternative are located on two of these soil types. Soil types in the permit area vary based on slope,
geology, landform, and micro-climate. As shown in Table 3-5, erosion potential for these soil types ranges
from none (on rock outcrop) to severe. The erosion-potential rating classes reflect slope and soil physical
factors that contribute to erodibility.
Over 80 percent of the permit area is Ladyofsnow-Robbersfire-Maryjane association soils. These soils are
found at moderate to high elevations and characterized by a well-drained profile and a depth to bedrock
between 39 and 60+ inches (NRCS 2017c). The Mountmummy-Thesisters-Maryjane association makes up
about 15 percent of the permit area and is located along the southern and northwest borders. Soils in this
50
association are extremely gravelly silt loams that are well-drained and have a depth to bedrock between 4
and 60+ inches (NRCS 2017c). The remaining codominant soil type is Maryjane extremely gravelly loam,
covering 2 percent of the permit area. Other minor inclusions are found within the three soil associations
discussed here, but their influence on soil properties is unimportant in the permit area.
Erosion occurs when the surface layer of topsoil is worn away by water, wind, or other forces, and in severe
cases the lower layers are also removed. Water erosion is the primary soil loss factor in the permit area, and
the degree or severity of this type of erosion is influenced by soil type and slope. As indicated in Table 3-
5, erosion potential for these soil types ranges from none (on rock) to severe. Slopes in the permit area
range from approximately 3 to 150 percent, and surface erosion is worse on steeper slopes, particularly
from midway down to the toe of the slope. As noted under Issue 1, surface runoff in the permit area is
generally localized and short-lived. Erosion and sediment transport are generally the same, with most
sediments deposited where slopes flatten at the base area. Little deposition occurs below the permit
boundary.
Table 3-5. Soil properties in the permit area (NRCS 2017c).

Surface Permit
Organic Depth to
Name (map unit Erosion Area
Parent Material Matter restrictive Slopes
symbol) Potential (% (ac/% of
Content layer1
of map unit) total)
Colluvium derived Severe
775: Ladyofsnow- Surface
from limestone and (75%),
Robbersfire- horizon: 29-65 15 - 75 662 /
dolomite, alluvium > 60 inches Moderate
Maryjane %, Subsurface percent (84%)
derived from (23%), Rock
association horizon: 3 - 7 %
limestone. outcrop (2%)
Colluvium and/or
Severe
residuum weathered Surface
905: Mountmummy- (77%),
from limestone and horizon: 4 - 65 15 - 75 110/
Thesisters-Maryjane < 39 inches Moderate
dolomite, alluvium %, Subsurface percent (14%)
association (20%), Rock
derived from horizon: 0 - 7 %
outcrop (3%)
limestone.
Severe (7%),
916: Maryjane Surface
Moderate
extremely gravelly Alluvium derived horizon: 65 %, 8 - 30 13/
> 60 inches (90%), Slight
loam, 8 to 30 from limestone. Subsurface percent (2%)
(1%), Rock
percent slopes horizon: 7 %
outcrop (2%)
1 Depth to restrictive layer represents at least 50 percent of map unit.
In the permit area, erosion has historically occurred as rill and gully erosion in response to intense summer
storm events. Small rills can become deep gullies during a single storm or from a series of storms if left
unmanaged. Erosion from snowmelt runoff has not been a concern in the permit area. As discussed above
under Issue 1, climate change is not anticipated to have a discernible effect on the intensity or frequency of
summer storms according to recent Forest Service research (Halofsky et al. 2018).
In 2006 the Forest Service suspended revegetation efforts, which had been successful at reducing erosion
in the past, with the objective of developing a revegetation seed mix that included more native plants. In
order to address the ongoing erosion problem, an erosion and sediment control plan was created in 2008
(Stantec 2008). This plan emphasizes physical BMPs to prevent erosion, including the creation of diversion
ditches and water bars to move water away from sensitive areas. In addition to preventative measures, the
plan also outlines actions to be taken in emergency circumstances, such as filling rills and gullies, and
51
localized re-grading. This plan was an important source of BMPs developed specifically for the ski area,
and pertinent BMPs were incorporated into this analysis (section 3.4.5).
Vegetative ground cover plays a key role in erosion prevention because it can stabilize the topsoil during
high intensity storm events. Sparse ground cover leaves the soil susceptible to erosion. Any area that lacks
consistent root structure, including disturbed areas that have been revegetated and undisturbed forest areas,
can be vulnerable to erosion. See section 3.5 for a detailed description of vegetation in the permit area.
Previously, heavily disturbed areas have either been reseeded or permitted to regrow naturally.
3.4.2.3 Issue 3 – Snow Accumulation and Snowmelt

The analysis area is characterized by forested areas intermixed with non-forested areas corresponding to
avalanche chutes, cleared ski trails, parking lots, and related infrastructure. Approximately 95 percent of
the analysis area is forested. Within the analysis area, there are 37.2 acres of existing ski trails, and
approximately 14 acres that have been gladed. Surfaces adjacent to the base area buildings and lower lift
terminals are relatively flat, but slopes increase rapidly above this area. The dominant drainages are oriented
north-south, resulting in a general northerly aspect in the analysis area. However, the pronounced ridges
between the drainages produce secondary east or west exposures for much of the ski area.
Based on data from the Lee Canyon and BCT SNOTEL sites, consistent snowfall accumulation typically
begins in early November (ranges from November 3 to December 14 with a median date of November 22),
is limited in November, then increases during December and lasts through early March. Snowmelt typically
begins in March, and accumulated snow is typically gone by early May (ranges from March 25 to May 10,
with a median date of April 18).
Temperature patterns, based on data from the Lee Canyon SNOTEL sites for the same 2008–2017 period,
were also analyzed. The average daily temperature was calculated for this 9-year period. During the
December–February period, the average daily temperature was 31.2° F. Inter-annual differences would
result in some years being cooler or warmer than other years.
How snowfall accumulates, how long it remains, and how quickly it melts are influenced by a number of
variables including the timing of snowfall, snowfall intensity, snowfall amount, temperature, time of year,
wind behavior, exposure to radiation, and forest canopy characteristics. Characteristics of winter storm
events and when they occur are generally not influenced by physical conditions in the permit area. However,
vegetation cover can influence some of the factors influencing how snow accumulates and melts, including
radiation, sublimation, wind, and density or water content. The interactions are complex.
In terms of radiation, snow surfaces are exposed to shortwave radiation (light energy) and longwave
radiation (heat energy). In forested areas, trees intercept snow, emit longwave radiation, and shelter snow
from wind and solar radiation (Lundquist et al. 2013). In some cases, sheltering snow from radiation results
in longer persistence of snow, while in other instances, longwave radiation emitted from the trees increases
snowmelt relative to snow in an open area.
Sublimation, the phase-change process of ice to water vapor, also influences snow persistence. Snow
intercepted in the tree canopy is typically sublimated at higher rates than snow on the ground underneath
the tree canopy. Sublimation is also typically higher in open areas relative to under the tree canopy (Svoma
2017). Sublimation rates in open areas are 3 to 10 times higher than those occurring in forested locations
(Lundquist et al. 2013).
Where wind deposition and redistribution play a large role in snow accumulation, or where surface energy
exchange is a primary contributor to snowmelt, snow was found to melt more slowly under a forest canopy
than in a clearing (Lundquist et al. 2013). Vegetation beneath the forest canopy is more sheltered and
typically experiences lower wind velocities and is exposed to less shortwave radiation, as well as having
higher humidity (Svoma 2017).
The amount of water in snow also affects retention and snowmelt. Snow density and snow-water-equivalent
content between forest and non-forested sites is affected by annual variability in snow totals. Based on plots
52
in healthy forest, beetle-killed forest, and clear cuts, in average to low snowfall years, snow depth and snow-
water-equivalent increased as percent canopy cover and stand density decreased, while in high snowfall
years, differences were reduced due to the ability of heavy snowfall to exceed interception capacity of the
canopy. (Boon 2012)
With all of these often-conflicting factors, it is not surprising that studies looking at whether snowmelt
occurs more quickly under forests or in clearings have reached conflicting conclusions. According to a
study analyzing the results of all observational studies of snowmelt patterns, in regions where the average
December–February temperature was greater than 30° F, forest cover reduced snow duration by 1–2 weeks
compared to adjacent open areas. This occurred because the dominant effect of forest cover shifted from
shading the snow and blocking the wind to accelerating snowmelt from increasing longwave radiation from
the trees. (Lundquist et al. 2013)
On the other hand, in areas with warmer air temperatures where snowmelt occurred earlier in the spring,
snow tended to last longer under trees than in the open. Early in the year, low sun angles prevail, and
longwave radiation from trees exceeds shortwave radiation from the sun. (Lundquist et al. 2013)
Thus whether snow lasts longer in an opening or in a clearing depends on if longwave (i.e., heat energy) or
shortwave (i.e., light energy) radiation is the dominant factor, as dictated by time of year (e.g., changes in
shortwave energy due to sun angle) and by climatological temperatures (e.g., changes in longwave energy
due to air temperature).
3.4.3 DIRECT AND INDIRECT EFFECTS

3.4.3.1 Alternative 1 – No Action
Peak runoff estimates derived from the InfoSWMM model for the permit area are shown in Table 3-6. As
discussed above in section 3.4.1.1, these estimates account for existing conditions that influence runoff
including topography, soil, and landcover, and they were determined for design-storm events with 2-year
(2.6 inches in 24 hours), 25-year (5.6 inches), and 100-year (7.3 inches) recurrence intervals. These
estimates represent the aggregated peak runoff that would occur from the East, Center, and Bristlecone
drainages that contribute runoff to main channels that drain to Camp Lee Canyon (Figure 3-2). These
drainages include land that is inside the permit area as well as upslope of the permit boundary. Runoff from
the Center and Bristlecone drainages converge just beyond the north permit boundary, immediately above
Camp Lee Canyon. Runoff from the East drainage empties into a channel that flows along the east side of
the Camp.
Table 3-6. Peak runoff estimates under current conditions from the East, Center, and Bristlecone
drainages (Figure 3-2).1
Aggregate Peak Runoff
Storm Return Interval (depth in inches)
(cubic feet per second)
100-year storm (7.3 in.) 1,736

25-year storm (5.6 in.) 1,030
2-year storm (2.6 in.) 106
1See JUB 2017 for additional detail.
Under the no-action alternative, intense summer storm events would continue to generate maximum surface
runoff, and the timing, extent, and amount of runoff would be similar to existing conditions described in
53
section 3.4.2. Runoff would flow from mountain slopes to the base area and beyond the lower permit
boundary, losing volume rapidly to infiltration as it moved downslope. Runoff events would remain intense,
localized, and short term.
Small decreases in runoff would occur over time in areas where low-growing vegetation (e.g., grasses,
forbs, shrubs) on ski runs became more established. Existing landcover by cover type is shown in Table 3-
7. Any changes in landcover that increased the density of low-growing vegetation would serve to detain
and disperse runoff and provide additional opportunities for runoff to infiltrate into the soil.
The potential for runoff flooding the wellhead at Camp Lee Canyon would not change – it would remain a
possibility during higher intensity storms. Groundwater contamination would remain unlikely due to
minimal surface contaminants and great depth to groundwater.
Table 3-7. Landcover in the permit area under existing conditions.

Landcover Type Existing Landcover (ac)
Brush 24.2
Building 0.3
Unpaved Road/Trail 4.9
Forested 702.0
Gladed 10.4
Paved 4.7
Ski Run 37.1
Water 1.3
Total (ac) 784.9

No development would occur under the no-action alternative, and existing levels of soil erosion and stability
would generally remain as described in section 3.4.2. Erosion would continue to occur at roughly existing
rates, particularly in areas where soil surfaces were exposed to raindrop impact or concentrated flow.
Vegetation cover on existing ski runs would continue to develop in some areas where immature and
relatively new growth exists. Large erosion features (e.g., headcuts and gullies) would continue to be
repaired as needed in the permit area once project-specific authorization was provided.
Under the no-action alternative, no new clearing or glading would occur. Landcover would remain as shown
in Table 3-7. No notable change in the existing pattern of snow accumulation and snowmelt, as described
in section 3.4.2.3, is anticipated. Daily and seasonal differences in weather patterns would be the dominant
variable affecting snow accumulation and melt patterns in both clearings and under forest canopy.
3.4.3.2 Proposed Action

To facilitate comparison, peak runoff estimates associated with existing conditions and the proposed action
are shown in Table 3-8. Aggregate peak runoff estimates are shown for the three primary permit-area
drainages that drain to Camp Lee Canyon (i.e., East, Center, and Bristlecone drainages; Figure 3-2) under
current conditions and the proposed action. Estimates are provided with and without physical BMPs, with
full rehabilitation, and with and without a detention basin.
54
These estimates assume that all disturbances would occur simultaneously under the proposed action, the
“worst-case scenario.” In reality, these disturbances would occur sequentially, allowing time for installation
of physical BMPs and some regrowth of vegetation before the next project element was started. The “No
BMP” scenarios are included to show the effectiveness of the required BMPs and do not represent situations
that would actually occur. The difference between the “With BMP” scenarios and the “Fully Rehabilitated”
scenarios is regrowth of vegetation in disturbed areas, either by seeding (with a Forest Service-approved
seed mix) or by natural regrowth.
Table 3-8. Peak runoff estimates (cubic feet per second) under the proposed action in response to a
24-hour design storm. 1
Current Proposed Action
Conditions
(cubic feet No Detention Basin Detention Basin Installed
per second) (cubic feet per second)/ % Change (cubic feet per second)/ % Change
Storm Return
Interval No With Fully No With Fully
No BMPs
(depth in BMPs BMPs Rehabilitated BMPs BMPs Rehabilitated
inches)
100-year 1,913/ 1,854/ 1,903/
Storm 1,736 1,758/1.3% 1,839/5.9% 1,726/-0.6%
10.2% 6.8% 9.6%
(7.3 in.)
25-year Storm 1,162/ 1,126/ 1,150/
1,030 1,054/2.3% 1,111/7.8% 1,026/-0.4%
(5.6 in.) 12.8% 9.2% 11.7%
2-year Storm 142/ 137/ 94/

106 117/10.6% 46/-56.7% 37/-64.6%
(2.6 in.) 34.0% 29.5% -11.3%
1
See JUB (2017) for additional detail.
Increases in modeled runoff prior to mitigation are due to changes in landcover and the characteristics in
each landcover type that influence runoff. For most project elements, landcover would change within the
disturbance area for that element (see Table 3-9). One important change would be an increase of 4.5 acres
of impervious surface from buildings and pavement, and 6.2 acres of hardened surfaces from service roads
and biking and hiking trails. These landcover changes would dramatically increase runoff per acre, but the
acreage involved would be small. (Note these increases are based on each element’s finished footprint and
not on total disturbance presented in Table 3-10. The remaining disturbed area would be subject to changes
in vegetation cover type rather than conversion to impermeable or hardened surfaces.)
The larger landcover changes, such as conversion of forest to ski runs or glades, would affect pre-mitigation
runoff less dramatically but would still increase it. Relative to the no-action alternative, the proposed action
would increase cleared areas (primarily ski runs) by 90.6 acres and gladed areas by 23.0 acres in the permit
area.
Changes in soil condition that reduce infiltration and increase runoff would also occur in the disturbance
areas associated with the proposed action. Soil bulk density and surface roughness could be adversely
affected by: removing vegetation, litter and roots; operating heavy equipment traffic; grading; and
excavation. Such effects would generally be smaller and more localized than the major landcover changes.
55
Table 3-9. Landcover in the permit area under existing conditions and the proposed action.
Landcover Type Existing Landcover (ac) Proposed Action (ac)/% Change
Brush 24.2 9.6/-60%
Building 0.3 0.7/133%
Unpaved Road/Trail 4.9 11.1/126%
Forested 702.0 592.3/16%
Gladed 10.4 33.4/321%
Paved 4.7 8.8/87%
Ski Run, Other Rehabilitated Areas 37.1 127.7/244%
Water 1.3 1.3/0%
Total (ac) 784.9 784.9
The impact of changed landcover and soil conditions on runoff and infiltration would be minimized in the
short term with physical BMPs and other practices that disperse runoff and provide opportunities for
infiltration to occur. Additional reductions would be achieved as ski runs and other disturbed areas were
revegetated. Past experience has shown that vegetation cover successfully controls soil and gravel
movement in the permit area (Stantec 2008). Soil bulk density also decreases as root structures penetrate
disturbed soils, resulting in increased infiltration during runoff.
The suggested runoff detention pond would create the greatest reduction in peak runoff from the ski area
for any given scenario (Table 3-8). Under the proposed action, a new parking lot would be constructed
below the lower base area. This structure would be designed to intercept and detain the majority of runoff
from upslope areas to Camp Lee Canyon. Vehicle use of the new parking lot would not occur during the
summer season and would not interfere with this purpose. The proposed parking lot would include 3.6 acres
of pavement. It would be designed as a tiered structure defined by vertical retaining walls to temporarily
store a total of 19.5 acre-feet of water. The downslope retention wall of each tier would include one or more
discharge points at designed locations to regulate flow out of the detention basin. Runoff discharging from
the lot would be treated with French drains, catchment basins and other industry standard structures to
remove oil, grease, sediment, and other pollutants. Treated stormwater runoff from the parking lot would
then be discharged below the lot.
Notable results of modeled peak runoff estimates under the proposed action include:
1. Unmitigated peak runoff (i.e., without BMPs) would increase above existing conditions for all
storm events by 10–34 percent. The 100-year storm would increase peak runoff by about 10
percent, and this proportion would increase for 25-year and 2-year storms. This pattern of greater
differences in runoff between existing conditions and the proposed action for smaller storm events
holds for all scenarios.
Although the difference between existing and modeled peak runoff is less for storms with large
return intervals compared to smaller storms (e.g., a 100-year storm vs. a 2-year storm, respectively),
the volume of increased runoff produced by large storms is substantially greater. As a result, the
changes associated with large storms have greater potential for resource impacts. The large
decrease exhibited by mitigated runoff from small storms is due primarily to the effect of the
detention basin.
2. Use of BMPs would reduce peak runoff by 3–5 percent below estimates without BMPs for a net
increase of 7–30 percent over existing conditions.
56
3. The BMPs considered in the modeling are physical and would include reinforced water bars and
water diversion ditches on existing and proposed ski runs, rolling dips on road surfaces and trails,
and correctly installed silt fences and straw wattles. Additional BMPs are identified in section 3.4.5
below.
4. Under the proposed action, fully rehabilitated conditions would result in only a 1–2 percent increase
above existing peak runoff for the 100-year and 25-year storm events, respectively and an 11
percent increase for the 2-year storm event.
5. Under the proposed action, peak runoff estimates for fully rehabilitated conditions with a detention
basin scenario range from less than 1 percent to 65 percent less than existing conditions.
6. This modeling of peak runoff was based on conservative assumptions (section 3.4.1.1 above),
including:
a. Design-storm scenarios assume consistent precipitation over the entire permit area. In
reality, intense thunderstorms and runoff events are typically isolated to only a portion of
the permit area (Hooper 2017).
b. Runoff estimates for disturbed conditions assume all disturbances would occur
simultaneously. In reality, construction of proposed elements would be staggered and
include BMP installation and time for some vegetation to establish on disturbed surfaces.
c. Use of the 100-year design storm to identify peak runoff and potential impacts is very
conservative. As noted above, the 100-year storm has a 1 in 100 chance of occurring in any
given year compared to the 2-year design storm which has a 1 in 2 chance of occurrence.
In summary, differences in peak runoff estimates between the proposed action and existing conditions can
be reduced to an increase of about 1 percent for the 100-year storm using physical BMPs and full restoration
of disturbed surfaces. A detention basin is needed in addition to BMPs and full restoration to reduce peak
runoff under the proposed action to less than existing conditions for all design-storm scenarios.
The potential for stormwater runoff to cover the wellhead at Camp Lee Canyon would be less than under
existing conditions. This is due primarily to implementing the detention basin and full restoration of
disturbed surfaces. Peak runoff from relatively small storm events (i.e. 2-year storm) would be substantially
less under the proposed action than under existing peak runoff estimates.
The effectiveness of proposed physical BMPs and revegetation would result from increased infiltration of
runoff. However, groundwater contamination would remain unlikely due to minimal surface contaminants
and the great depth to groundwater.
As indicated above in section 3.4.1.1, peak runoff estimates are based on conservative assumptions and
predict a maximum level of runoff from design storms. Actual runoff from design storms could potentially
yield less runoff. Additional modeling is recommended using site-specific data if proposed project elements
are approved. Results from this effort would minimize the need for conservative assumptions and identify
environmental impacts at greater spatial and temporal resolution which would also minimize conservative
assumptions and construction costs.
The results of the CDA analysis under the proposed action are presented in Table 3-10. Most elements
would be located on the Ladyofsnow-Robbersfire-Maryjane soil family association. This soil type covers
more than 80 percent of the permit area, and approximately 75 percent of this soil association has a severe
erosion-potential rating. The remaining 25 percent of this association has a moderate erosion potential
mixed with rock outcrop. Soil erosion potential is lowered where rock outcrops and rock fragments are
present at the soil surface.
Disturbance from individual project elements would range from less than 0.1 acre (zip line terminals, power
line trenches for mountain coaster and Lift 6) to 57.4 acres (ski run clearing for Chair 8 pod). As shown in
57
Table 3-10, the proposed action would affect a total of 129.8 acres including 3.1 acres of clearing (ski lifts
and zip line) and 23.4 acres of glading which would have minor erosion potential as surface disturbance
would be limited to stump removal and skidding of trees. Grading would affect 88.5 acres, primarily during
construction of ski runs for the Chair 5 and Chair 8 pods (70.7 acres) as well as hiking and biking trails,
parking lots, and conveyor lifts (Lift 4 and Lift 6). Many elements of the proposed action include excavation
for structure foundations (first aid building, gate house, mountain coaster, rental shop, vault toilet, lift
towers, zip line terminals), utility trenches for water and power, and installation of septic tanks and drain
fields. A total of 14.8 acres would be disturbed through excavation.
Project elements that involve moderately steep areas (i.e., maximum slopes within disturbance area greater
than 50 percent) for even short distances would include bike trails, the first aid building, the gate house,
glading, the hiking trail, the parking lot, snowmaking utility trenches, zip line corridor clearing, the
mountain coaster building and track, and Chair 8 ski runs. For all elements of the proposed action, maximum
slopes range from 0 to 84 percent. (Note that some ratings are conservative, reflecting steep slopes within
the arbitrary disturbance buffer which in reality would be avoided during construction.)
All drainage channel crossings (including permanent and temporary crossings) and their approximate
distance from each element are noted in Table 3-10. As described in section 3.4.2, flow in permit-area
drainage channels occurs only occasionally, in response to storm events and, to a much more limited extent,
following snowmelt. Drainage channels are topographic low points where surface runoff collects and
continues downslope in the channel. Disturbance from some elements would overlap drainage channels.
However, all structures other than the parking lot would be located outside of channels to ensure structural
stability and long-term maintenance.
Glading and clearing activities both involve channel crossings. No structures are involved with glading,
and no lift terminals or towers would be installed in channels or floodplains where corridors were cleared.
Ski runs associated with the Chair 5 and Chair 8 pods involve drainage channels, and these areas could be
graded during construction. Channels would remain in their existing locations. Temporary channel
crossings by heavy equipment would occur, as needed, during construction activities.
Elements that involve permanent channel crossings include hiking and biking trails, as well as access roads
to Chair 5 and Chair 8. These crossings would be armored and designed to maintain stability and prevent
erosion. Other permanent channel crossings would occur below the surface when trenches were excavated
for utility or snowmaking lines. Trenches would be backfilled immediately following excavation, and
channel crossing locations would be restored to their original dimensions.
The proposed parking lot would intercept two of the three drainage channels that pass through the permit
area. As discussed above, to mitigate increases in peak-runoff flows, the parking lot would be designed to
function as a detention basin for stormwater runoff, reducing peak flows and removing sediment. Flow
from this structure would be returned to the original drainage channels below the parking lot.
The CDA approach was used to incorporate the variables of soil type, area and intensity of disturbance,
slope, and proximity of channels in an objective assessment of the effects of each proposed element. As
indicated in Table 3-10, each element of the proposed action is assigned a high, medium, or low risk rating
prior to mitigation. This rating indicates the potential for individual elements to contribute erosion and
sediment, during or following construction, to downslope locations. Runoff pathways are a primary
concern.
Elements with a high risk rating usually intersect a runoff pathway (i.e., road or channel) and have large
disturbance areas with steep slopes. Elements such as hiking and biking trails have relatively large total
disturbance area but confined dimension (i.e., less than 3 feet wide) at each permanent crossing. Other
elements such as ski runs involve a large total area and incorporate long channel segments with temporary
crossings.
58
Table 3-10. Proposed action CDA table.

Soil unit1 / Element Pre-Mitigation Post-Mitigation
Max Proximity to
Project Element Erosion Disturbance Intensity2 Sedimentation BMPs3 Sedimentation
Slope Runoff Pathway
Hazard Area (acres) Risk Risk
Multiple channel
Bike Trails 775 / Severe 7.9 Grading High 13, 15, 26 Low
73 and road crossings.
First Aid
Crosses channel, 3, 6, 9, 12,
Building 775 / Severe 0.5 Excavation High Low
60 road crossing. 27
Crosses channel,
Septic System 775 / Severe 0.2 Excavation Moderate 5, 11 Low
23 road crossing.
Utilities < 50 ft. to channel,
775 / Severe 0.1 Excavation Moderate 10, 18, 24 Low
(Power/Water) 0 crosses road.
Subtotal (ac) 0.8
905 / 916 /
< 400 ft. to channel,
Gate House Severe / 0.2 Excavation High 3, 6, 9 Low
crosses road.
Moderate 51
Crosses channel, <
Glading 775 / Severe 23.4 Glading High 8, 11, 13 Low
70 50 ft. to road.
Multiple channel
Hiking Trail 775 / Severe 1.8 Grading High 13, 15 Low
65 and road crossings.
Lift 4
Crosses channel,
Power Line 775 / Severe 0.1 Excavation Moderate 10, 18 Low
0 road crossing.
Grading for Crosses channel,
775 / Severe 0.2 Grading High 6, 10, 21 Low
conveyor 32 road crossing.
Subtotal (ac) 0.3
3, 9, 10, 12,
Crosses channel,
Parking 775 / Severe 4.6 Grading High 19, 20, 22, Low
road crossing.
66 27, 28, 29
59
Table 3-10 (cont’d). Proposed action CDA table.

Max Proximity to
Crosses channel,
Rental Building 775 / Severe 0.7 Excavation 34 Moderate 3, 6, 20 Low
road crossing.
Snowmaking
Crosses channel,
Pumphouse 775 / Severe 0.3 Excavation 39 greater than1,000 ft. Moderate 6, 9, 20 Low
to road.
Crosses channel, <
Trench 775 / Severe 5.7 Excavation 57 High 10, 18 Low
50 ft. to road.
Subtotal (ac) 6.0
916 / <400 ft. to channel,
Vault Toilet 0.3 Excavation 10 Low 3, 5 Low
Moderate <100 ft. to road.
<50 ft. to channel,
Water Tank 775 / Severe 0.3 Excavation 26 Low 6, 19, 24 Low
adjacent to road.
Zip Line
Crosses channel, 3, 11, 12,
Corridor Clearing 775 / Severe 2.1 Clearing 61 High Low
road crossing. 13
775 / 905 / <300 ft. to channel,
Terminals <0.1 Excavation 59 Moderate 6, 9, 12, 16 Low
Severe <100 ft. to road.
Subtotal (ac) 2.1
Mountain Coaster
775 / 905 / Crosses channel,
Power Line <0.1 Excavation 29 Moderate 18 Low
Severe road crossing.
<50 ft. to channel, 3, 6, 9, 16,
Terminal and Track 905 / Severe 2.7 Excavation 72 High Low
road crossing. 27
Subtotal (ac) 2.8
60

Max Proximity to
Chair 5 Pod
Lift Corridor Crosses channel, 3, 11, 12,
775 / Severe 0.1 Clearing 19 Moderate Low
Clearing <700 ft. to road. 13
Adjacent to channel
Power Line 775 / Severe 0.8 Excavation 45 Moderate 18 Low
and road.
Roads 775 / Severe 0.9 Grading 46 Moderate Low
road crossing. 13, 15
3, 9, 10, 13,
Crosses channel,
Ski Run 775 / Severe 13.3 Grading 48 High 14, 17, 21, Moderate4
adjacent to road.
23, 25, 27
Crosses channel
9, 10, 12,
Terminals 775 / Severe 1.0 Excavation 31 (lower terminal), High Low
16
>1,000 ft. to road.
Adjacent to channel,
Towers 775 / Severe 0.1 Excavation 27 Moderate 6, 8, 11, 12 Low
<1,000 ft. to road.
Lift 6 Grading for Adjacent to channel
775 / Severe 0.2 Grading 46 Moderate 10, 11 Low
conveyor and road.
Crosses channel,
Lift 6 Power Line 775 / Severe <0.1 Excavation 11 Low 18 Low
road crossing.
Subtotal (ac) 16.45
Chair 8 Pod
Lift Corridor <400 ft. to channel, 3, 11, 12,
775 / Severe 0.9 Clearing 53 Moderate Low
Clearing >1,000 ft. to road. 13
Crosses channel,
Power Line 775 / Severe 0.8 Excavation 48 Moderate 18 Low
road crossing.
Roads 775 / Severe 2.1 Grading 57 High Low
<200 ft. to road. 13, 15
61

Max Proximity to
Varies - channel and
3, 9, 10, 13,
road crossing to >
Ski Run 775 / Severe 57.4 Grading 84 High 14, 17, 21, Moderate4
1,000 ft. to channel
23, 25, 27
and roads.
Crosses channel
9, 10, 12,
Terminals 775 / Severe 1.0 Excavation 56 (lower terminal), High Low
16
>1,000 ft. to road.
Varies – Adjacent to
channel to >1,000 ft.
Towers 775 / Severe 0.1 Excavation 47 Moderate 6, 8, 11, 12 Low
to channel, >1,000
ft. to road.
Subtotal (ac) 62.35
Total (ac) 129.85
1
Dominant soil type for an element; other types are present. More than one soil type is listed when both soil types contributed equal coverage to an element.
2
Intensity of disturbance is conservative; entire disturbance area for an element may not be subject to same intensity of disturbance (e.g., grading for ski runs
would only take place as needed to obtain consistent surface slope).
3
See Appendix B for definitions of these BMPs.
4
This is a pre-revegetation rating. Successful revegetation would result in a rating of low.
5
Value differs from value in Table 3-2 due to differences in category breakdown causing differences in rounding.
62
Elements with moderate risk ratings may include permanent, surface or subsurface crossings but have small
disturbances (less than 1 acre) on slopes less than 50 percent (e.g., access road, utility lines and corridor
clearing for the Chair 5 and Chair 8 pods). As previously described, road crossings would be armored to
prevent erosion. Utility lines would involve permanent subsurface crossings and all channels would be
restored to original dimensions. Trees would be felled and skidded from lift corridors and all would be
removed in lift corridor clearings. Any holes created by stump removal would be filled to prepare the area
for installing lift towers and winter grooming.
Elements with low risk ratings do not cross runoff pathways created by roads or channels. They typically
have small disturbances and low–moderate slopes.
Table 3-10 includes BMPs that address permanent channel crossings. These BMPs are designed to
minimize the potential risk of erosion, ensure stability in channel crossings, and maintain proper function
in channel segments above and below each crossing. In most cases, they would effectively reduce erosion
and sedimentation risk ratings to low. Ski runs, with their large disturbance area and long channel
intersections are the exception.
Table 3-10 also identifies BMPs that would minimize or eliminate the potential for erosion and sediment
for construction aspects other than stream crossings. Many of these are physical BMPs that manage runoff
without the use of reseeding. Any reseeding that does occur under the proposed action would use a Forest
Service approved seed mix. Some of the more important physical BMPs used include water bars, infiltration
ditches, armoring points of water discharge, diverting upslope runoff away from ski runs, and proper
installation and long-term maintenance of runoff control structures (including repair of new erosion
damage). All construction activities must comply with federal, state and local codes related to construction
disturbance and runoff from construction sites.
With these mitigation measures in place, the erosion and sedimentation risk ratings for all elements of the
proposed action would fall to low, with the exception of the Chair 5 and Chair 8 pod ski runs. The moderate
ratings for these ski runs are based primarily on the current absence of an approved seed mix for
revegetation. Once these runs were revegetated, they would pose a low sedimentation risk, but natural
revegetation could take several years.
The other elements of the proposed action would generate no substantial risk of erosion and sedimentation
in, or downslope of, the project area. This conclusion is supported by past experience with implementing
similar BMPs in the project area and at other locations on the SMNRA (Stantec 2008, Hooper 2017).
The proposed action would reduce the amount of forest landcover in the analysis area by approximately
109.7 acres or 15.6 percent (Table 3-9), primarily through the creation of additional ski runs in the Chair 5
and Chair 8 pods. The width of the Chair 5 pod runs would be approximately 100 feet, widening to up to
450 feet where they merge at the bottom. Width in the Chair 8 pod would be approximately 150 feet,
widening to up to 500 feet where they merge. The predominant exposure of the areas that would be cleared
for the ski runs would be northwest to northeast. In addition, approximately 23.4 acres would be gladed.
The exposure in the glade areas would be predominantly northwest.
Forest clearing under the proposed action would affect snow dynamics in varying, sometimes offsetting
ways. Cleared areas would experience less snow loss through canopy interception and sublimation relative
to their previous forested condition. However, snow in clearings could melt more quickly relative to snow
under a forest canopy due to more exposure to incoming solar radiation and could sublimate more quickly
due to greater exposure to solar radiation, wind, and lower humidity. Snow accumulation would likely be
greater in cleared areas. In high-snowfall years, differences in snow accumulation between open and cleared
areas are expected to be less (Boon 2012).
Areas near remaining tree stands would be exposed to increased longwave radiation from adjacent trees as
well as increased shortwave radiation from the sky, particularly in areas with a southerly exposure. This
63
effect would decrease as distance from trees increased. Increased longwave radiation would increase
snowmelt along the edges of clearings.
Glading would reduce snowfall interception by the canopy and increase the amount of snow reaching
ground. Gladed areas might also be more susceptible to increased snowmelt due to increased longwave
radiation from the trees, depending on site-specific conditions.
On the other hand, as discussed above under Affected Environment, snowmelt on sites with warmer winter
conditions (average daily temperature for the December–February period greater than 30° F) experience
snowmelt more quickly under forest canopy because of the importance of longwave radiation from the trees
in the energy budget. The temperature analysis for Lee Canyon based on data from the Lee Canyon
SNOTEL site indicated that the average temperature for the December–February period is slightly above
this threshold. This would suggest that snow would remain longer in cleared areas than under forest canopy.
The difference in the snowmelt period would likely be limited to 1–2 weeks. Because of the mix of warmer
and colder days, snowmelt behavior may shift from favoring forested areas to favoring open areas based on
temperature and cloud patterns within a given year. The pattern could also shift from year to year,
corresponding to warmer or cooler conditions and lower or higher snowfall amounts.
In the big picture, the removal or glading of 92.7 acres of trees would represent an approximately 9 percent
change in the forest cover for the ski area subwatershed. The small magnitude of this change would make
effects on snowmelt patterns undetectable in the context of watershed behavior.
3.4.3.3 Bristlecone Trail Alternative

This discussion focuses on impacts that are different from those of the proposed action. Peak runoff
estimates associated with the BCT alternative are included in Table 3-11. Scenarios for the 2-year, 25-year,
and 100-year storm events are listed in the first column. Peak runoff estimates for existing conditions, the
proposed action and BCT alternative are shown to facilitate comparison.
64
Table 3-11. Peak runoff estimates (cubic feet per second) under the proposed action and BCT alternative in response to a 24-hour design storm. 1
Proposed Action BCT Alternative
Current
Conditions No Detention Basin (cubic feet Detention Basin Installed (cubic No Detention Basin (cubic feet Detention Basin Installed (cubic
(cubic feet per second)/ % Change Relative feet per second)/ % Change per second)/ % Change feet per second)/ % Change
per to Existing Relative to Existing Relative to Existing Relative to Existing
second)
Return
Fully Fully Fully Fully
interval No With No With No With No With
No BMPs Rehabili- Rehabili- Rehabili- Rehabili-
(depth BMPs BMPs BMPs BMPs BMPs BMPs BMPs BMPs
tated tated tated tated
inches)
100-year 1,913/ 1,854/ 1,758/ 1,903/ 1,839/ 1,726/ 1,889/ 1,831/ 1,758/ 1,849/ 1,800/ 1,721/
storm 1,736
(7.3 in.) 10.2% 6.8% 1.3% 9.6% 5.9% -0.6% 8.8% 5.5% 1.3% 6.5% 3.7% -0.9%
25-year 1,162/ 1,126/ 1,054/ 1,150/ 1,111/ 1,026/ 1,145/ 1,108/ 1,048/ 1,113/ 1,093/ 1,023/
storm 1,030
(5.6 in.) 12.8% 9.2% 2.3% 11.7% 7.8% -0.4% 11.2% 7.6% 1.7% 8.1% 6.1% -0.7%
2-year 142/ 137/ 117/ 94/ 46/ 37/ 137/ 132/ 115/ 46/ 45/ 37/
storm 106
(2.6 in.) 34.0% 29.5% 10.6% -11.3% -56.7% -64.6% 29.2% 24.5% 8.5% 56.6% -57.5% -65.1%
1
See JUB 2017 for additional detail.
65
The overall changes in landcover in the permit area would be less under the BCT alternative compared to
the proposed action, reflecting primarily the reduction in the acreage of Chair 8 pod ski runs. This would
equate to an across-the-board reduction in the net impact on runoff. Specifically, the BCT alternative would
result in roughly the same increase in impervious surface from buildings and pavement (8.7 acres) and in
hardened surfaces from roads and trails (6.5 acres). It would entail 75.9 acres of clearing forest and shrub
landcover types for ski runs (14.7 fewer acres than the proposed action) and 28.5 acres of glading (5.5 more
acres than the proposed action, Table 3-12).
Table 3-12. Landcover in the permit area under existing conditions, proposed action, and the
BCT alternative.
Landcover Type Existing Landcover (ac) Proposed Action (ac) BCT Alternative (ac)
Brush 24.2 9.6 10.2
Building 0.3 0.7 0.6
Dirt Roads/Unpaved 4.9 11.1 11.4
Forested 702.0 592.3 600.9
Gladed 10.4 33.4 38.9
Paved 4.7 8.8 8.4
Ski Run, Other
37.1 127.7 113.0
Rehabilitated Areas
Water 1.3 1.3 1.3
Total (ac) 784.9 784.9 784.9
Notable results in modeled peak runoff estimates under the BCT alternative include:
1. Peak runoff estimates under the BCT alternative are generally 1–5 percent lower than the proposed
action for any design storm (i.e. 100-year, 25-year, and 2-year storms) or modeled scenario (i.e.,
without BMPs, including BMPs, and fully rehabilitated).
2. Similar to the proposed action, greater differences in peak runoff occur between existing conditions
and the BCT alternative for larger storm events.
3. Peak runoff from unmitigated conditions (i.e., without BMPs) would decrease for all storm events
by 1–5 percent compared to the same scenario under the proposed action. These values are 9–29
percent above existing conditions.
4. Similar to the proposed action, use of physical BMPs would reduce peak runoff estimates under
the BCT alternative by 3–5 percent relative to the unmitigated scenario. Peak runoff under the BCT
alternative would be slightly less than the proposed action for this scenario (i.e., without BMPs)
and 6–25 percent greater than existing conditions.
5. The same physical BMPs and mitigation measures would be applied to disturbed areas under the
BCT alternative and the proposed action.
6. Under the BCT alternative, peak runoff from areas that are fully rehabilitated and drain to a
detention basin would be marginally less (less than 1 percent) than estimates under the proposed
action.
In summary, the BCT alternative would not differ substantially from the proposed action in terms of
stormwater runoff. Peak runoff would be 1–5 percent lower than the proposed action for any design storm
66
or modeled runoff scenario. The potential for stormwater runoff to cover the wellhead at Camp Lee Canyon
would be slightly less.
This discussion of impacts on soil erosion and stability under the BCT alternative focuses on effects that
are different from the proposed action. General conclusions regarding impacts on soil erosion and stability
under the proposed action would apply under the BCT alternative, but the magnitude of such impacts would
change somewhat.
Total disturbance under the BCT alternative is 121.2 acres, 8.6 acres less than under the proposed action.
Some elements are the same size under the BCT alternative and the proposed action but are located in
different places on the mountain. Several elements are identical in regard to size and location under the
BCT alternative and the proposed action but would have slightly different disturbance areas (i.e., bike trails,
rental building, and Chair 5 ski runs). These minimal differences are the result of removing overlapping
disturbance from different combinations of adjacent elements and do not represent actual differences in
disturbance for each element.
As described in section 2.4.2, elements that are different between the BCT alternative and the proposed
action include glading, snowmaking, the zip line, the mountain coaster, and the Chair 8 pod. Disturbance
totals for these elements are shown in Table 3-13. Soil types and disturbance intensity for each of these
elements would be the same under the BCT alternative as the proposed action, with the exception of the
mountain coaster building and track. Soil resources impacted by this element would change from the
Mountmummy-Thesisters-Maryjane association to the Ladyofsnow-Robbersfire-Maryjane association.
Both of these soil types have a severe erosion hazard.
Under the BCT alternative, gladed areas would increase by about 5.5 acres in comparison to the proposed
action. Clearing activities would increase by 0.4 acres for the zip line corridor and decrease 0.8 acres for
the Chair 8 lift corridor, for a total increase of 1.2 acres. Similar to the proposed action, glading and clearing
activities would result in minimal impacts on erosion as surface disturbance would be limited to stump
removal and skidding of trees. Grading impacts include an increase of 0.1 acres for access roads and a
decrease of 13.9 acres for ski runs, both for the Chair 8 pod, for a net reduction of 13.8 acres. Excavation
increases under the BCT alternative include snowmaking trenches (1.0 acre), mountain coaster (less than
0.1 acre), and Chair 8 power line trench (0.2 acre) and access roads (0.1 acres). These excavation increases
would be offset by decreases including mountain coaster building and track (0.8 acre) and chair 8 lift
corridor clearing (0.8 acre) for a net decrease 0.3 acre. Overall, the BCT alternative would result in 8.6
fewer acres of disturbance.
Maximum slope would remain the same or decrease for most elements of the BCT alternative, resulting in
the same or decreased erosion risk. Three elements would have minimum slope increase (i.e., 10 percent or
less) compared to the proposed action, including snowmaking trenches, zip line corridor clearing, and Chair
8 access roads. Two elements, including the snowmaking pump house and power lines to the Chair 8 pod,
would have increased slopes of 16 and 14 percent, respectively. The BMPs described below would
minimize or eliminate the increased risk for these elements.
Some elements of the BCT alternative entail a road or stream crossing that would not occur under the
proposed action. These include permanent crossings for the snowmaking trenches, Chair 8 access roads,
and the mountain coaster building and track. Impacts of these developments would be identical to the
proposed action in regard to design and risk of erosion. Other elements of the BCT alternative would no
longer include a road or stream crossing due to a change in location or a smaller disturbance size. These
include glading and the Chair 8 power line trench. Changes in the number and location of channel or road
crossings between the proposed action and the BCT alternative would result in minor changes in the overall
impacts on soil erosion and stability. The same BMPs noted under the proposed action would be applied to
minimize the potential risk of erosion, ensure stability in channel crossings, and maintain proper function
in channel segments above and below each crossing.
67
Under the BCT alternative, the pre-mitigation risk rating for the Chair 8 power line would increase from
moderate to high due to increased slope and a slightly larger disturbance area. The pre-mitigation rating for
two other elements of the BCT alternative would decrease from moderate to low, including zip line
terminals and Chair 8 corridor clearing due to a decreased slope, compared to the proposed action.
The same BMPs applied under the proposed action would minimize or eliminate the potential for erosion
and sediment for construction aspects other than stream crossings. Similar to the proposed action BMPs
under the BCT alternative would primarily include physical BMPs. Some of the more important physical
BMPs used would include water bars, infiltration ditches, armoring points of water discharge, diverting
upslope runoff away from ski runs, and proper installation and long-term maintenance of runoff control
structures (including repair of new erosion damage). All construction activities must comply with federal,
state and local codes related to construction disturbance and runoff from construction sites. Appendix B
includes a full list of BMPs.
With these mitigation measures in place, the erosion and sedimentation risk ratings for all elements of the
BCT alternative would fall to low, as under the proposed action. In particular, the decreased disturbance
for developing the Chair 8 pod ski runs would produce less erosion risk under the BCT alternative. Overall,
the BCT alternative would generate no substantial erosion or sedimentation impacts in, or downstream of,
the project area. This conclusion is supported by past experience with implementing similar BMPs in the
project area and at other locations on the SMNRA (Stantec 2008, Hooper 2017).
Under the BCT alternative, clearing for new ski trails would be reduced to 78.1 acres, while glading would
be increased to 28.9 acres. The effects on snow dynamics of the BCT alternative would be similar to the
proposed action, though fewer trees would be removed. Overall, the small magnitude of this change would
make effects on snowmelt patterns undetectable in the context of watershed behavior.
3.4.4 CUMULATIVE EFFECTS

As discussed in section 3.3, the cumulative actions considered in this analysis are any projects listed in the
HTNF SOPA that would have temporally and spatially overlapping impacts on the same resources affected
directly or indirectly by the proposed action and alternatives. The Dolomite-McWilliams-Old Mill
Campgrounds Reconstruction, Foxtail Group Picnic Area Reconstruction, Old Mill WUI Hazardous Fuels
Treatment, and Lee Canyon Fuels Reduction projects meet the spatial and temporal overlap requirements.
A brief summary of these projects is provided above in section 3.3.
3.4.4.1 Issue 1 – Stormwater Runoff

Stormwater runoff generated from the cumulative actions listed in section 3.3 has the potential to interact
cumulatively with stormwater runoff from the proposed action or the BCT alternative. Improvements to the
Foxtail, Dolomite, McWilliams, and Old Mill recreation sites included installation and upgrades to existing
hardened surfaces (i.e., roads, parking lots, trails, etc.). The Old Mill WUI Hazardous Fuels Reduction and
Lee Canyon Fuels Reduction projects did not and will not create additional hardened surfaces and use BMPs
to maintain water infiltration and existing runoff patterns. Although any increase in hardened surfaces will
subsequently decrease infiltration and increase stormwater runoff, BMPs that disperse water can be used in
developed areas to reduce overall stormwater volume and peak runoff. Some of the BMPs used to mitigate
runoff impacts included low-water crossings, rolling dips, and lack of curbs and speed bumps that
concentrate runoff from paved surfaces.
68
Table 3-13. BCT alternative CDA table (only elements that would change from the proposed action).
Post-
Element Pre-Mitigation
Soil unit1 / Max Proximity to Mitigation
Name and Element Disturbance Intensity2 Sedimentation BMPs3
Erosion Hazard Slope Runoff Pathway Sedimentation
Area (acres) Risk
Risk
<50 ft. to
Glading 775 / Severe 28.9 Glading 70 channel and High 8, 11, 13 Low
road.
Snowmaking
<100 ft. to
Pumphouse 775 / Severe 0.3 Excavation 55 channel, >1,000 Moderate 6, 9, 20 Low
ft. to road.
Crosses channel,
Trench 775 / Severe 6.7 Excavation 67 High 10, 18 Low
road crossing.
Subtotal (ac) 7.0
Zip Line
Corridor Clearing 775 / Severe 2.5 Clearing 62 High Low
road crossing. 13
<100 ft. to
6, 9, 12,
Terminals 775 / 905 / Severe <0.1 Excavation 30 channel, <50 ft. Low Low
16
to road.
Subtotal (ac) 2.5
Mountain Coaster
Crosses channel,
Power Line 775 / Severe 0.1 Excavation 13
< 50 ft. to road.
Moderate 18 Low
Terminal and Track 775 / Severe 1.9 Excavation 45 High Low
<200 ft. to road. 16, 27
Subtotal (ac) 2.0
69
Table 3-13 (cont’d). BCT alternative CDA table (only elements that would change from the proposed action).
Pre- Post-
Element
Soil unit1 / Max Proximity to Mitigation Mitigation
Name and Element Disturbance Intensity2 BMPs3
Erosion Hazard Slope Runoff Pathway Sedimentati Sedimentation
Area (acres)
on Risk Risk
Chair 8 Pod
<300 ft. to channel, 3, 11, 12,
Lift Corridor Clearing 775 / Severe 0.1 Clearing 33 Low Low
>1,000 ft. to road. 13
Adjacent to channel,
Power Line 775 / Severe 1.0 Excavation 62
road crossing.
High 18 Low

Roads 775 / Severe 2.2 Grading 65 High Low
road crossing. 13, 15
Varies - channel and 3, 9, 10,
road crossing to > 13, 14,
Ski Run 775 / Severe 43.5 Grading 84 High Moderate4
1,000 ft. to channel 17, 21,
and roads. 23, 25, 27
<150 ft. to channel, 9, 10, 12,
Terminals 775 / Severe 1.0 Excavation 52 High Low
>1,000 ft. to road. 16
Varies - < 300 ft. to
>1,000 ft. to 6, 8, 11,
Towers 775 / Severe 0.1 Excavation 43 Moderate Low
channel, >1,000 ft. 12
to road.
Subtotal (ac) 47.8
Total (ac) 121.25
1 Dominant soil type for an element; other types are present. More than one soil type is listed when both soil types contributed equal coverage to an element.
2 Intensity
of disturbance is conservative and some areas of many elements would not be disturbed (e.g. grading for ski runs would take place as needed to obtain consistent surface
slope).
3See Appendix B for definitions of these BMPs.
4
This is a pre-revegetation rating. Successful revegetation would result in a rating of low.
5 Value differs from value in Table 3-2 due to differences in category breakdown causing differences in rounding.
70
Although the cumulative actions in section 3.3 created a small, local increase in total paved area, the BMPs
used created an overall reduction in peak runoff in Lee Canyon. This reduction would be cumulative with
the peak runoff levels described above for the proposed action and BCT alternatives, resulting in slightly
lower peak flows below the recreation sites than would have been expected had the cumulative action
projects not been completed.
3.4.4.2 Issue 2 – Soil Erosion and Stability

In regard to soil erosion and stability, the cumulative actions in section 3.3 created increased erosion
potential and scour of surface fines during demolition or construction phases at recreations sites. This
potential lasted for approximately 1–3 years from the start of disturbance and steadily decreased during that
time due to leaf litter fall and vegetation re-growth. To the extent that culvert crossings were replaced with
wide, low-water crossings, the potential for channel erosion and sediment loading also decreased. Runoff
and sediment transport from treatment areas in the Old Mill WUI Hazardous Fuels Reduction and Lee
Canyon Fuels Reduction projects were and will be affected locally. Some increased surface runoff and
erosion may occur where mineral soils were exposed following fire and mastication treatments. These
impacts are short-term as needles dropped from overlaying conifer stands were spread on the ground and
reduced the chance of surface runoff.
The proposed action and the BCT alternative will also create potential for soil erosion, sedimentation, and
a loss of stability. The risk of erosion potential under each alternative would be minimized through the use
of appropriate BMPs that reduce erosion, disconnect disturbed areas from erosion pathways, and minimize
impacts for each project element.
The risk of soil erosion is greatest when surfaces are recently disturbed and unprotected from raindrop
impact and other erosive forces that can detach and transport fine soil particles. This is a short-term risk,
and the cumulative effect is dependent on the timing of construction. The cumulative actions in section 3.3
have been implemented, so the short-term risk is primarily absent and would not be cumulative with the
short-term risk of soil erosion under the proposed action and BCT alternative. Long-term risks of soil
erosion could be cumulative, depending on the success of BMPs. At this time, the use of BMPs has been
successful for each action in section 3.3 and would not combine in a cumulative way with the proposed
action or BCT alternative to adversely affect soil erosion and stability.
3.4.4.3 Issue 3 – Snow Accumulation and Snowmelt

The cumulative actions in section 3.3 associated with recreation sites have limited potential for influencing
snow accumulation and snowmelt. Vegetation patterns were adjusted slightly to accommodate the design
of campsites and upgrade existing sites. The influence of these slight changes on snow accumulation and
snowmelt would be minimal.
The Old Mill WUI Hazardous Fuels Reduction and Lee Canyon Fuels Reduction projects treated, or will
treat, vegetation with prescribed burning, hand thinning, and mastication. These activities reduce the
number of trees/acre and created a mosaic of vegetation, which could lead to some increase in snow
accumulation. Some of these areas are found at lower elevations than the permit area and receive less
precipitation in the form of snow. Some treatment areas are located in a different watershed and do not flow
into Lee Canyon.
The proposed action and BCT alternative would remove or glade about 93 acres of the permit area where
proposed ski runs are located and other smaller areas where ski lifts, buildings, trails, etc. are proposed.
Similar to vegetation treatment, cleared areas would likely see an increase in snow accumulation but
snowmelt in clearings could occur more rapidly compared to areas with full cover, due to increased
exposure to incoming solar radiation.
The proposed action and BCT alternative would contribute in a cumulative way to the effect of the Old Mill
WUI Hazardous Fuels Treatment project on snow accumulation and snowmelt. However, the impact of
71
these activities on a watershed level would be minimal due to the level of natural variation that occurs on a
watershed level.
3.4.5 MITIGATION
These mitigation measures include practices from Lee Canyons Master Erosion and Sediment Control Plan
(Stantec 2008), Nevada BMP handbooks and field guides (Nevada Conservation Commission 1994,
Nevada DEP 2008), Ski Area BMPs (Forest Service 2001) and Forest Service National Core BMPs (Forest
Service 2012a). Some practices are not specifically referenced in Tables 3-10 and 3-13 and generally apply
to most of the proposed elements.
Pre-Construction
1. Conduct appropriate soil and water studies, including modeling, to support design of runoff and
erosion control structures. Provide documentation to justify the design life.
2. Develop engineering drawings for each runoff and erosion control structure described in a project
plan. Include plan and profile views of structures as appropriate.
3. Comply with all federal, state and local codes related to construction disturbance and runoff from
construction sites. As required, develop and implement an erosion control and sediment plan that
covers all disturbed areas, including borrow, stockpile, skid trails, roads, or any areas disturbed by
development activities.
4. Design and locate parking, staging, and stockpiling areas of appropriate size and configuration to
accommodate expected vehicles and avoid or minimize adverse effects to adjacent soil, water
quality, and riparian resources.
5. Coordinate all phases of sanitation system management (planning, design, field surveys and testing,
installation, inspection, operation, and maintenance) with appropriate agencies to ensure
compliance with applicable regulations.
6. Locate ski area facilities (including buildings, runs, and lifts) on stable geology and soils to
minimize risk of slope failures.
7. Develop an erosion structure maintenance schedule showing structures needing annual
maintenance and those where non-recurring maintenance is expected. Display hand-crew or
machine maintenance if appropriate.
8. Plan projects to minimize re-entry after the site is stabilized.
Construction
9. Limit the amount of exposed or disturbed soil at any one time to the minimum necessary. Define
outer boundaries of disturbance with markers. Install sediment and stormwater controls prior to
disturbance where practicable.
10. When topsoil is present or can be salvaged, remove and stockpile with appropriate cover and
erosion control methods. Consult Forest Service soil scientist for determination of presence of
viable top soil. Revegetation specifications and seed mixes must be approved by the Forest Service.
11. Limit operation of equipment when ground conditions could result in excessive rutting, soil
puddling, or runoff of sediments.
12. Confine all light vehicle traffic, parking, staging, and stockpiling materials to designated areas to
minimize ground disturbance. Heavy equipment (e.g. feller buncher, dozer, etc.) will be used but
also rely on helicopters to deliver lift towers and place equipment.
13. Consider over the snow removal of large trees when conditions allow. Small trees, branches and
other small residue created during clearing or glading activity will be chipped, mulched, burned, or
72
moved off site. Avoid damage to remaining trees and root systems adjacent to cut slopes and
cleared areas.
14. Prevent water from running down ski run prism particularly on steep grades (20 to 40 percent) and
from accumulating on gentle slopes (0 to 30 percent). Water bar spacing will account for slope as
follows:
Slope (%) Spacing (feet)
2% 250
5% 150
10–30% 100
>30% 75
15. Prevent water from running down roads and trails using water bars and rolling dips with a cross-
slope of 2 to 5 percent. Minimize cross slopes in areas where infiltration is a possible method to
reduce runoff. Water bars, rolling dips and culverts will be inspected and repaired on a weekly basis
during construction. Ruts will be repaired immediately.
16. Infiltration trenches shall be installed to intercept runoff from loading and unloading areas for ski
lifts, zip lines, mountain coasters and any outdoor locations where people will gather. Where soil
conditions permit (i.e. areas where soils are not cobbly or rocky) use erosion control mat to protect
any cut and fill areas associated with these locations.
17. Construct modified water bars across existing ski slopes to prevent the concentration of water flow,
act as micro-infiltration ditches and divert runoff to undisturbed terrain. Where feasible, use a
horseshoe design concept for waterbars and ditches with the tailing off ends of the structures at a 5
to 7 percent slope into the naturally vegetated areas.
18. Whenever possible, place excavated material on the uphill side of trenches and water bars. Manage
material placement to avoid trapping or concentrating water flow during construction. Fill trenches
with a 2-inch surcharge/berm to allow for settlement. Construct water bars over trenched areas as
in ski runs.
19. Use correctly installed silt fence or straw wattle to prevent sediment from entering existing drainage
channels, for projects within 50 feet of existing channels.
20. Use a lined ditch to transport water away from structures or areas where standard mitigation
strategies are not possible due to slope.
21. Use diversions ditches as needed to divert water away from ski run segments where both sides of
the run slope inward and prevent discharge from modified water bars. A mid-slope diversion ditch
may also be necessary to move runoff away from the ski run.
22. Protect any point of water discharge (e.g. trenches, ditches, water bars) with rip-rap or other
methods to slow water velocity and disperse runoff.
Post Construction Restoration/Maintenance
23. Fill material for storm damage repair will be sourced from areas that collect sediment after storms.
Essentially, material eroded off slopes will be collected and replaced.
24. Ensure that permit holder-owned and other authorized drinking water systems on NFS lands are
operated and maintained according to direction in FSM 7423.
73
25. Consider amending soil with mulch (e.g. wood chips), compost, mycorrhizal fungi inoculants and
other products to provide added nutrients, promote revegetation success, and increase infiltration.
Utilize irrigation where appropriate.
26. Use and maintain surfacing materials suitable to the trail site and use to withstand traffic and
minimize runoff and erosion. Pay attention to areas where high wheel slip (curves, acceleration,
and braking) during motorized use generates loose soil material.
27. Install suitable stormwater and erosion control measures to stabilize disturbed areas and waterways
before seasonal shutdown of project operations or when severe or successive storms are expected.
28. Maintain the natural drainage pattern of the area wherever practicable.
29. Use and maintain suitable measures to collect and contain oil and grease in larger parking lots with
high use and where drainage discharges directly to channels.
3.5 VEGETATION
Issue 1 – Special-Status Species: The SMNRA is a unique ecosystem, and the permit area includes habitat
for a number of special-status species, including Forest Service sensitive species and management indicator
species (MIS), Spring Mountains Conservation Agreement species of concern (CA species), and species
covered in the MSHCP. There are no federally listed plant species at Lee Canyon ski area, nor is there any
habitat for federally listed plant species. Development and subsequent use of the proposed infrastructure
would result in temporary habitat disruption during construction, permanent habitat conversion, and
increased levels of human activity year round. These changes may affect special-status plant species or their
habitats.
Indicator: Species-specific determinations of potential individual- and population-level impacts, based
primarily on surveys, published information on the species’ distribution and population status, and the
efficacy of design criteria and proposed mitigation. These determinations are based on the laws, regulations,
and policies regarding management of each category of species.
Issue 2 – Invasive Species: Noxious and non-native invasive species pose an ongoing threat to the permit-
area’s ecosystem. Construction-related soil disturbance would create habitat conditions favorable to many
such species, and construction equipment could introduce their seeds. Use of hiking and biking trails could
also introduce seeds and spread established infestations. As a result, these activities may affect the
introduction and spread of these undesirable plant species.
Indicator: Assessment of the current invasive species scenario in the permit area and analysis of the efficacy
of design criteria in place and proposed mitigation. Compliance with applicable County regulations will
provide an assessment criterion.

The Lee Canyon ski area is located at the upper extent of Lee Canyon in the Spring Mountains. The
elevation ranges from approximately 8,540 feet in the lower parking lot to 11,290 feet at the summit of Lee
Peak, though the upper elevation of the survey area for this analysis is approximately 9,700 feet. The area
consists of alpine and montane forest and meadow communities. Due to both natural variation and previous
resort development, the habitats are relatively segmented on the east side of the ski area. For example, the
forest communities are divided by avalanche chutes, rock outcroppings, talus slopes, and cliff areas,
especially at higher elevations. Ski runs and roads have further segmented forests. As a result, forest stands
occur as islands or patches rather than large contiguous blocks. The forest is less divided on the west side
of the ski area, though avalanche chutes and drainages are still present. The ground cover varies across the
74
disturbance area, but averages approximately 30 percent vegetation, 10 percent litter or duff, 15 percent
bare ground, 35 percent gravel, and 10 percent rock.
Within the ski area, the forested habitat is a mix of pine and fir species. At lower elevations and on south-
facing slopes, the dominant tree species are ponderosa pine (Pinus ponderosa) with a component of white
fir (Abies concolor). At higher elevations, ponderosa pine transitions to limber pine (Pinus flexilis) and
bristlecone pine (Pinus longaeva). Quaking aspen (Populus tremuloides) are also present adjacent to ski
runs, in avalanche scars, and as a minor component of the evergreen stands lower on the slope. The
understory vegetation consists of a mixture of shrubs, forbs and grasses dominated by common juniper
(Juniperus communis), gooseberry currant (Ribes montigenum), Nuttall’s linanthus (Leptosiphon nuttallii
ssp. pubescens), sharpleaf valerian (Valeriana acutiloba), bottlebrush squirreltail (Elymus elymoides), and
bluegrass (Poa sp.).
The meadow communities largely correspond to ski runs, some of which were replanted with a seed mix
that includes introduced species, while others were not replanted and support more native species. The
replanted ski runs are dominated by a mix of alfalfa (Medicago sativa), yellow sweet clover (Melilotus
officinalis), smooth brome (Bromus inermis), and intermediate wheatgrass (Thinopyrum intermedium). The
ski runs that were not replanted dominated by Nuttall’s linanthus, Clokey thistle (Cirsium clokeyi), and
bottlebrush squirreltail.
Herbaceous plant species appear to be more common in man-made or naturally-occurring clearings such as
ski runs and avalanche scars or in relatively open forest stands, than they are in forested stands with closed
canopies. The herbaceous species support a large number of pollinator species (i.e., insects, birds, and bats).
The effect of this project on pollinators is discussed in section 3.13.7.
As a result of the combination of the ground cover, steepness of the slope, erosivity of the soil (section
3.4.1), and the intensity of summer precipitation events, special-status plants growing in exposed sites are
vulnerable to disturbance and soil erosion. Ongoing feral horse grazing and deer browsing also pose threats
to special-status plants, primarily to those growing on ski runs and other open areas. Dispersed, off-trail
hiking by summer recreationists has impacted special-status plants in the past (Flores et al. 2007). Fencing
and signs have been placed near the BCT to curtail hiking in sensitive areas and encourage recreationists to
remain on established trails.
3.5.2.1 Special-Status Species

Portions of the ski area have been surveyed previously for special-status plants in conjunction with previous
ski area-related projects, vegetation monitoring, and conservation efforts (NewFields 2006a, NewFields
2006b, NewFields 2007, Flores et al. 2007, Betzler 2009, Brickey 2012a, Brickey 2012b). Though not
reviewed in this EIS in detail, the results of earlier surveys are incorporated into the description of the
affected environment. The Nevada Natural Heritage Program (NNHP) maintains a geodatabase of the
occurrences of rare plants across the state, which was also consulted for this analysis.
An initial screening process was employed to determine which special-status plant species were most likely
to occur in the project area, based on previous survey results and habitat requirements. Species were
eliminated from further analysis at that point if the disturbance area is outside of known distribution of the
species, so no potential habitat would be affected.
The species list resulting from that initial screening – i.e., those which could have potential habitat in the
disturbance area based on published information – was the focus of pedestrian surveys conducted in 2016
and 2017. The survey area included the footprint of projects associated with the proposed action and BCT
alternative, plus a disturbance buffer, plus an additional buffer as a conservative measure. The survey area
is therefore different from the disturbance area, which refers only to the element footprint and the
disturbance buffer. The results of previous surveys and the 2016 and 2017 surveys completed for this
analysis established the list of special-status plants actually occurring in the survey area and potentially
affected by the proposed action and alternatives. Table 3-14 shows the results of the initial screening and
subsequent surveys. It identifies the 13 species carried into detailed analysis and the 27 that are not.
75
Table 3-14. Special-status plant species1 occurring or suspected to occur on the Spring Mountains
National Recreation Area, Humboldt-Toiyabe National Forest, and their level of analysis for this
project.
Status and Carried into
Species Comments4,5
Rank2,3 Detailed Analysis?
Rough angelica R4, MIS, CA, No Limited potential habitat exists near
(Angelica scabrida) MSHCP springs, but there are no documented
G1/G2, S2 occurrences in the vicinity of the ski area
(NNHP 2016) and it was not observed
during the pedestrian surveys.
Charleston pussytoes R4, CA, No Species is known to occur in avalanche
(Antennaria soliceps) MSHCP chutes and on the ridgeline upslope of
G1/G2, S1/S2 the disturbance area (NNHP 2016). A
group of plants was also observed near
the BCT in 2003 but has not been
relocated since. It was not observed
during pedestrian surveys.
White bearpoppy MSHCP G3, No Suitable habitat includes dry to moist
(Arctomecon merriamii) S3 soils including alkaline clay and sand,
gypsum, calcareous alluvial gravels, and
carbonate rock outcrops at 2,000 to
6,280 feet in elevation. Disturbance area
is outside of known distribution.
King’s rosy sandwort R4, CA, Yes Suitable habitat exists in the disturbance
(Arenaria kingii ssp. rosea = MSHCP area. Species was observed during field
Eremogone kingii var. GNR, SNR surveys.
glabrescens)
Clokey’s milkvetch R4, CA, No Suitable habitat includes calcareous
(Astragalus aequalis) MSHCP gravelly flats, hillsides, and open ridges
G2, S2 beneath the canopies of sagebrush,
pines, Gambel oak, Utah juniper or curl-
leaf mountain mahogany at elevations
between 5,970 and 8,400 feet.
Disturbance area is outside of known
distribution.
Halfring milkvetch CA No Suitable habitat includes carbonate
(Astragalus mohavensis var. G3/G4, S2S3 gravels and soils on terraced hills,
hemigyrus) ledges, open slopes, and along stream
washes in creosote-bursage, blackbrush,
and mixed-shrub communities at
elevations between 3,000 and 5,600 feet.
distribution.
Clokey’s eggvetch R4, CA, Yes Suitable habitat exists in the disturbance
(Astragalus oophorus var. MSHCP area. Species observed during field
clokeyanus) G4, S2 surveys.
76
Table 3-14 (cont’d). Special-status plant species1 occurring or suspected to occur on the Spring
Mountains National Recreation Area, Humboldt-Toiyabe National Forest, and their level of analysis
for this project.
Species Comments4,5
Spring Mountains milkvetch R4, CA, No Suitable habitat includes rocky, gravelly,
(Astragalus remotus) MSHCP and sandy calcareous soils in washes and
G2, S2 drainages, or on hillslopes and rocky
ledges of desert shrub communities at
3,400 to 7,050 feet in elevation.
distribution.
Spring Mountains rockcress R4 No Habitat is present in clearings in the
(Boechera nevadensis) G1, S1 disturbance area, especially on the
south- and east-facing slopes near the
BCT, but species is not known to exist
in the vicinity of the ski area (NNHP
2016) and was not observed during
pedestrian surveys.
Upswept moonwort R4, CA No The Three Springs area upslope of the
(Botrychium ascendens) G3, S1 Sherwood lift is the most suitable habitat
in the disturbance area, but species is not
known to exist in the vicinity of the ski
area (NNHP 2016) and was not observed
during pedestrian surveys.
Dainty moonwort R4, CA Yes Suitable habitat exists in the disturbance
(Botrychium crenulatum) G3, S1? area. Species observed during field
surveys.
Slender moonwort R4 No Potential habitat occurs in disturbance
(Botrychium lineare) G3, SNR area, but species is not known to occur
in the vicinity of the ski area (NNHP
2016) and was not observed during
pedestrian surveys.
Moosewort R4 No There is potential habitat in sparsely-
(Botrychium tunux) G3/G4, S1 vegetated open areas that correspond to
ski runs and avalanche chutes, but
species is not known to occur in the
vicinity of the ski area (NNHP 2016)
and was not observed during pedestrian
surveys.
Clokey’s paintbrush MIS, MSHCP Yes Suitable habitat exists in the disturbance
(Castilleja applegatei var. G3, S3 area. Species observed during field
martini = C. martini var. surveys.
clokeyi)
Clokey’s thistle CA, MSHCP Yes Suitable habitat exists in the disturbance
(Cirsium clokeyi = C. eatonii G2, S2/S3 area. Species observed during field
var. clokeyi) surveys.
77
for this project.
Species Comments4,5
Wasatch draba R4 No Disturbance area contains avalanche
(Draba brachystylis) G1/G2, S1 chutes and drainages that are suitable
habitat, primarily on north-facing slopes,
but species is not known to occur in the
vicinity of the ski area (NNHP 2016),
and was not observed during the
pedestrian surveys.
Jaeger’s draba R4, MIS, CA, No Disturbance area has areas of potential
(Draba jaegeri) MSHCP habitat, primarily in the small clearings
G2, S2 to the south of the base area, and a
population was observed in the
disturbance area in 1976. That
population has not been relocated since
(NNHP 2016). No plants were observed
Charleston Mountain draba R4, CA, No Suitable habitat exists within the
(Draba paucifructa) MSHCP disturbance area, especially on the rock
G1/G2, S1/S2 ledges and in drainages and avalanche
chutes on the north-facing slopes. The
species is known to occur on the
hillslope and ridgeline above the
disturbance area but not within the ski
area (NNHP 2016). It was not observed
Nevada willowherb R4, CA No Potential habitat in the disturbance area
(Epilobium nevadense) G3, S2 is located near the BCT, extending
upslope to the ridgeline, but species is
not known to occur in the vicinity of the
ski area (NNHP 2016) and was not
observed during the pedestrian surveys.
Charleston Mountain goldenbush R4 Yes Suitable habitat exists in the disturbance
(Ericameria compacta) G2?, S2? area. Species observed during field
surveys.
Inch high fleabane MSHCP Yes Suitable habitat exists in the disturbance
(Erigeron uncialis ssp. G3/G4, S3? area. Species observed during field
conjugans) surveys.
Clokey’s buckwheat R4 No Suitable habitat includes carbonate

(Eriogonum heermannii var. G5, S2 outcrops, talus, scree, and gravelly
clokeyi) washes in creosote, shadscale, and
blackbrush communities at elevations of
4,000 to 6,000 feet. Disturbance area is
outside of known distribution.
78
for this project.
Species Comments4,5
Clokey’s greasebush R4, CA, No There is potential habitat on ledges north
(Glossopetalon clokeyi) MSHCP of the BCT and on the south of the
G2, S2 disturbance area where two associated
species grow, but species is not known
to occur in the vicinity of the ski area
(NNHP 2016) and was not observed
Smooth pungent greasebush R4, CA, No Suitable habitat includes crevices of
(Glossopetalon pungens var. MSHCP carbonate cliffs and outcrops, avoiding
glabra = G. p. var. glabrum = G. G2/G3, S2/S3 southerly exposures, in pinyon-juniper
p. var. pungens) and montane conifer forests, and in
mountain mahogany communities at
elevations from 6,000 to 7,800 feet.
distribution.
Lemmon’s rubberweed MIS No The species is not known to occur in the
(Hymenoxys lemmonii) G4, SNR vicinity of the ski area (NNHP 2016)
and was not observed during pedestrian
surveys.
Hidden ivesia R4, CA, No Suitable habitat includes moist to dry
(Ivesia cryptocaulis) MSHCP carbonate scree, talus, outcrops, and
G2, S2 gravelly soils on steep slopes, ridges and
alpine flats in upper subalpine conifer
forests or alpine communities at
elevations between 10,890 and 11,915
feet. Disturbance area is outside of
known distribution.
Jaeger’s ivesia R4, MIS, CA, No Previous surveys documented
(Ivesia jaegeri) MSHCP populations on the ridgeline south of the
G2/G3, S2/S3 ski area, above the disturbance area
(NNHP 2016), but the species was not
observed during the pedestrian surveys.
Hitchcock’s bladderpod R4, MSHCP Yes Suitable habitat exists in the disturbance
(Lesquerella hitchcockii = G3, SNR area. Species observed during field
Physaria hitchcockii var. surveys.
hitchcockii)
Charleston pinewood lousewort MSHCP G4, Yes Suitable habitat exists in the disturbance
(Pedicularis semibarbata var. S3 area. Species observed during field
charlestonensis) surveys.
79
for this project.
Species Comments4,5
Death Valley beardtongue CA No Suitable habitat includes sandy or
(Penstemon fruticiformis ssp. G4, S2 gravelly washes within the Mojave
amargosae) Desert scrub communities and pinyon-
juniper woodlands at elevations between
3,100 and 6,332. Disturbance area is
Charleston beardtongue R4, CA, Yes Suitable habitat exists in the disturbance
(Penstemon leiophyllus var. MSHCP area. Species observed during field
keckii) G3, S2 surveys.
Jaeger’s beardtongue R4, MSHCP No Suitable habitat is present in the majority

(Penstemon thompsoniae ssp. G4, S2 of the disturbance area, but the species is
jaegeri) not known to occur in the vicinity of the
ski area (NNHP 2016) and was not
observed during pedestrian surveys.
Quaking aspen MIS Yes Suitable habitat exists in the disturbance
(Populus tremuloides) G5, SNR area. Species observed during field
surveys.
Golden currant MIS No Suitable habitat includes stream banks,
(Ribes aureum) G5, SNR often including willow thickets at
elevations between 6,000 and 8,000 feet.
distribution.
Clokey’s mountain sage CA, MSHCP Yes Suitable habitat exists in the disturbance
(Salvia dorrii var. clokeyi) G5, S3 area. Species observed during field
surveys.
Clokey’s catchfly R4, CA, No Suitable habitat includes dry to moist
(Silene clokeyi) MSHCP carbonate scree, talus, and loose rocky
G2, S2 soils on ridges, flats, and steep slopes,
often near persistent snowbanks in open
areas in the upper subalpine and lower
alpine zone at elevations between 9,940
and 11,580 feet. Disturbance area is
Charleston tansy R4, CA, No Several associated species are present in
(Sphaeromeria compacta) MSHCP the upper portion of the disturbance area,
G2, S2 and occurrences have been recorded on
the hillslope and ridgeline upslope of the
disturbance area, along the south
boundary of the ski area (NNHP 2016).
The species was not observed during
pedestrian surveys.
80
for this project.
Species Comments4,5
Charleston Mountain kittentails R4, CA, No Associated species occur in the
(Synthyris ranunculina) MSHCP disturbance area, including adjacent to
G2, S2/S3 Three Springs, and this species has been
documented in avalanche chutes upslope
of the disturbance area (NNHP 2016).
The species was not observed during
pedestrian surveys.
Charleston ground-daisy R4, CA, Yes Suitable habitat exists in the disturbance
(Townsendia jonesii var. MSHCP area. Species observed during field
tumulosa) G4, S3 surveys.
Charleston violet R4, MSHCP No Suitable habitat is present in the

(Viola charlestonensis) G3, S2/S3 disturbance area, and a single population
approximately 600 feet northeast of the
ski area has been recorded (NNHP
2016). No Charleston violet was
observed during pedestrian surveys.
1
Special-status plants include those species identified as Forest Service sensitive, Forest Service management
indicator species, Spring Mountains Conservation Agreement species of concern, and Clark County Multiple
Species Habitat Conservation Plan covered species.
2
Status: R4 = Region 4 Sensitive, MIS = management indicator species, CA = Spring Mountains Conservation
Agreement species of concern, MSHCP = Clark County Multiple Species Habitat Conservation Plan covered
species
3
Conservation rank: G = global, S = state. 1 = critically imperiled, 2 = imperiled, 3 = vulnerable, 4 = apparently
secure, 5 = secure, NR = not ranked.
4
Nevada Natural Heritage Program, Nevada Rare Plant Atlas. Available online at: http://heritage.nv.gov/atlas
5
NatureServe Explorer. Available online at: http://explorer.natureserve.org
Note that when a species is listed in more than one status category, discussion of that species in this analysis
is found under the most restrictive category. For example, Clokey’s eggvetch (Astragalus oophorus var.
clokeyanus) is a Forest Service sensitive species, a CA species of concern, and a species covered by the
Clark County MSHCP, so detailed discussion of this species is found in the sensitive species section of this
analysis.
3.5.2.1.1 Threatened, Endangered, and Candidate Species
As mentioned above, there are no known occurrences of, or potential habitat for, federally listed threatened,
endangered, or candidate species within the survey area. Federally listed species would not be affected by
the proposed action or alternatives and are not addressed further in this document.
3.5.2.1.2 Forest Service Sensitive Species
A biological evaluation (BE) was also prepared for this project (Forest Service 2019b). The BE includes
copies of pedestrian survey report forms. This document assessed the presence of Forest Service
Intermountain Region sensitive species in the survey area and analyzed potential impacts on these species
from project-related activities. A total of 29 Forest Service sensitive species are known or suspected to
occur on the SMNRA (Table 3-14). Potential suitable habitat is present in the survey area for 23 of the 29
sensitive species. However, only seven sensitive species have been documented in the survey area,
81
including during the 2016 and 2017 pedestrian surveys. Those seven species are addressed further below.
The 16 sensitive species for which there is no potential suitable habitat within the survey area would not be
affected by the proposed action or alternatives and are not addressed further in this analysis.
King’s Rosy Sandwort

King’s rosy sandwort is a small wildflower with linear, grass-like leaves. It is endemic to the Spring
Mountains and is known from Deer Creek, Lee, and Kyle canyons (Glenne and Johnson 2002). It occurs in
dry, shallow, gravelly or rocky carbonate soils on wooded slopes and ridges in the upper pinyon-juniper,
montane coniferous forest, and lower subalpine coniferous forest zones at elevations from 6,560 to 9,550
feet (NNHP 2001). It has been documented previously in the disturbance area (NewFields 2006a, Flores et
al. 2007, NNHP 2016).
In 2016, a total of 14 subpopulations were observed during the pedestrian survey. The subpopulations are
found in relatively open ponderosa pine and white fir stands in the northern portion of the survey area, and
on the Blackjack ski run. Collectively, the subpopulations are present on 12.0 acres of the survey area.
Additional areas of potential habitat are present, but not occupied.
Clokey’s Eggvetch
Clokey’s eggvetch is a perennial wildflower in the pea family with magenta flowers and speckled seedpods.
It is considered to be endemic to the Spring Mountains and is known from Lee Canyon, Wheeler Pass,
Willow Peak, Bonanza Trail above Cold Creek area, and Carpenter Canyon (Glenne and Johnson 2002).
There is an ongoing debate as to whether the occurrence discovered in Nye County was correctly identified.
Clokey’s eggvetch inhabits dry to slightly moist open sites, or drainages on gravelly soil derived from either
limestone or rhyolitic volcanic parent material. It is often found growing either in the open or beneath the
canopy of shrubs in ponderosa pine forests, in pinyon-juniper woodlands, or in old burned areas that have
Gambel oak trees between elevations of 5,400 and 8,990 feet (NNHP 2001).
Clokey’s eggvetch occurs at Lee Canyon and has been monitored for more than 20 years. The number of
individuals in the largest population has fluctuated in that time from a low of 315 plants (2016) to a high of
3,140 (2007), with an average of 1,615. The extent of the population has also varied, from 1.9 acres (2001)
to 11.1 acres (2005), with an average of 4.3 acres (Anderson 2008, Crum et al. 2012). The fluctuations in
the number of individuals and the amount of occupied habitat do not correlate with annual precipitation,
indicating that some other unknown factor is likely affecting the subpopulations.
A second, smaller subpopulation was observed in 2012 and re-visited in 2016. The number of plants
observed decreased from 52 in 2012 to 42 in 2016. Three new subpopulations were observed in 2016 that
had a combined 15 plants. These subpopulations are all located on or adjacent to ski runs. There were a
total of 4.8 acres of occupied Clokey’s eggvetch habitat in 2016 in the survey area.
Dainty Moonwort
Dainty moonwort is a small, perennial fern with a single frond that grows above ground. It is known from
the western U.S. and a number of counties in Nevada. Dainty moonwort is an aquatic or wetland dependent
species (NNHP 2001), though it is also found occasionally in wet roadside swales, ditches, and other
drainage ways that are partially to fully shaded (NatureServe 2017). It has also been discovered in a sedge
community along a dry ridgeline (Glenne and Johnson 2002).
A single population is known to occur on the hillslope south of the disturbance area, but still within the ski
area (NNHP 2016). A second small population with three plants was observed during pedestrian surveys at
the bottom of a steep ephemeral channel, in an accumulation of pine needles inside the disturbance area.
This subpopulation covered approximately 28 square feet.
82
Charleston Mountain Goldenbush

Charleston Mountain goldenbush is a compact, woody shrub, with dense foliage and yellow disc flowers.
It is endemic to the Spring Mountains between Charleston and Griffith peaks, and the Sheep Mountains to
the east (Glenne and Johnson 2002). It grows on forested carbonate slopes and adjacent ridges and low
outcrops in montane and subalpine forests from 2,850 to 11,350 feet in elevation. The forest canopy
overstory often includes bristlecone pine, limber pine, and ponderosa pine (NNHP 2001).
A number of populations of Charleston Mountain goldenbush are known to occur in the vicinity of the ski
area, including a population on the slopes above the BCT (NNHP 2016). The extent of that population, as
well as 13 previously undocumented subpopulations associated with it, was mapped during the 2016
pedestrian surveys. Collectively, the population covers approximately 26.9 acres in the survey area.
Hitchcock’s Bladderpod
Hitchcock’s bladderpod is a low-growing herb with ball-shaped fruit that grows on flat or sloping talus
ridges and rocky hillsides in mixed conifer or bristlecone pine forests or alpine communities, between
elevations of 8,200 and 11,400 feet (Recon 2000). It occurs in southern Utah (NatureServe 2017) and in
Clark, Nye, and White Pine counties of Nevada. The Spring Mountain populations are located on Mummy
Mountain, Kyle Canyon, and in the vicinity of the Charleston Peak Trail, South Loop Trail, and Big Falls
area (Glenne and Johnson 2002).
A number of populations have been identified in the vicinity of the ski area, some as early as the 1930s
(NNHP 2016). Eleven subpopulations scattered over a collective 0.4 acres on the dry, south-facing slopes
near the BCT were documented during the 2016 pedestrian surveys.
Charleston Beardtongue
Charleston beardtongue is a small wildflower with pink to lavender flowers and pale, opposite leaves. It is
endemic to the Spring Mountains and is known from Deer Creek, Mummy Mountain, and Lee and Kyle
canyons (Glenne and Johnson 2002). Suitable habitat includes ledges, gravelly, rocky, or talus slopes, open
meadows, mixed conifer, quaking aspen, and bristlecone pine forests between elevations of 7,000 and
11,200 feet (Recon 2000). NNHP records indicate that there are multiple populations in the vicinity of the
ski area (NNHP 2016).
It has been documented previously at the ski area (NewFields 2006a) and specifically in the alignment of
Lift 2 (Brickey 2012a). A total of 52 subpopulations were observed during the 2016 pedestrian surveys,
totaling 11.8 acres. They are predominantly on north-facing slopes, both beneath the forest canopy and in
open areas. Four of the subpopulations are located in the narrow valley adjacent to the BCT.
Charleston Ground-daisy
Charleston ground-daisy is a small, matted, short-lived perennial herb. It is endemic to the Spring and Sheep
mountains. In the Spring Mountains, it occurs on Bonanza and Charleston peaks; Deer Creek; Mud Spring;
Lee, Macks, Scout, and Clark canyons; and the North Loop Trail area (Glenne and Johnson 2002). Suitable
habitats include open, sparsely vegetated calcareous areas with shallow, gravelly soils on slopes and
exposed knolls in forest clearings of the pinyon-juniper, montane conifer, and lower subalpine conifer zone
at elevations from 5,200 to 11,060 feet (NNHP 2001).
Previous surveys have documented the presence of Charleston ground-daisy within the disturbance area
(Flores et al. 2007, NNHP 2016). A total of 12 subpopulations were observed during pedestrian surveys,
covering 15.4 acres. Those subpopulations are all located on the relatively open, drier, south-facing slopes
on the north side of the disturbance area. A subpopulation that was observed adjacent to the snowmaking
pond in 2010 was not observed in 2016 or 2017.
83
3.5.2.1.3 Management Indicator Species

The National Forest Management Act (NFMA; 36CFR 219.9(a)(1) requires the Forest Service to identify
species that are indictors of ecosystem health and the success of resource management. In fulfillment of
that requirement, the HTNF has designated MIS on the SMNRA according to land type association (LTA)
communities and seral stage. Table 3-15 presents the LTA communities in the disturbance area and their
associated MIS. Note that some of these species (i.e., rough angelica, Jaeger’s draba, Jaeger’s ivesia, and
golden currant) are not carried into detailed analysis as there is no suitable habitat in the disturbance area.
Palmer’s chipmunk, brown-headed cowbird, and chuckwalla are discussed in the wildlife analysis.
Table 3-15. Land type association communities in the disturbance area and their associated
management indicator species.
Communities Early Seral Mid Seral Late Seral
Palmer’s chipmunk
Mixed Conifer Rough angelica Aspen
Brown-headed cowbird
Upper Wash Rough angelica Aspen Golden currant
Jaeger’s draba, Lemon hymenoxys (Lemmon’s rubberweed), and Charleston Indian
Bristlecone Pine
paintbrush (Clokey’s paintbrush)
Cliffs Chuckwalla and Jaeger’s ivesia
Clokey’s Paintbrush
Clokey’s paintbrush is a colorful wildflower that grows on dry, gravelly slopes in the understory beneath
pinyon-juniper and limber pine at elevations between 2,730 and 11,515 feet (NNHP 2001). It is known to
occur in the Cathedral Rock, Deer Creek, Peak Spring, Lee Canyon, Kyle Canyon, and Macks Canyon and
along high elevation trails in the SMNRA, and in the Quinn Canyon and Sheep Mountain ranges in Nye
and Clark counties, Nevada. Outside of Nevada, Clokey’s paintbrush is known from the Panamint and Inyo
mountains of California (Glenne and Johnson 2002).
It has been documented in the past at the ski area (NewFields 2006a, Flores et al. 2007, NNHP 2016), and
it is abundant in the disturbance area, especially beneath the ponderosa pine canopy on south-facing slopes
and in open areas on north-facing slopes. A total of 42 subpopulations were observed during 2016
pedestrian surveys, covering 40.9 acres of the survey area.
Quaking Aspen
Quaking aspen is a deciduous tree with smooth, light-colored bark. Quaking aspen grows on a variety of
soils, particularly porous, rocky, loamy or clay soils on mountain slopes, canyons, and along streambanks
in mixed conifer forests at elevations from 6,500 to 10,000 feet (NatureServe 2017). It is shade intolerant
and can be displaced by encroaching conifers. Disturbances including top removal, fire, windthrow, and
disease-stimulated suckering (asexual reproduction).
Quaking aspen has been noted in past surveys (NewFields 2006a, Brickey 2012a, Brickey 2012b). Within
the disturbance area, quaking aspen are present along the margin of ski runs, in avalanche chutes and
drainages, and intermixed in the fir and pine forest stands. Collectively, there are approximately 223 acres
of quaking aspen within the survey area, ranging from contiguous clonal stands to clumps of individuals
scattered within fir and pine stands. As expected, aspens growing within avalanche chutes are generally
younger than those growing within and beneath the fir and pine canopy. Additional aspens occur further
upslope within the ski area.
84
3.5.2.1.4 Spring Mountains Conservation Agreement Species of Concern

The 1998 Conservation Agreement for the Spring Mountains National Recreation Area – Clark and Nye
Counties, Nevada (CA) is an agreement between Forest Service Region 4, the Nevada Department of
Conservation and Natural Resources, and the Pacific Region of the U.S. Fish and Wildlife Service (FWS).
The CA identifies species of concern for which the agencies involved will provide long-term protection.
These species are considered rare, believed to be sensitive to human disturbance, or subject to threat.
Potential habitat is present in the disturbance area for 17 of the 24 species of conservation concern listed in
the CA (including those that are also Forest Service sensitive, etc.). All but two, Clokey’s thistle and
Clokey’s mountain sage, are addressed above under other categories and not discussed further here. The
seven species of concern for which there is no potential suitable habitat in the disturbance area are not
addressed further in this analysis.
Clokey’s Thistle
Clokey’s thistle has deeply lobed leaves with large spines on the leaf lobe that grows to a height of between
3 and 6 feet. It is a Spring Mountains endemic, occurring in eastside canyons and along the main ridge from
Griffith Peak to Mummy Mountain (Glenne and Johnson 2002). Clokey’s thistle grows in dry to moist,
rocky, carbonate soils of spring and seep areas, talus slopes, drainage bottoms, avalanche chutes, and snow
depressions in openings of mixed conifer and bristlecone pine forests at elevations of 7,159 to 11,650 feet
(NNHP 2001).
It has been observed at the ski area in the past (NewFields 2006a) and was observed in the alignments of
both Lifts 2 and 3 (Brickey 2012a, Brickey 2012b). Some of areas previously occupied by Clokey’s thistle
were not occupied in 2016, perhaps as a result of erosion mitigation. In 2016, Clokey’s thistle was abundant
in disturbed areas near the base area, in avalanche scars and drainages, and beneath the forest canopy in the
lower elevations of the survey area. Thirty subpopulations were observed in the 2016 pedestrian surveys,
covering 68.9 acres.
Clokey’s Mountain Sage

Clokey’s mountain sage is a subshrub with pale green leaves and lavender, blue, or purple flowers. It is
known from the Kyle, Macks, Scout, and Lee canyons, and Deer Creek, Bonanza Peak, Mud Spring, and
Harris Mountain areas of the Spring Mountains, and the Sheep Mountains to the east (Glenne and Johnson
2002). Suitable habitat includes shallow rocky to gravelly carbonate soils on ridges, slopes, and drainages
in pinyon-juniper, montane conifer, and subalpine conifer forests, and mountain mahogany communities
from 7,070 to 9,840 feet (NNHP 2001).
The NNHP has documented the presence of Clokey’s mountain sage in the survey area and on the slopes
to the west (NNHP 2016). Flores et al. observed this species growing on the hillslope and ridgeline north
of the BCT in 2007 (Flores et al. 2007). A total of five subpopulations, covering approximately 18.9 acres,
was observed within the survey area in that same vicinity during the 2016 pedestrian surveys.
3.5.2.1.5 Clark County Multiple Species Habitat Conservation Plan Covered Species
The 2000 MSHCP is an agreement between the Clark County Department of Comprehensive Planning and
the FWS. The MSHCP identifies 79 species to be covered under an Endangered Species Act (ESA) Section
10(a) Permit (allowing for incidental take) and specifies the actions necessary to maintain the viability of
their natural habitat (Recon 2000).
Potential habitat is present for 20 species listed in the MSHCP (including overlap with species also listed
as Forest Service sensitive, etc.). All but two, inch high fleabane and Charleston pinewood lousewort, are
addressed above under other categories and not discussed further here. Those MSHCP species for which
there is no suitable potential habitat in the disturbance area are not addressed further in this analysis.
85
Inch High Fleabane

Inch high fleabane is a small, slender, short daisy endemic to southern Nevada, specifically Clark, Nye, and
White Pine counties. Within the Spring Mountains, it is known from Deer Creek, Kyle, Lee, Fletcher, and
Carpenter canyons (Glenne and Johnson 2002). It grows on carbonate outcrops and crevices in pinyon-
juniper, montane conifer, and subalpine conifer forests between elevations of 5,400 and 11,100 feet (NNHP
2001).
Though inch high fleabane had not been documented in the vicinity of the ski area in the past (NNHP 2016),
seven subpopulations were observed during the 2016 pedestrian surveys. The subpopulations are located in
crevices in large rock outcrops in the southwest portion of the disturbance area, beneath a canopy of white
fir (Abies concolor) and limber pine. They occupy 0.5 acres of the survey area.
Charleston Pinewood Lousewort

Charleston pinewood lousewort is a perennial herb that grows on gravelly soils beneath the canopy of pine
and mixed conifer forests at elevations between 8,400 and 9,800 feet (Recon 2000). It is a parasitic species
associated with bristlecone and ponderosa pines. It occurs in Lee, Kyle, Carpenter, and Fletcher canyons,
and near Harris Springs in the Spring Mountains (Glenne and Johnson 2002).
Charleston pinewood lousewort has been documented previously at the ski area (NewFields 2006a),
including on the hillslope above the BCT (Flores et al. 2007, NNHP 2016) and in the alignment of Lift 2
(Brickey 2012a). The 2016 surveys found that the species is widely distributed across the survey area,
though it is more common at mid to lower slope areas where ponderosa pine is dominant. It is absent on
open areas including ski runs, the base area, in avalanche scars, and on exposed south-facing slopes. The
12 extensive subpopulations observed in 2016 cover approximately 311.1 acres in the survey area.
3.5.2.2 Invasive Species

The Nevada Department of Agriculture maintains a list of weed species considered noxious. Those species
are harmful to agriculture, the general public, or the environment because they tend to displace native plants,
degrade wildlife habitat, alter nutrient cycle and fire behavior, contribute to soil erosion, and potentially
reduce recreational values. They have developed many characteristics, such as rapid growth rates, high
seed production, and extended growing periods that give them competitive advantages over native plants
(Creech et al. 2010).
The Forest Service must consider the risk of introducing or spreading noxious weeds through ground
disturbing activities associated with the proposed action. Weeds may be introduced if the equipment used
has operated previously in an area with infestations. Disturbing soil adjacent to existing infestations may
facilitate the spread of the infestation. Landowners with noxious weed infestations are required to
implement control measures. The ski area is responsible for controlling noxious weeds in the permit area.
Non-native invasive plants are also a concern. They are aggressive species capable of degrading
environmental quality or causing economic harm. Invasive plants are undesirable in forest ecosystems for
reasons similar to noxious weeds.
Management direction has been provided with regard to noxious weeds and invasive species. Executive
Order 13112, issued in February 1999, directs federal agencies to “…prevent the introduction of invasive
species and provide for their control and to minimize the economic, ecological, and human health impacts
that invasive species cause…” One of the goals of NFMA is to provide a diversity of plant and animal
communities. NFMA also includes a disclosure requirement for proposed noxious-weed-control activities
on NFS lands. The Forest Service Manual (FSM) sets objectives, policies, and responsibilities for weed
management on NFS lands and specifies the use of an integrated approach including prevention, control,
cooperation, and education. Finally, specific guidance is provided to the HTNF in FSM 2080 Supplement
2000-2004-1 that establishes Forest policy for noxious weed procedures (i.e., best management practices)
that include the use of a noxious weed risk assessment.
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Because of the extensive number of special-status plant species at the ski area – many of them endemic to
the Spring Mountains – the ski area’s special use permit includes a provision requiring a written request,
approved by the Forest Service, in order for the ski area to use herbicides for weed control.
Surveyors also documented the presence of noxious and non-native invasive plant species in the survey
area during the 2016 and 2017 pedestrian surveys. No state or federal noxious weeds were observed in the
survey area. Of the eight non-native invasive plant species known to occur on the SMNRA, three were
observed: African mustard, prostrate knotweed, and common mullein (Table 3-16).
3.5.2.2.1 African Mustard
African mustard is an annual, introduced, forb, with narrow, linear fruit that inhabits disturbed sites. It was
previously documented at the Rainbow Quarry west of Las Vegas (Niles and Leary 2013). During the 2016
pedestrian surveys, three subpopulations of African mustard were observed on the south and west margins
of the existing parking lot. Collectively, the subpopulations include 12 plants and cover approximately 555
square feet of the disturbance area.
3.5.2.2.2 Prostrate Knotweed
Prostrate knotweed is a low-growing, mat-forming, annual forb. It is known from Spring Mountain Ranch,
Red Spring, Bridge Mountain, Kyle Canyon, and near Whiskey Spring, typically at elevations from 3,700
to 7,680 feet (Niles and Leary 2013).
A total of 16 separate subpopulations were observed in the disturbance area during the 2016 pedestrian
surveys. The subpopulations are located on the south and west margins of the existing parking lot, in pockets
along the shoulder of SR 156, on the Rabbit Peak ski run (learner hill), and at the base of Keno and Jacks
ski runs near the base area. The subpopulations included approximately 13,000 plants and covered
approximately 4.8 acres. The largest subpopulation is located on Rabbit Peak ski run in an area that was
subsequently disturbed to expand a septic system.
3.5.2.2.3 Common Mullein
Common mullein is a conspicuous perennial forb with large, velvety leaves and one or more slender raceme
inflorescences with yellow flowers. It is known from the northwest Spring Mountains and the Cold Creek
area, typically at elevations between elevations of 6,000 and 6,500 feet.
Three subpopulations with a total of 18 plants were observed in the disturbance area during the 2016
pedestrian surveys. The subpopulations cover a total of 3,300 square feet and are located on the shoulder
of SR 156, adjacent to a wash in the base area, and in the maintenance yard.
3.5.2.2.4 Risk Assessment
Noxious and non-native invasive risk assessments involve two factors: 1) the likelihood of undesirable plant
species spreading to the project area, and 2) the consequence of undesirable plant establishment in the
project area. Both factors have ratings and associated point scores and are used to quantify the level of risk,
as described in Table 3-17. The ratings are determined for each element associated with a proposed action
or alternative.
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Table 3-16. Noxious and non-native invasive plant species occurring on the Spring Mountains National
Recreation Area, Humboldt-Toiyabe National Forest and their level of analysis for this project.
Carried into
Species Category1 Detailed Comments2, 3, 4, 5
Analysis?
Russian knapweed Noxious, B No Grows in waste places, along roadsides, and adjacent
(Acroptilon repens) to waterways in all Nevada counties. Reported from
Kyle Canyon at elevation of 5,415 feet. Not observed
during field surveys. Outside of known distribution.
Curveseed butterwort Invasive No Dry upland communities. Reported from Lovell
(Ceratocephala testiculata) Canyon at elevations between 5,400 and 6,000 feet.
Not observed during field surveys.
Redstem stork’s bill Invasive No Grows in open, disturbed areas at elevations between
(Erodium cicutarium) 4,400 and 6,000 feet. Outside of known distribution.
Not observed during field surveys.
African mustard Invasive Yes Species observed during field surveys.
(Malcolmia africana)
Horehound Invasive No Grows near spring and in disturbed areas at
(Marrubium vulgare) elevations between 3,750 and 6,000 feet. Outside of
known distribution. Not observed during field
surveys.
Prostrate knotweed Invasive Yes Species observed during field surveys.
(Polygonum aviculare)
Cutleaf nightshade Invasive No Grows on a sandy site at Spring Mountain Ranch at
(Solanum triflorum) elevation of 3,870 feet. Outside of known
distribution. Not observed during field surveys.
Saltcedar Noxious, C No Grows along waterways, lakes, and ponds in all
(Tamarix spp.) Nevada counties. Not observed during field surveys.
Puncturevine Noxious, C No Grows in dry, sandy soils, often near roadsides, in

(Tribulus terretris) crop fields, or other waste areas in all Nevada
Counties. Not observed during field surveys.
Siberian elm Invasive No Grows in waste places, roadsides, and fencerows at
(Ulmus pumila) elevations from 0 to 7,215 feet. Outside of known
distribution. Not observed during field surveys.
Common mullein Invasive Yes Species observed during field surveys.
(Verbascum thapsus)
1Category A = weeds that are generally not found or that are limited in distribution throughout the state, and that are subject to
active exclusion from the state and active eradication wherever found, and active eradication from the premises of a dealer of
nursery stock.
Category B = weeds that are generally established in scattered populations in some counties of the state, and that are subject to
active exclusion where possible, and active eradication from the premises of a dealer of nursery stock.
Category C = weeds that are generally established and widespread in many counties of the state, and that are subject to active
eradication from the premises of a dealer of nursery stock.
2Nevada Department of Agriculture. Nevada Noxious Weed List. http://agri.nv.gov/Plant/Noxious_Weeds/Noxious_Weed_List/
3Welsh et al. 2015.
4Flora of North America (2017) www.efloras.org
5Niles and Leary (2013).
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Table 3-17. Noxious and non-native invasive species risk assessment ratings.
Rating Points Description
Factor 1: Likelihood of undesirable plants spreading to the project area.
None 0 Undesirable plants, including noxious weed species not located within or
adjoining the project area. Project activity is not likely to result in the
establishment of undesirable species on the project area.
Low 1 Undesirable plant species present in areas adjacent to but not within the project
area. Project activities can be implemented and prevent the spread of undesirable
plants into the project area.
Moderate 5 Undesirable plant species adjoining or within the project area. Project activities
are likely to result in some areas becoming infested with undesirable plant species
even when preventative management actions are followed. Control measures are
essential to prevent the spread of undesirable plants or noxious weeds within the
project area.
High 10 Heavy infestations of undesirable plants are located within or adjoining the
project area. Project activities, even with preventative management actions, are
likely to result in the establishment and spread of undesirable plants on disturbed
sites throughout much of the project area.
Factor 2: Consequence of undesirable plant establishment in the project area.
Low 1 None. No cumulative effects expected.
Moderate 5 Possible adverse effects on site and possible expansion of infestation within
project area. Cumulative effects on native plant community are likely, but
limited.
High 10 Obvious adverse effects within the project area and probable expansion of
undesirable plants, including noxious weed infestations to areas outside the
project area. Adverse cumulative effects on native plant community are probable.
After both factors have been evaluated for the different elements, the points for each are multiplied to
generate a total value for each element. That value is then used to assign a risk determination, as described
in Table 3-18.
Table 3-18. Noxious and non-native invasive species risk assessment determinations.
Value1 Risk Rating Action
0 None Proceed as planned.

1, 5, or 10 Low Proceed as planned. Initiate control treatments on undesirable plant populations
that get established in the area.
25 Moderate Develop preventative management measures for the proposed project to reduce
the risk of introduction or spread of undesirable plants into the area. Monitor the
area for at least 3 consecutive years and provide for control of new infestations.
50 or 100 High Modify project design and implement preventative management measures for the
proposed project to reduce the risk of introduction or spread of undesirable plants
into the area. Monitor the area for at least 5 consecutive years and provide for
control of new infestations.
1
Values derived by multiplying the corresponding point value from Factor 1 and Factor 2. See Table 3-17.
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The risk assessment results for the elements associated with the proposed action and BCT alternative are
provided below in sections 3.5.3.2.2 and 3.5.3.3.2, respectively.

3.5.3.1 No-Action Alternative
3.5.3.1.1 Special-Status Species
Since there would be no ground-disturbing or habitat-altering elements under the no-action alternative,
there would be no impact on Forest Sensitive species, MIS, CA species of concern, or MSHCP covered
species.
3.5.3.1.2 Invasive Species
As there would be no disturbance of the existing habitat due to proposed elements, the noxious and non-
native invasive weed conditions would remain as described in the affected environment section. Given the
nature of the noxious weeds present in the area, there is a moderate risk that African mustard, prostrate
knotweed, and common mullein may continue to expand. The risk of expansion for African mustard is
relatively low based on the small numbers present and the limited distribution. Prostrate knotweed would
likely continue to be present at the lower extent of the ski runs and in the base area. The prostrate knotweed
infestation on the Rabbit Peak ski run that was removed by the construction of the septic system upgrade
would likely return from seeds in the soil or from the spread of the residual bordering infestation. And
common mullein would continue to be present along the roadside and in the drainage near the base area.
The ski area would treat existing weed infestations with the objective of either controlling or eradicating
these known occurrences, consistent with the terms of their special use permit.

As described in section 3.2 the proposed elements will result in four disturbance types: clearing, glading,
grading, and excavation. Clearing will be done to open corridors for the alignment of the zip line and Chairs
5 and 8. Glading will be done to open the forest canopy to facilitate tree skiing. Grading will recontour the
ground surface for ski runs, hiking and biking trails, access roads to Chairs 5 and 8, the alignment of Lifts
4 and 6, and for the parking area. Excavation will occur at the terminals of Chairs 5 and 8, Lifts 4 and 6,
zip line terminals, utilities, and buildings. Each has the potential to affect both the special-status plant
species and the noxious and non-native plant species present in the project area.
Table 3-19 indicates the extent of disturbance to occupied special-status plant species habitat affected by
the proposed action. Discussion of those impacts by category follows. Note again that since special-status
categories overlap considerably, many species are on more than one list. In those instances, the species is
addressed in detail under the most restrictive category and not under the others.
Several aspects of this impact assessment carry across special-status categories and species. They are
summarized as follows and not repeated for each species below:
• Recreation use during the winter season is not likely to impact special-status plants, since they
would be dormant and insulated by a layer of snow.
• Recreation use during the summer months is not anticipated to impact occupied habitat beyond the
actual disturbance footprints indicated in Table 3-19. Although some visitors may hike/bike off
trail, the continued use of vegetation design criteria and mitigation would minimize off-trail use
(see Appendix B). Similar design criteria have been successfully employed at Lee Canyon to
protect special-status plant species. Some impact may occur if bike riders crash and/or leave the
trail in occupied habitats.
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• Impacts on pollinator species have the potential to impact plant communities, including sensitive
species (section 3.13.8).
• Design criteria for prevention of noxious weed introduction or spread would be employed, reducing
competition and habitat alteration associated with the spread of noxious or non-native invasive
species.
Table 3-19. Acres of occupied special-status plant species habitat affected by the proposed action.
Number of
Percent of Acres
Species Name Occupied Acres in Affected Acres
Affected
Survey Area
King’s rosy sandwort 12.0 1.1 9
Clokey’s eggvetch 4.8 0.6 13
Dainty moonwort >0.1 0 0
Clokey’s paintbrush 40.9 3.3 8
Clokey’s thistle 68.9 21.1 31
Charleston Mountain goldenbush 26.9 1.6 6
Inch high fleabane 0.5 <0.1 2
Hitchcock’s bladderpod 0.4 <0.1 4
Charleston beardtongue 11.8 1.7 14
Charleston pinewood lousewort 311.1 100.4 32
Quaking aspen 223.0 95.2 43
Clokey’s mountain sage 18.9 1.9 10
Charleston ground-daisy 15.4 1.2 8
Forest Sensitive Species

The seven Forest Service sensitive species potentially affected are discussed below.
The proposed action would impact 1.1 acres of the 12 acres of occupied King’s rosy sandwort habitat in
the survey area (Table 3-19), or 9 percent. The elements involving clearing (i.e., zipline) and glading would
occur on 0.7 acres of occupied habitat and are likely to result in short-term impact since there would be
limited ground disturbance. Clearing and glading would decrease canopy cover, but as suggested by the
presence of King’s rosy sandwort in areas with little or partial canopy cover elsewhere in the ski area, the
species can tolerate those conditions. Individuals impacted by foot traffic, falling trees, or machinery during
clearing and glading may be replaced through reproduction of remaining plants. The remaining 0.4 acres
of occupied habitat would be graded or excavated and would result in a long-term impact.
Overall, the proposed action may impact individuals but is not likely to cause a trend toward federal listing
or loss of viability of King’s rosy sandwort because the majority of the impacts would be short-term, and
because the long-term effects would occur on a small amount of the habitat present.
Clokey’s Eggvetch
As described above, the amount of occupied Clokey’s eggvetch habitat in the ski area has varied from 1.9
to 11.0 acres. In 2016, 4.8 acres of occupied habitat were documented in the survey area, 0.6 acres, or 13
percent, within the proposed action disturbance area. Clearing for the zipline would occur on 0.1 acres of
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occupied habitat and is likely to result in short-term impact since there would be limited ground disturbance.
Clearing would decrease canopy cover, but as suggested by the presence of Clokey’s eggvetch in areas with
little or partial canopy cover elsewhere at the ski area, the species can tolerate those conditions. Individuals
impacted by foot traffic, falling trees, or machinery during clearing and glading may be replaced through
reproduction of remaining plants. The remaining 0.5 acres of occupied habitat would be graded (bike trails)
or excavated (mountain coaster, utilities, and building) and would result in a long-term impact.
Overall, the proposed action is likely to result in a trend toward federal listing or loss of viability of Clokey’s
eggvetch. Since the populations at the ski area are experiencing so much numerical and spatial variability,
impacting 13 percent of the current population extent could cross, or move toward, a threshold that would
make recovery difficult.
Dainty Moonwort
There are an estimated 28 square feet of occupied dainty moonwort habitat in the survey area, none of
which would be disturbed by project elements associated with the proposed action. Recreation use during
the summer months is not anticipated to impact occupied habitat due to the steepness of the terrain and
isolation of the occupied habitat.
The proposed action would have no impact on dainty moonwort. The disturbance area does not overlap
with occupied habitat, and recreation use patterns are not expected to change during the growing season in
a manner that would have an effect on occupied habitat.
There are an estimated 26.9 acres of occupied Charleston Mountain goldenbush habitat in the survey area,
including 1.6 acres, or 6 percent, within the proposed action disturbance area. Approximately 0.3 acres of
the occupied habitat would be impacted by clearing, which is unlikely to be detrimental since the species
exists in open areas. The remaining acres would be impacted by grading for bike trails (0.7 acres) and
excavation for Chair 8 and zip line terminals, the first aid building, and the mountain coaster (0.6 acres).
Subpopulations in proposed graded areas may recover up to the footprint of the bike trails, but those in
proposed excavation areas would be permanently displaced. The shrubby growth form of the plant provides
some protection from trampling. Overall, the proposed action may impact individuals but is not likely to
cause a trend toward federal listing or loss of viability of Charleston Mountain goldenbush.
There are an estimated 0.4 acres of occupied Hitchcock’s bladderpod habitat in the survey area, including
705 square feet, or 4 percent, within the proposed action disturbance area. Approximately 510 square feet
of the occupied habitat would be impacted by grading for bike trails, and the remaining 195 square feet
would be impacted by excavation for the mountain coaster. Subpopulations in proposed graded areas may
recover up to the footprint of the bike trails, but those in proposed excavation areas would be permanently
displaced. Overall, the proposed action may impact individuals but is not likely to cause a trend toward
federal listing or loss of viability of Hitchcock’s bladderpod.
There are an estimated 11.8 acres of occupied Charleston beardtongue habitat in the survey area, including
1.7 acres, or 14 percent, within the proposed action disturbance area. Approximately 0.2 acres of the
occupied habitat would be impacted by glading. That impact is likely to be short-term or minimal, since the
species exists in an area that was gladed in 2012 – 2013. The remaining 1.5 acres impacted by grading (ski
runs, hiking and biking trails, and access roads), and excavation (lift terminals and snowmaking lines)
would be a long-term displacement of occupied habitat.
Because this species produces a conspicuous flower, individuals growing adjacent to trails may be targeted
for wildflower collection by summer recreationists. Overall, the proposed action may impact individuals
but is not likely to cause a trend toward federal listing or loss of viability of Charleston beardtongue.
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There are an estimated 15.4 acres of occupied Charleston ground-daisy in the survey area, including 1.2
acres, or 8 percent, within the proposed action disturbance area. Approximately 0.2 acres of the occupied
habitat would be impacted by clearing, which is unlikely to be detrimental since the species exists in open
areas. The remaining 1.0 acres impacted by grading (biking trails), and excavation (zip line terminals and
mountain coaster) would be a long-term displacement of occupied habitat. Overall, the proposed action
may impact individuals but is not likely to cause a trend toward federal listing or loss of viability of
Charleston ground-daisy.
Management Indicator Species

There are an estimated 40.9 acres of occupied Clokey’s paintbrush habitat in the survey area, including 3.3
acres, or 8 percent, within the proposed action disturbance area. Approximately 0.3 acres of the occupied
habitat would be impacted by clearing for the zipline and glading. Those impacts are likely to be short-term
or minimal, since the species exists in open areas and an area that was gladed in 2012 – 2013. The remaining
3.0 acres impacted by grading (ski runs, hiking and biking trails, and access roads), and excavation (zip line
terminals, mountain coaster, buildings, and snowmaking lines) would be a long-term displacement of
occupied habitat.
Because this species produces a conspicuous flower, individuals growing adjacent to trails may be targeted
for wildflower collection by summer recreationists. Overall, the proposed action would have a small effect
on Clokey’s paintbrush. The proposed action would not alter the existing trend for Forest-level Clokey’s
paintbrush populations although it would reduce the amount of habitat.
Quaking Aspen
There are an estimated 223 acres of occupied quaking aspen habitat, including 95.2 acres, or 43 percent,
within the proposed action disturbance area. Approximately 2.3 acres of the occupied habitat would be
impacted by clearing (zip line, Chair 5, and Chair 8 alignments), 14.7 acres would be impacted by glading,
68.6 acres would be impacted by grading (hiking and biking trails, ski runs, access roads, and parking), and
9.6 acres would be impacted by excavation (utilities, snowmaking, lift and zip line terminals and towers,
buildings, mountain coaster, and a water tank). The glading impact could be a short-term adverse impact if
quaking aspen are cut but may also create a beneficial impact by opening the canopy and facilitating
regeneration. Clearing, grading, and excavation would result in a long-term impact and removal of quaking
aspen from the footprints of those project elements. There may also be a beneficial impact in the adjacent
areas by opening the canopy and stimulating regeneration, especially where quaking aspen are already
present. Small trees with crowns extending above the snowpack may be damaged by skiers, snowboarders,
or snow grooming equipment.
To assess aspen effects at the SMNRA scale, a second estimate was generated using data from a joint effort
by the SMNRA, the Remote Sensing Applications Center, and Intermountain Regional Office Vegetation
Classification, Mapping and Quantitative Inventory. Based on aspen stands greater than 5 acres (2 acres in
riparian areas), that data identified a total of 698 acres of aspen in the SMNRA, including approximately
31 acres in the survey area. Overlaying disturbance under the proposed action yielded an impact area of
20.1 acres, or 2.8 percent of the SMNRA total.
Overall, the proposed action would have a small effect on quaking aspen. The proposed action would not
alter the existing trend for SMNRA or Forest-level aspen, and the reduction of aspen habitat would be
minimal.
Spring Mountains Conservation Agreement Species of Concern

Clokey’s Thistle
There are an estimated 68.9 acres of occupied Clokey’s thistle habitat, including 21.1 acres, or 31 percent,
within the proposed action disturbance area. Due to the propensity of Clokey’s thistle to become established
in disturbed areas, the elements involving clearing (Chair 5 and zipline), glading, and grading (biking and
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hiking trails, chair and lift alignments, access roads, and parking) would occur on 16.7 acres of occupied
habitat and are likely to result in short-term adverse impacts or even a beneficial impact. Seeds present in
the soil are likely to be adequate to re-establish the displaced individuals, and their germination may be
facilitated by the ground disturbance. The remaining 4.4 acres of occupied habitat would be excavated and
would result in a long-term adverse impact.
The abundance of spines and height Clokey’s thistle decrease the likelihood of users trampling on
individuals. Overall, the proposed action may impact individuals but is not likely to cause a trend toward
federal listing or loss of viability of Clokey’s thistle. Short-term adverse effects would likely be partially
offset by potential beneficial effects, and long-term effects would only occur in a small amount of occupied
habitat.
There are an estimated 18.9 acres of occupied Clokey’s mountain sage habitat, including 1.9 acres, or 10
percent, within the proposed action disturbance area. Approximately 0.4 acres of the occupied habitat would
be impacted by clearing, which is unlikely to be detrimental since the species exists in open areas. The
remaining acres would be impacted by grading for bike trails (0.4 acres) and excavation for Chair 8 and zip
line terminals (1.1 acres). Subpopulations in proposed graded areas may recover up to the footprint of the
bike trails, but those in proposed excavation areas would be permanently displaced. The shrubby growth
form of the plant provides some protection from trampling. Overall, the proposed action may impact
individuals but is not likely to cause a trend toward federal listing or loss of viability of Clokey’s mountain
sage.
Clark County Multiple Species Habitat Conservation Plan Covered Species

Inch High Fleabane
There are an estimated 0.5 acres of occupied inch high fleabane habitat, including 385 square feet, or 2
percent, within the proposed action disturbance area. Approximately 290 square feet of the occupied habitat
would be impacted by grading for ski runs, and the remaining 95 square feet would be impacted by
excavation for a snowmaking line. However, since inch high fleabane grows in crevices of large rock
outcrops, they may be protected from impacts. When the ski area finalizes the on-the-ground layout for the
ski run and the snowmaking line, it is possible that the location of those features may be slightly adjusted
rather than remove, or drill into, those rocks. As a conservative measure, this analysis assumes that the 385
square-feet impact would occur.
Recreation use during the summer months is not anticipated to impact occupied habitat because of the
isolated nature of the occupied habitat. Overall, the proposed action may impact individuals but is not likely
to cause a trend toward federal listing or loss of viability of inch high fleabane.
There are an estimated 311.1 acres of occupied Charleston pinewood lousewort habitat in the survey area,
including 100.4 acres, or 32 percent, within the proposed action disturbance area. Approximately 21.6 acres
of the occupied habitat would be impacted by glading. That impact is likely to be short-term or minimal,
since the species exists in relatively open forest stands in the ski area. The remaining 78.8 acres impacted
by clearing (lift and zip line alignments), grading (ski runs, hiking and biking trails, access roads, and
parking areas), and excavation (lift and zip line terminals, utilities, snowmaking, and buildings) would be
a long-term displacement of occupied habitat.
Because this species is so abundant in the forested portions of the ski area, it is more likely to experience
trampling by summer recreationists. However, that same abundance may also help minimize the impact of
trampling because it is unlikely for all individuals to be affected. Overall, the proposed action may impact
individuals but is not likely to cause a trend toward federal listing or loss of viability of Charleston pinewood
lousewort, based on the abundance of the species.
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Summary
The proposed action would have no impact on rough angelica, Charleston pussytoes, Spring Mountains
rockcress, upswept moonwort, dainty moonwort, slender moonwort, moosewort, Wasatch draba, Jaeger’s
draba, Charleston Mountain draba, Nevada willowherb, Clokey’s greasebush, Jaeger’s ivesia, Jaeger’s
beardtongue, Charleston tansy, Charleston Mountain kittentails, Charleston violet, or Lemmon’s
rubberweed, because the proposed action would not directly or indirectly disturb occupied habitat for these
species.
The proposed action may impact individuals but is not likely to cause a trend toward federal listing or loss
of viability of King’s rosy sandwort, Charleston Mountain goldenbush, Hitchcock’s bladderpod, Charleston
beardtongue, Charleston ground-daisy, Clokey’s paintbrush, quaking aspen, Clokey’s thistle, Clokey’s
mountain sage, inch high fleabane, and Charleston pinewood lousewort because occupied habitat is present
for these species in the proposed action disturbance area.
The proposed action may impact individuals and may cause a trend toward federal listing or loss of viability
of Clokey’s eggvetch because the observed numerical and spatial variation in the population at the ski area,
which could amplify the affect associated with the presence of occupied habitat in the proposed action
disturbance area.
African Mustard
There are an estimated 555 square feet of African mustard in the survey area, including 160 square feet
within the proposed action disturbance area. The disturbance would be excavation for the vault toilets at
the overflow parking lot. Design criteria would be employed to prevent the introduction of additional
noxious weeds or the spread of African mustard, reducing impacts from competition and habitat alteration
on residual desired species.
Prostrate Knotweed
There are an estimated 4.8 acres of prostrate knotweed in the survey area, including 0.5 acres within the
proposed action disturbance area. Much of the impact on prostrate knotweed would be near the base area
(i.e., Rabbit Peak ski run, open areas near the lower terminals of the Sherwood and Bluebird lifts), all of
which were previously cleared. As a result, clearing for the zip line (0.1 acres) would not be necessary, so
prostrate knotweed would not actually be affected. The remaining 0.4 acres would be impacted by grading
(bike trails, ski runs, access roads, hiking trails, lift alignments, and parking), and excavation (snowmaking,
utilities, and buildings). Design criteria would be employed to prevent the introduction of additional
noxious weeds or the spread of prostrate knotweed, reducing impacts from competition and habitat
alteration on residual desired species.
Common Mullein
There are an estimated 3,300 square feet of common mullein in the survey area, including 1,382 square feet
within the proposed action disturbance area. The disturbances would be associated with grading the
proposed parking lot and excavation for the rental building at the base area. Design criteria would be
employed to prevent the introduction of additional noxious weeds or the spread of common mullein,
reducing impacts from competition and habitat alteration on residual desired species.
Risk Assessment Results

A risk assessment rating was calculated for each element associated with the proposed action by considering
the likelihood of undesirable species spreading to the project area and the consequence of undesirable
species becoming established in the project area, as described above in section 3.5.2.2.4.
The majority of the project elements have a moderate risk rating (Table 3-20) and could be completed
provided that design criteria (section 2.6) were implemented to reduce the risk of introduction or spread of
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undesirable plants into the area, and that the disturbed areas were monitored for 3 consecutive years after
construction and new infestations were controlled.
The zip line would have a low risk and could proceed as planned, though a Forest Service-authorized control
plan should be initiated to treat any undesirable plants that were established in the disturbance area. The
glading, mountain coaster, and water tank would have no risk and could proceed as planned.
Table 3-20. Noxious and non-native weed species risk assessment results for the proposed action.
Risk Assessment
Project Element Factor 1 Value Factor 2 Value
Rating
Lift 4 5 5 25
Chair 5 Pod 5 5 25
Chair 8 Pod 5 5 25
Glading 0 1 0
Snowmaking Coverage 5 5 25
Mountain Coaster 0 1 0
Mountain Bike Trails 5 5 25
Hiking Trail 5 5 25
Zip Line 5 1 5
Equipment Rental/Food & Beverage Building 5 5 25
First Aid/Ski Patrol Building 5 5 25
Vault Toilet Facility at Overflow Parking Lot 5 5 25
New Parking Lot 5 5 25
Gate House 5 5 25
Water Tank 0 1 0

In order to provide a clear contrast between the proposed action and the BCT alternative, the following
discussion focuses on how the impacts of the BCT alternative would differ from those of the proposed
action, as described above.
Table 3-21 indicates the extent of disturbance to occupied special-status plant species habitat affected by
the BCT alternative.
The same aspects of this impact assessment noted above for the proposed action carry across special-status
categories and species under the BCT alternative:
• Recreation use during the winter season is not likely to impact special-status plants, since they
would be dormant and insulated by a layer of snow.
• Recreation use during the summer months is not anticipated to impact occupied habitat beyond the
actual project element disturbance footprints indicated in Table 3-19 above. Although some visitors
may hike/bike off trail, the continued use of vegetation design criteria and mitigation would
minimize off-trail use (see Appendix B). Similar design criteria have been successfully employed
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at Lee Canyon to protect special-status plant species. Some impact may occur if bike riders crash
and/or leave the trail in occupied habitats.
• Impacts on pollinator species have the potential to impact plant communities, including sensitive
species (section 3.13.7).
• Design criteria for prevention of noxious weed introduction or spread would be employed, reducing
competition and habitat alteration associated with the spread of noxious or non-native invasive
species.
Overall, as indicated by comparing Tables 3-19 and 3-21, the BCT alternative would reduce impacts on
special-status plants across the board. The same suite of species would be affected, and the impacts would
be qualitatively similar to those outlined above for the proposed action, just reduced in extent.
Table 3-21. Acres of occupied special-status plant species habitat affected by the BCT alternative.
Number of Percent of Acres
Species Name Affected Acres
Occupied Acres Affected
King’s rosy sandwort 12.0 0.9 8
Clokey’s eggvetch 4.8 0.1 2
Dainty moonwort >0.1 0 0
Clokey’s paintbrush 40.9 2.4 6
Clokey’s thistle 68.9 20.4 30
Charleston Mountain goldenbush 26.9 0.7 3
Inch high fleabane 0.5 <0.1 2
Hitchcock’s bladderpod 0.4 <0.1 3
Charleston beardtongue 11.8 1.6 14
Charleston pinewood lousewort 311.1 93.8 30
Quaking aspen 216.7 88.3 41
Clokey’s mountain sage 18.9 0.4 2
Charleston ground-daisy 15.4 0.5 3
Forest Sensitive Species

The acreage of occupied habitat in the disturbance area would fall from 1.1 to 0.9, or from 9 to 8 percent
of the survey-area total. The BCT alternative may impact individuals but is not likely to cause a trend
toward federal listing or loss of viability because the majority of the impacts would be short-term, and
because long-term effects would occur on a small amount of the habitat present.
Clokey’s Eggvetch
of the survey-area total. The impact may be amplified by the numerical and spatial variability of this species.
However, impacting 2 percent of the current occupied habitat is not likely to cross, or move toward, a
threshold that would make recovery difficult. The BCT alternative may impact individuals but is not likely
to cause a trend toward federal listing or loss of viability of Clokey’s eggvetch.
Dainty Moonwort
As under the proposed action, no occupied habitat for this species would be affected.
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toward federal listing or loss of viability of Charleston Mountain goldenbush.
The acreage of occupied habitat in the disturbance area would be the same as under the proposed action at
less than 0.1 acres, or 3 percent of the study area total. The BCT alternative may impact individuals but is
not likely to cause a trend toward federal listing or loss of viability of Hitchcock’s bladderpod.
The acreage of occupied habitat in the disturbance area would fall from 1.7 to 1.6, no notable change in the
percentage of the survey-area total. The BCT alternative may impact individuals but is not likely to cause
a trend toward federal listing or loss of viability of Charleston beardtongue.
of the survey-area total. Overall, implementing the BCT alternative may impact individuals but is not likely
to cause a trend toward federal listing or loss of viability of Charleston ground-daisy.
Management Indicator Species

of the survey-area total. The BCT alternative would not alter the existing trend for SMNRA or Forest-level
Clokey’s paintbrush populations although it would reduce the amount of habitat.
Quaking Aspen
The acreage of occupied habitat in the disturbance area would fall from 95.2 to 88.3, or from 43 to 41
percent of the survey-area total. Using the broader-scale SMNRA data set, the BCT alternative would
impact 2.5 percent of the management area-wide aspen population.
The BCT alternative would have a small effect on quaking aspen. Adverse effects would be partially offset
by potential beneficial effects. The BCT alternative would not alter the existing trend for SMNRA or Forest-
level aspen populations although it would reduce the amount of habitat.
Spring Mountains Conservation Agreement Species of Concern

Clokey’s Thistle
percent of the survey-area total. The BCT alternative may impact individuals but is not likely to cause a
trend toward federal listing or loss of viability of Clokey’s thistle. Short-term adverse effects would likely
be partially offset by potential beneficial effects, and long-term effects would only occur in a small amount
of occupied habitat.
toward federal listing or loss of viability of Clokey’s mountain sage.
Clark County Multiple Species Habitat Conservation Plan Covered Species

Inch High Fleabane
As under the proposed action, Less than 0.1 acres would be affected, or 2 percent of the survey-area total.
The BCT alternative may impact individuals but is not likely to cause a trend toward federal listing or loss
of viability of inch high fleabane.
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percent of the survey-area total. The BCT alternative may impact individuals but is not likely to cause a
trend toward federal listing or loss of viability of Charleston pinewood lousewort, based on the abundance
of the species.
Summary
Similar to the proposed action, the BCT alternative would have no impact on rough angelica, Charleston
pussytoes, Spring Mountains rockcress, upswept moonwort, dainty moonwort, slender moonwort,
moosewort, Wasatch draba, Jaeger’s draba, Charleston Mountain draba, Nevada willowherb, Clokey’s
greasebush, Jaeger’s ivesia, Jaeger’s beardtongue, Charleston tansy, Charleston Mountain kittentails,
Charleston violet, or Lemmon’s rubberweed, because the proposed action would not directly or indirectly
disturb occupied habitat for these species.
Implementing the BCT alternative may impact individuals but is not likely to cause a trend toward federal
listing or loss of viability of King’s rosy sandwort, Clokey’s eggvetch, Charleston Mountain goldenbush,
Hitchcock’s bladderpod, Charleston beardtongue, Charleston ground-daisy, Clokey’s paintbrush, quaking
aspen, Clokey’s thistle, Clokey’s mountain sage, inch high fleabane, and Charleston pinewood lousewort
because occupied habitat is present for these species in the project area.
The main differences would be reduced area of impact across species, and a significantly reduced impact
on Clokey’s eggvetch.
As discussed above under Special-Status Plant Species, this discussion focuses on differences between the
effects of the proposed action and the effects of the BCT alternative. The only differences to note are related:
the acreage of disturbance within prostrate knotweed populations would grow from 0.5 to 0.8 acres, due
primarily to relocation of the mountain coaster, and that change would raise the risk assessment rating for
the mountain coaster from 0 to 5. That rating falls in the low range, so the mountain coaster element could
proceed as planned, with control treatments initiated on any undesirable plant populations that establish in
the area.
As under the proposed action, 160 square feet of African mustard infestation would be disturbed by
construction of vault toilets at the existing overflow parking lot, and 1,382 square feet of common mullein
infestation would be disturbed by grading in the proposed parking lot and excavation for the rental building
at the lower base area.

3.5.4.1 Special-Status Species

Since the proposed action and BCT alternative would have no effect on federally listed plant species, they
would not interact cumulatively with the actions listed in section 3.3 to have a cumulative effect on federally
listed species.
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3.5.4.1.2 Forest Sensitive Species

The cumulative actions listed in section 3.3 have the potential to interact cumulatively with the proposed
action and the BCT alternative on the following Forest Service sensitive species: King’s rosy sandwort,
Clokey’s eggvetch, Charleston Mountain goldenbush, Charleston ground-daisy, and Hitchcock’s
bladderpod. The impact analyses for those projects indicated that they may impact individuals but are not
likely to cause a trend toward federal listing or loss of viability of these same Forest Service sensitive
species. The majority of those impacts are the result of concentrated recreation use, trampling, or vegetation
treatments, though some are the result of construction.
Since the determination for the Old Mill WUI project was made, the treatment area has decreased
substantially, reducing impacts on these species.
The Lee Canyon Fuels Reduction Project area overlaps some of the glading areas under the proposed action
and BCT alternative. In areas where these projects overlap, they are likely to complement each other due
to design criteria 11 requiring the ski area to consult with the Forest Service as to which trees would be cut
in gladed areas. In areas where these projects do not overlap directly, populations of these species would
likely be impacted to some degree by the Lee Canyon Fuels Reduction Project.
Considered together, the cumulative actions and the proposed action or BCT alternative may impact
individuals but are not likely to cause a trend toward federal listing or loss of viability of Forest Sensitive
species.
The impacts of the Old Mill WUI Hazardous Fuels Reduction and Lee Canyon Fuels Reduction projects
have the potential to interact cumulatively with the impacts of the proposed action and the BCT alternative
on quaking aspen and Clokey’s paintbrush. The impact analysis for the Old Mill WUI project determined
that it may impact these two species. However, since this determination was made, the treatment area has
decreased substantially, reducing impacts on these species. The Lee Canyon Fuels Reduction Project area
overlaps some of the glading areas in the proposed action and BCT alternative. In areas where these projects
overlap, they are likely to complement each other due to design criteria 11 requiring the ski area to consult
with the Forest Service as to which trees would be cut in gladed areas. In areas where these projects do not
overlap directly, populations of these species would likely be impacted to some degree by the Lee Canyon
Fuels Reduction Project. These cumulative effects would not alter the existing trend for Forest-level
populations for these species although it would reduce the amount of habitat.
The impacts of the Old Mill, Dolomite, and McWilliams Recreation Sites Reconstruction, Old Mill WUI
Hazardous Fuels Reduction, and Lee Canyon Fuels Reduction projects have the potential to interact
cumulatively with the impacts of proposed action and BCT alternative on Clokey’s thistle and Clokey’s
mountain sage. The impact analyses for those projects determined that they may impact individuals, but are
not likely to cause a trend toward federal listing or loss of viability of these two species. Since the
determination for the Old Mill WUI project was made, the treatment area has decreased substantially,
reducing impacts on these species.
The Lee Canyon Fuels Reduction Project area overlaps some of the glading areas in the proposed action
Considering the small amount of habitat impacted relative to the amount of potential habitat in the Spring
Mountains, the cumulative action projects and the proposed action or BCT alternative may impact
individuals but are not likely to cause a trend toward federal listing or loss of viability of Clokey’s thistle
or Clokey’s mountain sage.
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The impacts of the cumulative actions listed in section 3.3 have the potential to interact cumulatively with
the impacts of the proposed action and the BCT alternative on Charleston pinewood lousewort. The impact
analyses for these projects indicated that they may impact individuals or habitat of this species. Since the
reducing impacts on these species.
Based on the abundance of occupied habitat observed at Lee Canyon that will not be impacted by either the
proposed action or BCT alternative and the amount of potential habitat elsewhere, these actions may impact
individuals but are not likely to cause a trend toward federal listing or loss of viability of Charleston
pinewood lousewort.
3.5.4.2 Invasive Species

The cumulative actions listed in section 3.3 would have a moderate short-term risk of invasive species
increase because of the considerable soil disturbance, movement of equipment and materials, and increased
vehicle traffic. Weed mitigation measures, including follow-up monitoring and treatment would ensure no
long-term increase in weeds. Similar measures would be employed at Lee Canyon. The short-term risk of
invasive species increase would be cumulative to the impacts of the proposed action or the BCT alternative.
3.5.5 MITIGATION
In addition to the design criteria outlined in section 2.6, the determinations above require the following
vegetation mitigation measures to be in place:
1. Install interpretive signs in prominent locations with information about special-status plant and
wildlife species and their habitat, including reminders to stay on designated trails.
2. Include text on summer trail maps reminding visitors to stay on designated trails in order to protect
special-status plant and wildlife species and their habitat.
3. Verbally remind visitors renting equipment, purchasing lift tickets, or asking for trail information
to stay on designated trails in order to protect special-status plant and wildlife species and their
habitat.
4. Install rope lines or signs to minimize entry into suitable special-status plant and wildlife species
habitat near high traffic areas.
5. Employ preventative management measures for the proposed projects to reduce the risk of
introduction or spread of undesirable plants into the area. Monitor the area for at least 3 consecutive
years and provide for control of new infestations.
3.5.6 FOREST PLAN COMPLIANCE

The proposed action complies with all vegetation-related SMNRA-wide standards and guidelines, except
standard 0.31:
New roads, administrative facilities, and developed recreation sites other than low-impact facilities
(trails, trailhead parking, signs, restrooms, etc.) will be outside a 100-yard-buffer zone around
known Clokey’s eggvetch and rough angelica populations or potential habitat, and outside
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biodiversity hotspots (defined as areas of particular biodiversity or sensitivity) (see Map 4 and Map
5).
Under the proposed action, 11 acres of disturbance would occur within the 100-yard-buffer zone around
occupied Clokey’s eggvetch habitat. That disturbance would include grading (Chair 5 ski runs and access
road, Chair 8 ski runs and access road, Lift 4 and Lift 6 alignments, and parking) and excavation (utilities,
Chair 8 towers, buildings, mountain coaster, snowmaking, water tank, and zip line terminals). As described
above in section 3.5.3.2.1, the proposed action would directly impact 0.6 acres of occupied Clokey’s
eggvetch habitat. Many of the project elements would also be located within the biodiversity hotspot.
Under the BCT alternative, 6.6 acres of disturbance would occur within the 100-yard-buffer zone around
occupied Clokey’s eggvetch habitat. The disturbed acres are associated with grading (Chair 5 ski runs and
access road, Chair 8 ski runs and access road, Lift 4 and Lift 6 alignments, and parking) and excavation
(utilities, buildings, mountain coaster, snowmaking, water tank, and zip line terminals). As described in
section 3.5.3.3.1, the BCT alternative would directly impact 0.1 acres of occupied Clokey’s eggvetch
habitat. Therefore, the BCT alternative would result in much less disturbance within the 100-yard-buffer
zone, and to actual occupied habitat than the proposed action. Many of the BCT alternative project elements
would also be located within the biodiversity hotspot.
The proposed action and the BCT alternative comply with most Management Area 11 – Developed Canyons
Standards and Guidelines. The exception is standard 11.57. Standard 11.57 allows for limited expansion at
Lee Canyon provided that the expansion, among other things, “does not impact any threatened, endangered,
or sensitive species or species of concern, or its habitat.” As described above in sections 3.5.3.2 and 3.5.3.3,
the proposed action and BCT alternative would impact several species that fall within the categories listed
in standard 11.57.
3.6 WILDLIFE
Issue – Special-status Species: The SMNRA is a unique ecosystem, and the permit area includes habitat for
a number of special-status species, including federally listed species, Forest Service sensitive species, CA
species, species covered in the MSHCP, and migratory birds. Development and subsequent use of the
proposed infrastructure would result in temporary habitat disruption during construction, permanent habitat
conversion, and increased levels of human activity year-round. These changes may affect special-status
wildlife species or their habitats.
Indicator: Species-specific determinations of the potential individual- and population-level impacts, based
primarily on surveys, published information on the species’ habitat distribution and population status, and
the efficacy of design criteria and proposed mitigation. The determinations are based on the laws,
regulations, and policies regarding management of each category of species.

Special-status wildlife include those species identified as threatened, endangered, or candidate species
under the ESA; Forest Service sensitive species; Forest Service MIS; CA species of concern; and MSHCP
covered species. Species from each of these categories are carried into detailed analysis below if individuals
or habitat could be impacted by the project. Table 3-22 identifies these species.
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Table 3-22. Special-status species with the potential to occur in the project area.
Carried into
Species
Species1 Habitat Description Detailed Rationale
Status2
Analysis?
Insects
Spring Mountains dark R4, CA, Areas with open water in Yes Habitat exists in the
blue butterfly MSHCP mixed conifer forests disturbance area.
(Euphilotes anicilla (Thompson and Abella 2016).
purpura)
Morand’s checkerspot R4, CA, Open areas in conifer or mixed Yes Habitat exists in the
(Euphydryas anicia MSHCP conifer forests (Hiatt and disturbance area.
morandi) Boone 2004).
Spring Mountains CA, MSHCP Areas with open water in Yes Habitat exists in the
comma skipper mixed conifer forests (Hiatt disturbance area.
(Hesperia colorado and Boone 2004).
mojavensis)
Charleston ant CA Subterranean nests in Yes Habitat may exist in
(Lasius nevadensis) unknown habitats (Cole 1956). the disturbance
area.
Nevada admiral CA, MSHCP Varied forested habitats as Yes Habitat exists in the
(Limenitis weidemeyerii well as riparian areas (Hiatt disturbance area.
nevadae) and Boone 2004).
Spring Mountains CA, MSHCP Open meadows in a wide Yes Habitat exists in the
icarioides blue butterfly variety of habitats (Hiatt and disturbance area.
(Plebejus icarioides Boone 2004).
austinorum)
Mt. Charleston blue Endangered, Open meadows where host Yes Habitat exists in the
butterfly CA, MSHCP and nectar plants are present in disturbance area.
(Plebejus shasta sufficient densities (FWS
charlestonensis) 2015).
Carole’s silverspot CA, MSHCP All habitats in the SMNRA Yes Habitat exists in the
(Speveria carolae) (Thompson et al. 2014). disturbance area.
Spring Mountains R4, CA, Pinyon-juniper areas with No No habitat exists in

acastus checkerspot MSHCP rabbitbrush (Thompson et al. the disturbance
(Chlosyne acastus 2014). area.
robusta)
Mammals
Desert bighorn sheep R4 Associated with hot desert No No habitat exists in
(Ovis Canadensis) environments on the SMNRA. the disturbance
area.
Pale Townsend’s big- R4,CA Roosts and hibernates in caves Yes Foraging habitat
eared bat and mines. Forages in open exists in the
(Corynorhinus forest (Bradley et al. 2006). disturbance area.
townsendii pallescens)
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Table 3-22 (cont’d). Special-status species with the potential to occur in the project area.
Carried into
Species
Status2
Analysis?
Spotted bat R4, CA Roosts in crevices in cliffs. Yes Foraging habitat
(Euderma maculatum) Forages in a wide variety of exists in the
habitats (WBWG 2017). disturbance area.
Silver-haired bat MSHCP Forages and roosts in forested Yes Foraging and
(Lasionycteris areas (NatureServe 2017). roosting habitat
noctivagans) exists in the
disturbance area.
Allen’s big-eared bat CA Mid-elevation riparian areas No The disturbance
(Idionycteris phyllotis) with open water (NatureServe area is too high
2017). elevation for this
species.
Western small-footed CA Roosts and forages in a wide Yes Foraging and
myotis variety of habitats (Hiatt and roosting habitat
(Myotis ciliolabrum) Boone 2004). exists in the
disturbance area.
Long-eared myotis CA, MSHCP Roosts and forages in a wide Yes Foraging and
(Myotis evotis) variety of habitats (Bradley et roosting habitat
al. 2006) exists in the
disturbance area.
Fringed myotis CA, MSHCP Roosts and forages in a wide Yes Foraging and
(Myotis thysanodes) variety of habitats (Bradley et roosting habitat
al. 2006). exists in the
disturbance area.
Long-legged myotis CA, MSHCP Roosts in a wide variety of Yes Foraging and
(Myotis volans) habitats. Forages in mixed roosting habitat
conifer and pinyon-juniper exists in the
areas (Ramsey 1997). disturbance area.
Palmer’s chipmunk CA, MSHCP, All forest types in the Yes Habitat exists in the
(Neotamias palmeri) MIS SMNRA (Lowrey and disturbance area.
Longshore 2010).
Birds1
Brown-headed cowbird MIS Mixed conifer MIS on the Yes The disturbance
(Molothrus ater) SMNRA. area is within the
community
association for this
MIS.
Northern goshawk R4, CA Conifer and mixed conifer Yes Habitat exists in the
(Accipiter gentilis) forests (Squires and Reynolds disturbance area.
1997).
Peregrine falcon R4, CA, Forages in open areas near Yes Foraging habitat
(Falco peregrinus) MSHCP cliffs (White et al. 2002). exists in the
disturbance area.
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Table 3-22 (cont’d). Special-status species with the potential to occur in the project area.
Carried into
Species
Status2
Analysis?
Flammulated owl R4, CA Conifer and mixed conifer Yes Habitat exists in the
(Otus flammeolus) forests (Linkhart and disturbance area.
Mccallum 2013).
Southwestern willow Endangered, Willow-dominated riparian No No habitat exists in
flycatcher CA, MSHCP areas (Sedgwick 2000). the disturbance
(Empidonax traillii area.
extimus)
Yellow-billed cuckoo Threatened, Large cottonwood-dominated No No habitat exists in
(Coccyzus americanus) MSHCP riparian areas (Hughes 2015). the disturbance
area.
Fishes
Pahrump poolfish Endangered Artificial populations exist in No No habitat exists in
(Empetrichthys latos) three springs in the Pahrump the disturbance area
Valley (FWS 2017). and no downstream
impacts would
affect this species.
Reptiles
Speckled rattlesnake MSHCP Low-elevation desert habitats No The disturbance
(Crotalus mitchellii) (NatureServe 2017). area is too high
elevation for this
species.
Western redtail skink MSHCP Low-elevation mesic sites No The disturbance
(Plestiodon gilbert (NatureServe 2017). area is too high
rubricaudatus) elevation for this
species.
1
Migratory bird species are not listed but are addressed as a group below.
2
Status: R4 = Region 4 Sensitive, MIS = management indicator species, CA = Spring Mountains Conservation
Agreement species of concern, MSHCP = Clark County Multiple Species Habitat Conservation Plan covered species
Note that when a species is listed in more than one status category, discussion of that species in this analysis
is found under the most restrictive category. For example, the Spring Mountains dark blue butterfly is a
Forest sensitive species, a CA species of concern, and a species covered by the Clark County MSHCP, so
detailed discussion of this species is found in the sensitive species section of this analysis.
3.6.2.1 Threatened, Endangered, and Candidate Species

A project-specific species list was obtained from the FWS Information for Planning and Conservation
website on June 22, 2018 (FWS 2018). This list identified four species as potentially occurring in the project
area or potentially being affected by the project. One of these species, the Mount Charleston blue butterfly
(MCBB), does have potential habitat in the project area and is discussed in detail below. However, the
project area contains no habitat or known occurrence of the southwestern willow flycatcher, yellow-billed
cuckoo, or Pahrump poolfish. As a result, the proposed action and BCT alternative would have no effect
on these three species (see Table 3-22). Any take of the MCBB that could occur, and the methodology for
determining take, will be determined through Section 7 Consultation with the FWS. This consultation
process is ongoing.
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3.6.2.1.1 Mount Charleston Blue Butterfly

The MCBB is endemic to the Spring Mountains and was first described in 1980 based on seven males and
seven females taken from Lee Canyon, from elevations of 2,515 – 2,682 meters (8,250 – 8,800 feet) (Austin
1980). The MCBB typically occurs on open, exposed, sunny, gravelly, and well-drained flats, slopes,
hilltops, or ridges (Sever 2011). The MCBB requires open habitat that supports its larval host plant, Torrey’s
milkvetch (Astragalus calycosus var. calycosus), which grows between 5,000 and 10,800 feet on the east
side of the Spring Mountains. Two other species of milkvetch have been confirmed as larval host plants
(Andrew et al. 2013) for MCBB: mountain oxytrope (Oxytropis oreophila var oreophila) and broadkeel
milkvetch (Astragalus platytropis; FWS 2015).
The MCBB is presumed to diapause (period of suspended growth or development similar to hibernation)
at the base of its larval host plant or in the surrounding substrate for at least one season. The number of
years the MCBB can remain in diapause is unknown; however, some researchers have hypothesized that in
response to unfavorable environmental conditions, a prolonged diapause period may be possible (Scott
1986, DataSmiths 2007, Boyd and Murphy 2008). Recent presence/absence surveys indicate population
fluctuation that may be attributed to extended diapause and less-than-annual adult emergence (NewFields
2008, Thompson et al. 2014). Additionally, Scott states that P. shasta is a biennial species: spending the
first winter as an ovum and the second as a late instar larva (Scott 1986). Shortly after snowmelt in mid-
June, post-diapause P. shasta larvae were located leading to the conclusion that diapause is performed by
partly grown larvae (Emmel and Shields 1978).
Adults live one season, typically a short span of time (2 – 4 weeks) during the known flight or breeding
period. The typical flight and breeding period for the MCBB is early July to mid-August with a peak in late
July, although the species has been observed as early as mid-June and as late as mid-September (FWS
2013).
Like most butterfly species, the MCBB is dependent on plants both during larval development (larval host
plants) and the adult butterfly flight period (nectar plants). The MCBB requires areas that support one or
more of its larval host and one or more of its nectar plants. Clokey fleabane (Erigeron clokeyi), Lemmon’s
bitterweed (Hymenoxys lemonii), Cooper’s bitterweed (Hymenoxys cooperi), buckwheat (Eriogonum
umbellatum spp.), snake-weed (Gutierrezia sarothrae), and rock sunflower (Petradoria pumila) are the
known nectar sources for MCBB; however, it is likely that MCBB also use trailing fleabane (Erigeron
flagellaris), rosy pussytoes (Antennaria rosea), four-nerve daisy (Tetraneuris acaulis), and rubber
rabbitbrush (Ericameria nauseosa)(Thompson 2018).
Both the phenology (timing) and number of MCBB individuals that emerge and fly to reproduce during a
particular year are reliant on the combination of many environmental factors that may constitute a
successful (favorable) or unsuccessful (poor) year for the subspecies. Little is known regarding these
aspects of this subspecies’ biology, since the key determinants for the interactions among the butterfly’s
flight and breeding period, larval host plant, and environmental conditions have not been specifically
studied. Observations indicate that above- or below-average precipitation coupled with above or below
average temperatures influence the phenology of this subspecies and are likely responsible for the
fluctuation in population numbers from year to year (FWS 2011).
Most butterfly populations exist as regional metapopulations (groups of spatially separated populations that
may function as single populations due to occasional interbreeding; Murphy et al. 1990). Boyd and Austin
(1999) indicate this is true of the MCBB. Small habitat patches tend to support smaller butterfly populations
that are frequently extirpated by events that are part of normal variation (Murphy et al. 1990). Boyd and
Austin (1999) suggest smaller colonies of the MCBB may be ephemeral in the long term, with the larger
colonies of the subspecies more likely than smaller populations to persist in poor years, when environmental
conditions do not support the emergence, flight, and reproduction of individuals.
The ability of the MCBB to move between habitat patches has not been studied; however, field observations
suggest the subspecies exhibits short within-patch movements, on the order of 10 to 100 meters (Weiss et
al. 1995), and nearly sedentary behavior (DataSmiths 2007; Boyd and Murphy 2008). During 3 years of
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intensive field surveys as part of the butterfly autecology project, metapopulation structure was not detected
in the MCBB (Thompson et al. 2014). Based on studies of closely related species, the MCBB can likely
move between patches approximately 1,000 meters apart (FWS 2015). At this distance, MCBB could move
between most of the existing patches of habitat at the ski area, given a suitable movement corridor.
Habitat Requirements
Using a resource selection model, Thompson and others (2014) recently described favorable habitat as
containing low densities of the larval host plant and high densities of nectar plants, in particular Erigeron
clokeyi, low or no grass cover, and low tree density. The Federal Register defined suitable habitat as having
a density of host plants greater than two plants per square meter and a density of nectar plants of greater
than two plants per square meter for smaller nectar plants and more than 0.1 plants per square meter for
larger nectar plants (FWS 2015).
Threats
Field surveys conducted by Sever (2011) in 2010 and 2011 recorded 63 observations in 2010 and 28
observations in 2011 within the SMNRA. There has been concern that populations of the MCBB have been
declining, but surveys have not been consistent. Before Sever (2011) surveyed in 2010 the MCBB had not
been seen since 2007. It appears the population has been gradually declining since 1995, but this has not
been confirmed due to irregular survey effort. Based on the best available information, the FWS has
concluded that these declines in distribution and abundance are a result of natural and human-caused
factors. Known threats include the following.
Fire Suppression
Fire suppression and other management practices have likely limited natural maintenance of previous
habitat and the formation of new habitat for the MCBB. The Forest Service began suppressing fires in the
Spring Mountains in 1910 (ENTRIX 2008). Throughout the Spring Mountains, fire suppression has resulted
in higher densities of trees and shrubs and a transition to a closed-canopy forest with shade-tolerant
understory species (ENTRIX 2008) that is generally less suitable for the MCBB. Boyd and Murphy (2008)
hypothesized that the loss of pre-settlement vegetation structure over time has caused the MCBB
metapopulation dynamics to collapse in Upper Lee Canyon.
Recreational Development and Fuels Reduction Projects
Unhindered recreational development and fuels reduction projects, including development at the ski area,
were identified in the federal register as potential threats to the MCBB. This is due to the fact that past, as
well as imminent, projects of this nature overlapped areas of known suitable habitat. Since this listing of
the MCBB as endangered in 2013, some of these projects have been implemented and some have not (FWS
2013). This document addresses the impacts of recreational development and ongoing recreational activities
at the ski area to address this threat.
Increases of Nonnative Plants
Nonnative plants can impact the MCBB by outcompeting the host or nectar plants this species requires. In
the past, nonnative plants have been intentionally seeded for erosion control purposes at the ski area. No
such seeding has occurred at the ski area since 2005 but many nonnative plants remain at the ski area from
past seedings (FWS 2013). No new seedings are currently proposed and design criteria included for this
project are intended to prevent the spread of nonnative plants into other areas. Any future revegetation
would need to be done in compliance with mitigation measure 20.
Human Disturbance
Human disturbance has not been identified as a threat to the MCBB and there is no literature available
describing the impacts of human disturbance on individual MCBB adults. There is no literature available
describing the impacts of human disturbance on the MCBB. However, a study of a related species, the
Karner’s blue butterfly, identified 4.2 meters as the maximum distance at which a flushing response was
triggered by passing hikers (Bennett et al. 2010). In this analysis, a conservative distance of 5 meters is
used for the distance at which a flushing response could be triggered by human activity. Further results of
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Bennett et al. (2010) are based on computer modeling of simulated butterflies and may not be applicable
beyond the environment simulated.
Suitable Habitat in the Project Area

In June of 2015, the FWS designated 5,210.2 acres of critical habitat in three units across the range of the
MCBB (FWS 2015). The Lee Canyon unit includes approximately 2,569.3 acres of designated critical
habitat of which 414 acres overlaps with the Lee Canyon Ski Area permit boundary. Not all of the
designated critical habitat contains the physical or biological features necessary to sustain the species’ life
history processes.
Specific habitat features that provide the physical or biological features necessary to sustain the species’
life-history processes are called the Primary Constituent Elements (PCEs) and are essential to the
conservation of the species (FWS 2015). Because these habitat features are considered to be the most
important for sustaining populations, analysis in this document focuses primarily on the effects to habitat
that contain the PCEs for the MCBB, hereafter referred to as “suitable habitat.” For the MCBB these habitat
requirements include:
• PCE 1 – Elevations between 8,200 and 11,500 feet, tree canopy cover less than 50 percent, widely
spaced low forbs and grasses, exposed soil and rock substrates;
• PCE 2 – The presence of one or more species of host plants required by MCBB larvae (see Ecology
of the Species above for a list of host plants) at a density of greater than 2 per square meter;
• PCE 3 – The presence of one or more species of nectar plants required by MCBB adults (see
Ecology of the Species above for a list of nectar plants) at a density of greater than 2 plants per
square meter for small nectar plants and greater than 0.1 plants per square meter for larger nectar
plants (FWS 2015).
Based on these criteria, it is estimated that the Lee Canyon Critical Habitat Unit contains approximately
172 acres of habitat with PCEs (suitable habitat) for the MCBB (Gulley 2018). Of these 172 acres,
approximately 50.1 acres of suitable habitat occurs within the project area which accounts for
approximately 29 percent of the available suitable habitat in the Lee Canyon Critical Habitat Unit. Suitable
habitat located in the project area represents approximately 2.6 percent of the 1,921 acres of suitable habitat
that is estimated to occur within all three critical habitat units (Gulley 2018).
Occurrence in the Project Area

Critical Habitat designated in June of 2015, covers all of the project area with the exception of the mid-
mountain base area and maintenance area (FWS 2015). However, the entire project area does not constitute
suitable habitat. This section discusses the latest known occurrences of individuals of the species in the
project area as well as the latest known presence and condition of suitable habitat in the project area.
In 2017, the Forest Service conducted surveys for individuals within the ski area permit boundary. Surveys
were conducted over 12 days from June 26 through July 24, 2017 and yielded 17 observations in the ski
area permit boundary. In 2018, the ski area was surveyed for a single day (July 5) and seven individuals
were documented. During the 2019 monitoring season, 13 individuals were documented at the ski area
between July 18th and August 21st.
Surveys conducted by Cirrus personnel during the summer of 2016 resulted in a MCBB GIS habitat layer
providing coverage of all potentially disturbed areas at the ski area at a resolution of 25 by 25 meters (Forest
Service 2019a, Appendix A). The intent of this survey was to provide guidance on which areas had potential
for improvement, which areas contained no habitat, which areas needed to be avoided, and to provide an
estimate for the amount of habitat impact that would be necessary for the implementation of this project.
Previous habitat survey efforts at the ski area were dated and provided insufficient coverage for project
planning at the scale required.
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Using the data collected during the summer of 2016 the amount of suitable habitat at the ski area is estimated
as 50.1 acres.
While the method used to generate this estimate of the amount of suitable habitat in the project area was
appropriate to set the baseline for assessment of potential effects of the proposed action and alternatives, a
more precise methodology will be necessary to define and to limit the actual impacts on suitable MCBB
once final design of authorized project elements is complete and construction begins. The details of this
more precise methodology will be spelled out in the biological opinion (BO) issued by the FWS following
consultation with the Forest Service under Section 7 of the ESA. In the meantime, this analysis identifies a
mitigation measure calling for site-specific, preconstruction delineation of suitable habitat, within the
disturbance footprint of each authorized element (section 3.6.5, mitigation measure 2). Other mitigation
measures then specify what can and cannot be done within this precisely delineated suitable habitat. Some
impact will likely be necessary to complete the project, and the BO will identify an allowable amount of
“incidental take” that cannot legally be exceeded.
3.6.2.2 Forest Service Sensitive Species

A biological evaluation (BE) was prepared for this project (Forest Service 2019b). The BE includes copies
of survey reports. This document assessed the presence of Forest Service Intermountain Region sensitive
species in the survey area and analyzed potential impacts on these species from project-related activities.
Potential suitable habitat is present in the survey area for seven sensitive wildlife species. These seven
species are addressed below.
3.6.2.2.1 Spring Mountains Dark Blue Butterfly
The Spring Mountains dark blue butterfly is endemic to the Spring Mountains in Clark and Nye counties,
Nevada. Dark blue butterflies have been observed puddling at stream banks, springs, and seeps in mixed
conifer and pinyon-juniper habitat, and occasionally sagebrush communities, between 1,618 and 2,414
meters (ENTRIX 2008; Hiatt and Boone 2004). The known larval host is buckwheat (Eriogonum
umbellatum), which is also used as a nectar plant while bastard toadflax (Comandra umbellata) is used only
as a nectar plant (Thompson et al. 2014).
The Spring Mountains dark blue butterfly is considered locally common to abundant in some parts of the
SMNRA. It has never been observed at the ski area, but some potential habitat exists in the northwest
portion of the permit area (Thompson et al. 2014).
3.6.2.2.2 Morand’s Checkerspot
This butterfly primarily inhabits meadows and avalanche chutes within alpine, bristlecone pine, mixed
conifer, and pinyon-juniper habitats. Sites at lower elevations appear to be associated with past fires, while
other sites appear to be associated with avalanche chutes. The Morand’s checkerspot has a patchy
distribution and forms discrete colonies around its larval host plants. Nectar plants include western
wallflower (Erysimum asperum), common dandelion (Taraxacum officinale), Lemmon’s hymenoxys
(Hymenoxys lemmonii), Erigeron sp., mountain monardella (Monardella odoratissima), Pakera sp., and
Penstemon sp., among others. Larval host plants include some paintbrush species (Castilleja sp.) and some
penstemon species (Penstemon sp.). (Thompson et al. 2014)
This species is abundant in other areas of the SMNRA but rare in Lee Canyon, with only six adults observed
during surveys in 2010, 2011, and 2012 (Thompson et al. 2014). Habitat in the disturbance area occurs
primarily in the avalanche chute in the Chair 8 pod.
3.6.2.2.3 Spring Mountains Icarioides Blue Butterfly
The Spring Mountains icarioides blue butterfly is found primarily in disturbed open stands and open
meadows within bristlecone pine and mixed conifer, as well as in pinyon-juniper, sagebrush communities,
and wet areas near springs. The larval host plant is silvery lupine (Lupinus argenteus). Known nectar plants
include sulphur-flower buckwheat (Eriogonum umbellatum), Douglas’ dustymaiden (Chaenactis
douglasii), cinquefoil (Potentilla spp.), sweetclover (Melilotus sp.), Erigeron spp., lobeleaf groundsel
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(Senecio douglasii), among others. Important ecological factors include wet sites and standing mud where
adult butterflies obtain moisture, minerals, and nutrients before host plants are in bloom. (Thompson et al.
2014)
This species is most common in Kyle Canyon, but it is predicted to occur anywhere lupine species (Lupinus
spp.) are found (Thompson et al. 2014). In the disturbance area, lupines are found in two isolated locations
in the northern portion of the permit area.
3.6.2.2.4 Pale Townsend’s Big-eared Bat
This species is highly dependent on caves and mines but uses trees and buildings that offer cave-like spaces
in areas where caves and mines are not available. Diet consists primarily of small moths, and foraging
occurs in flight or near vegetation where prey is gleaned from vegetation surfaces. Telemetry studies have
revealed over 95 percent of foraging activity to be concentrated in open forest habitat. (Bradley et al. 2006)
This species was detected during surveys conducted at the snowmaking pond during the summer of 2016
(Forest Service 2019b).
3.6.2.2.5 Spotted Bat
This species is found in a wide variety of habitats from low-elevation desert scrub to high-elevation
coniferous forests. It primarily roosts in crevices in cliffs and may use caves and mines in winter. It forages
in canyons, open, and riparian areas in desert settings, over meadows, forest edges, and open coniferous
woodland in montane settings. (WBWG 2017)
3.6.2.2.6 Northern Goshawk
This species is typically associated with late seral or old-growth forests, characterized by contiguous stands
of large trees and snags with closed canopies and relatively open understory.
The typical home range for a nesting pair is approximately 6,000 acres. Three major components make up
the home range: nest area, post fledging-family area (PFA) and foraging area. The nest area (approximately
30 acres) may include more than one nest that may be used in alternate years. Stick nests are often built in
larger, mature trees on north or northwest-facing slopes, near water and are typically associated with
quaking aspen. Nest areas contain one or more stands of large, old trees with a dense canopy cover. The
PFA (approximately 420 acres) surrounds the nest area. Due to its size, the PFA typically includes a variety
of forest types and conditions. Goshawks may choose foraging areas based on prey availability, habitat
structure, and composition. (Squires and Reynolds 1997)
The disturbance area contains suitable nesting and foraging habitat. Surveys in 2016 determined that no
goshawks were nesting in the disturbance area for the 2016 nesting season (Forest Service 2019b). There
are no previous records of goshawks in the disturbance area, but there have been sightings elsewhere in Lee
Canyon. Anecdotally, no individuals were detected during other survey activities in the disturbance area.
3.6.2.2.7 Peregrine Falcon
This species generally prefers open country for hunting adjacent to cliffs for nesting. It is associated with
mixed conifer, pinyon-juniper, sagebrush, lowland riparian and grassland habitats.
This falcon feeds primarily on medium-sized birds such as jays, flickers, meadowlarks, pigeons, starlings,
shorebirds, waterfowl and other readily available species. Prey species are usually hunted over open habitat
types such as waterways, fields, and wetland areas such as swamps and marshes. Nests typically consist of
shallow depressions on rock ledges or small caves on high cliffs. (White et al. 2002)
There is suitable foraging habitat but no nesting habitat in the disturbance area. Cliffs near the ski area were
surveyed using a spotting scope for whitewash associated with nest ledges but none was detected.
Anecdotally, no individuals were detected during other survey activities in the disturbance area.
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3.6.2.2.8 Flammulated Owl

Flammulated owls typically occur in mixed coniferous forests of pine, spruce and fir at higher elevations,
as well as oak and pinyon pine at lower elevations. They are secondary cavity nesters, nesting in relatively
open stands of large-diameter (> 21-inch diameter) ponderosa pine (Pinus ponderosa), Jeffrey pine (Pinus
jeffreyi), Douglas-fir (Pseudotsuga menziesii), and aspen (Populus tremuloides). (Linkhart and Mccallum
2013)
This species is an insectivorous, cavity nesting, neotropical migrant. Territories are established in early
May and eggs are typically laid in early June. The young fledge in late July and disperse by September.
Threats include loss of habitat, habitat fragmentation, and nest disturbance. (Linkhart and Mccallum 2013)
There is suitable foraging and nesting habitat for this species in the disturbance area. Flammulated owls are
known to occur at the ski area and were detected during surveys in 2015 (Forest Service 2019b).
3.6.2.3 Management Indicator Species

The National Forest Management Act (NFMA; 36CFR 219.9(a)(1) requires the Forest Service to identify
species that are indictors of ecosystem health and the success of resource management. In fulfillment of
that requirement, the HTNF has designated MIS on the SMNRA according to land type association (LTA)
communities and seral stage. Table 3-23 presents the LTA communities in the disturbance area and their
associated MIS. LTAs not present in the disturbance area, and their associated MIS, are not presented in
Table 3-23 or discussed in this document. MIS plants are discussed in section 3.5. Palmer’s chipmunk and
brown-headed cowbird are discussed below. The project area is above the maximum elevation range of the
chuckwalla and this species will not be discussed further.
Table 3-23. Land type association communities in the disturbance area and their associated
management indicator species.
Communities Early Seral Mid Seral Late Seral
Palmer’s chipmunk
Mixed Conifer Rough angelica Aspen
Brown-headed cowbird
Upper Wash Rough angelica Aspen Golden currant
Jaeger’s draba, Lemon hymenoxys (Lemmon’s rubberweed), and Charleston Indian
Bristlecone Pine
paintbrush (Clokey’s paintbrush)
Cliffs Chuckwalla and Jaeger’s ivesia
3.6.2.3.1 Palmer’s Chipmunk

Palmer’s chipmunk is an endemic species that occurs throughout the Spring Mountains from the pinyon-
juniper zone to above the bristlecone pine zone but is most abundant in the limber pine-white fir mixed
conifer zone (Lowrey and Longshore 2010).
The diet of the Palmer’s chipmunk consists mainly of conifer seeds, but it also eats flowers, berries, green
vegetation, and insects (Hiatt and Boone 2003). Palmer’s chipmunk seeks shelter among large rocks, logs,
holes in trees, or cliff crevices at the base of canyons (Hiatt and Boone 2003).
This species is a management indicator for the late-seral stage of mixed conifer. Palmer’s chipmunks are
abundant in the disturbance area and surrounding area.
3.6.2.3.2 Brown-headed Cowbird
The breeding range of this species extends from southeast Alaska, to Newfoundland, and south to central
Mexico, along the entire southern U.S. to Florida. Analysis of breeding bird survey data indicates a
significant population increase (1968-2004) within the region for this species. (Sauer et al. 2008)
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The species is a management indicator for the late-seral stage of mixed conifer and is associated with areas
of disturbances such as roads, campgrounds, facilities, and housing developments (Forest Service 1986a).
As an indicator of disturbance, presence of brown-headed cowbirds and upward population trends for this
species are an indicator of habitat decline. Absence of this species or downward population trends are the
management goal. Its numbers are documented on the SMNRA during annual breeding and winter bird
surveys.
Because the brown-headed cowbird is an indicator species for disturbance and fragmentation in mixed-
conifer areas, populations would be expected to change in response to disturbances that create an edge
effect advantageous to the species’ breeding success. While the SMNRA is highly fragmented in areas,
surveys have indicated that this is a rare species with low numbers within the SMNRA.
Suitable brown-headed cowbird habitat exists in the disturbance area. Anecdotally, no individuals were
detected during other survey activities in the disturbance area.
3.6.2.4 Spring Mountains Conservation Agreement Species of Concern

The 1998 CA is an agreement between Forest Service Region 4, the Nevada Department of Conservation
and Natural Resources, and the Pacific Region of the FWS. The CA identifies species of concern for which
the agencies involved will provide long-term protection. These species are considered rare, believed to be
sensitive to human disturbance, or subject to threat.
Potential habitat is present in the disturbance area for 18 of the 30 wildlife species of conservation concern
listed in the CA (including those that are also Forest Service sensitive, etc.). All but eight, are addressed
above under other categories and not discussed further here. The 12 wildlife species of concern for which
there is no potential suitable habitat in the disturbance area are not addressed further in this analysis.
3.6.2.4.1 Spring Mountains Comma Skipper
The Spring Mountains comma skipper inhabits riparian areas in mixed conifer forests and pinyon-juniper
communities where there is surface water. It is speculated that larval host plants for the Spring Mountains
comma skipper include perennial grasses and sedges (Carex sp.), which are common throughout the Spring
Mountains (Thompson et al. 2014; Weiss et al. 1997).
This species is widespread throughout the SMNRA but at fairly low numbers. Surveys in 2010, 2011, and
2012 documented 10 individuals at Lee Canyon (Thompson et al. 2014). Habitat in the disturbance area
exists in the northwest portion of the permit area.
3.6.2.4.2 Charleston Ant
Charleston ant is believed to be a Spring Mountains endemic, but its total distribution is unknown. One
report exists of six ant colonies in Kyle Canyon at the junction of Echo Canyon and SR 157 (Cole 1956).
It is believed that this species lives in subterranean nests, without cover, or beneath large stones. In 1956,
nests were found in open coniferous forest habitat at 7,700 feet elevation (Cole 1956), but no data exist on
the observation of this species since 1956.
It is not known whether this species currently inhabits the disturbance area, and no surveys have been
conducted within the disturbance area for this species.
3.6.2.4.3 Nevada Admiral
The Nevada admiral occurs in riparian habitats, bristlecone pine forests, mixed conifer forests, and pinyon-
juniper communities. The primary larval host plant is likely quaking aspen, as well as potentially willow
(Salix spp.) and serviceberry (Amelanchier utahensis). Important ecological features include riparian areas
and the presence of host plants. Nectar plants include western white clematis (Clematis ligusticifolia),
thistles (Cirsium sp.), fireweed (Epilobium angustifolium), and horehound (Marrubium vulgare) among
others. (Thompson et al. 2014)
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The Nevada admiral population in the SMNRA appears to be secure because of its distribution throughout
the Spring Mountains (NatureServe 2017). Surveys in 2010, 2011, and 2012 documented 10 individuals at
the ski area (Thompson et al. 2014). Habitat for this species exists throughout the disturbance area.
3.6.2.4.4 Carole’s Silverspot
Carole’s silverspot occurs throughout all vegetation zones in the SMNRA. They occur in bristlecone pine
forests, white fir-Ponderosa pine forests, pinyon-juniper forests, sagebrush, chaparral, and desert habitats.
The larval host plant is Charleston violet (Viola charlestonensis). Nectar plants include Arizona thistle
(Cirsium arizonicum), sanddune wallflower (Erysimum capitatum), spreading dogbane (Apocynum
androsaemifolium), Wood’s rose (Rosa woodsii), rough angelica (Angelica scabrida), dustymaiden
(Chaenactis sp.), lupine (Lupinus sp.), mountain monardella (Mondardella odoratissima), and rubber
rabbitbrush (Ericameria nauseosa). (Thompson et al. 2014)
Investigations have shown that this butterfly is widespread and common on slopes in the central portion of
the Spring Mountains range, between approximately 6,560 and 8,860 feet in elevation. Surveys in 2010,
2011, and 2012 documented 14 individuals at the ski area (Thompson et al. 2014). Habitat for this species
exists throughout the disturbance area.
3.6.2.4.5 Western Small-footed Myotis
This species utilizes a variety of habitats including desert scrub, grasslands, sagebrush steppes, blackbrush,
pinyon-juniper, pine-fir forests, and agriculture and urban areas between 1,683 and 9,108 feet. These bats
can be found hibernating in caves or mines, but little else is known about them. They are known to roost in
caves, mines, and under loose bark in trees. This species prefers to forage in the early evening, feeding on
small insects such as moths and beetles, foraging along cliffs and rocky slopes. (Hiatt and Boone 2004)
3.6.2.4.6 Long-eared Myotis
The long-eared myotis primarily occurs in mixed conifer, pinyon-juniper, and sagebrush habitats at
elevations between 5,400 and 9,600 feet. It is a year-round resident of the SMNRA and day roosts in hollow
trees, caves and mines, and structures. This species forages along rivers and streams, over ponds, and within
cluttered forest environment. (WBWG 2017)
3.6.2.4.7 Long-legged Myotis
This species occurs between 5,400- and 10,150-feet elevation on the Spring Mountains and primarily occurs
in mixed conifer and pinyon-juniper habitats but may occasionally use desert scrub habitats. This species
requires a consistent source of water and is associated with rivers and springs. Important ecological factors
are hollow trees, caves, and mines for roosting and open water for foraging. Roost sites include hollow
trees, large diameter snags, under bark, live trees with lightning scars, rock crevices, mines, and buildings.
Large colonies utilize mines and caves that serve as hibernacula. Maternity roosts are in buildings, under
bridges, in rock crevices, on cliffs, in trees, or in snags. (Ramsey 1997)
3.6.2.4.8 Fringed Myotis
Habitat for this species includes desert scrub, pinyon-juniper, and coniferous forest habitats, usually at
elevations of 3,500 – 7,000 feet. This bat is a year-round resident in the SMNRA that roosts in mines, caves,
trees, and buildings. Fringed myotis prefer to forage on beetles, but they also eat other insects, including
moths. Foraging occurs in and among vegetation. (Bradley et al. 2006)
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This species was not detected during surveys conducted at the snowmaking pond during the summer of
2016 (Forest Service 2019b). However, suitable foraging habitat exists in the disturbance area, and there is
roosting habitat in the area.
3.6.2.5 Clark County Multiple Species Habitat Conservation Plan Covered Species
The 2000 MSHCP is an agreement between the Clark County Department of Comprehensive Planning and
the FWS. The MSHCP identifies 79 species to be covered under an ESA Section 10(a) Permit (allowing
for incidental take) and specifies the actions necessary to maintain the viability of their natural habitat
(Recon 2000).
Potential habitat is present for 13 wildlife species listed in the MSHCP (including overlap with species also
listed as Forest Service sensitive, etc.). All but one, the silver-haired bat, are addressed above under other
categories and not discussed further here. Those MSHCP species for which there is no suitable potential
habitat in the disturbance area are not addressed further in this analysis.
3.6.2.5.1 Silver-haired Bat
These are the most common bats in forested areas, most closely associated with coniferous, mixed
coniferous, and deciduous forest types. They appear to hibernate mainly in forested areas, though they may
be making long migrations from their summer forest to a winter forest site. Typical hibernation roosts
include small hollows beneath exfoliating bark of large trees, in wood piles, and in cliff faces. They feed
on insects, mainly within disturbed areas, sometimes at tree-top level, but often in small clearings and along
roadways or water courses. (WBWG 2017)
3.6.2.6 Migratory Birds

Migratory birds are protected under the Migratory Bird Treaty Act of 1918. Executive Order 13186 details
the responsibilities of federal agencies to protect bald and golden eagles and other migratory birds. In
December 2008, an MOU between the Forest Service and the FWS to promote the conservation of
migratory birds was signed (Forest Service 2008). Pursuant to the Executive Order and the MOU, the Forest
Service ensures that environmental analyses of federal actions required by NEPA evaluate the effects of
actions and agency plans on migratory birds, with emphasis on species of conservation concern.
A list of birds of conservation concern is published and maintained by the FWS, Division of Migratory Bird
Management (FWS 2008). The current list is available at http://www.fws.gov/migratorybirds. The
disturbance area is located within the Sonoran and Mojave Deserts Bird Conservation Region (BCR 33).
The official species list for this project, obtained from the FWS on June 22, 2018, identifies 28 species of
conservation concern that could occur in the vicinity of the ski area (FWS 2018). These species occupy a
wide variety of habitat types and could occur in the disturbance area year-round or during the breeding or
migration seasons.

Under this alternative, no development would take place at the ski area. Therefore, there would be no
impacts on any special-status wildlife species because no action impacting individuals or habitat would take
place.

Under this alternative, disturbance would occur as described in section 2.2 and enumerated in section 3.2.
The direct and indirect impacts of this disturbance on special-status wildlife species are described below.
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Mount Charleston Blue Butterfly

With the design criteria and mitigation measures described in section 2.6 and 3.6.5 in place, the direct
effects of the proposed action should be limited. Most of the construction would take place outside of
suitable habitat, so the potential for impacts on adults, larvae, pupae, or eggs would be small. However,
flushing of adults or trampling of larvae, pupae, or eggs could occur as a result of surveys to mark suitable
habitat or of construction activities within suitable habitat.
As noted above (section 3.6.2.1.1), and detailed in the biological assessment (BA)(Forest Service 2019a),
the method used to identify the 50.1 acres of suitable MCBB habitat in the project area was conservative –
that is, it resulted in a higher acreage than is likely to actually exist. To estimate potential impacts on this
acreage, the footprints of all proposed action elements involving vegetation or soil disturbance, or human
activity, were overlaid on the suitable habitat. Any suitable habitat overlaid by a disturbance footprint was
tallied adversely affected. By that method, 20.1 of the 50.1 acres of suitable habitat at the ski area would be
affected by construction, maintenance, or operation-related disturbance.
Similar to the estimation of suitable habitat, the projection of disturbance is conservative; 20.1 acres is the
most that could be disturbed. Mitigation measures (section 3.6.5) would reduce the actual disturbance
acreage, but it is not possible to quantify the reduction until final design of authorized project elements is
underway, suitable habitat within their potential disturbance footprints is mapped (mitigation measure 2),
and mitigation measures are implemented to avoid or minimize impacts. As an example, a patch of suitable
habitat within an area proposed for clearing is considered to be completely lost by the cutting and skidding
of nearby trees in this analysis. However, in accordance with mitigation measure 3, the patch would be
avoided entirely if that were feasible. Avoidance would not always be practical or even possible. As
discussed in section 3.6.2.1.1, consultation under ESA section 7 will identify an allowable acreage of
incidental take of suitable habitat consistent with recovery of the MCBB. Unavoidable impact on suitable
habitat could not legally exceed that amount.
The main potential effect of maintenance of new infrastructure is flushing of adult MCBB from adjacent
habitat. This is because all maintenance activities associated with the new infrastructure would take place
within the construction disturbance buffer, where all habitat (and larvae, pupae or eggs associated with that
habitat) is assumed to have been lost during construction. As discussed above, this is a conservative
assumption. Habitat will persist outside the construction disturbance buffer, and those areas are where
adults could be flushed by maintenance activities.
In time, MCBB habitat may grow back into areas within the construction disturbance buffer, and habitat
may expand beyond the estimated 20.1 acres of existing habitat in that area. Should that occur, maintenance
of new infrastructure would have direct impacts on adults, larvae, pupae, and eggs due to trampling and
flushing of adults. The degree to which these impacts would occur is not possible to determine at this time
since the extent of potential habitat regeneration and expansion is not known. Future monitoring would be
necessary to quantify impacts of maintenance activities on new habitat.
Operation-related effects are less clear and certain than construction-related effects. This is primarily due
to the uncertainty of predicting human behavior. Another component introducing uncertainty is the potential
increase in habitat resulting from tree cutting and ground disturbance that would occur during construction
(see below).
Winter operations have few direct impacts on the MCBB since all individuals are snow covered most of
the time these activities are ongoing. However, during some years when ski run coverage is thin, patches
of habitat and potentially individual larvae, pupae, or eggs may be exposed. Mitigation measures 13 and 14
in section 3.6.5 require closure of such areas to avoid impacts during the winter.
In the short term, direct effects of on-trail use of the proposed summer recreational infrastructure would be
limited to accidents in which a biker was thrown from, or a hiker fell from, the trail into suitable habitat.
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With the final location of the hiking and biking trails unknown, it is not possible to determine how much
habitat could be impacted in this way. However, using the conceptual trail network, an estimate may be
calculated. For this analysis, it is assumed that such events could occur on the order of 10 incidents per day.
In order to directly impact the MCBB, these accidents would have to occur within the approximately small
percentage of the trail system that would be within 3 meters (3 meter accident impact area) of suitable
habitat, and an adult MCBB would have to be present at the near edge of the suitable habitat patch at the
time of the accident. Approximately 1.4 acres of the estimated 50.1 acres of suitable habitat would be within
3 meters of the trail system. This represents 3 percent of the estimated suitable habitat at the ski area. In
short, this risk would be small. Final layout of the trails may shift, and trails would be located within forested
areas wherever possible as these areas do not currently qualify as suitable habitat and would be much less
likely to contain habitat in the future.
Off-trail use by hikers in MCBB habitat at the ski area would likely be reduced due to the addition of trails.
Currently, most hikers ride up Chair 1 and walk down where they choose, or simply walk around at will,
since there are no trails for them to use. Some hikers use the access roads, but the roads are too loose and
rocky for most users’ preference. The increased educational measures described in the vegetation mitigation
section (3.5.5), in conjunction with the proposed hiking trail, would likely result in fewer direct impacts on
adults, larvae, pupae, and eggs when compared with the existing situation. Bike Patrol would be periodically
checking all trails to ensure bikers and hikers stay on the trail. Bikers and hikers who choose to go off-trail
would be ushered back onto the designated trails and bikers who are repeat offenders would have their lift
privileges revoked due to breach of the agreement they entered into by purchasing a lift ticket for downhill
biking. Hikers who choose to hike off-trail would be ushered back onto the designated hiking trail as a
matter of safety due to the potential for collisions between downhill bikers and hikers if off-trail hiking
were allowed.
Over the long term, if MCBB habitat extended into open areas created by clearing and glading of trees,
incidents of flushing of MCBB adults related to accidents on the trails could be expected to increase. This
scenario is highly speculative, but if such expansion were to occur, additional consultation with the FWS
may be necessary to determine the appropriate course of action.
Adult MCBB could be flushed by the mountain coaster over an area of approximately 1 acre. This could
impact foraging and oviposition activities in that area.
Potentially offsetting the loss of suitable habitat within the construction disturbance buffer is the possible
increase in the amount and connectivity of suitable habitat at the ski area. This could result from the removal
of trees that are currently providing too much shading for sufficient densities of MCBB host and nectar
plants to grow underneath them. The proposed action would glade or remove trees entirely from
approximately 124 acres in five patches. By design, most of this acreage is adjacent to existing suitable
MCBB habitat.
Specific elements of the proposed action could generate habitat expansion in three ways. First would be the
gradual expansion at the perimeter of suitable habitat patches as the plants there propagated into newly
habitable areas. Second would be the increase in host and nectar plant density in areas where shading is
currently a limiting factor for new plant establishment. Third would be propagation by seeds from distant
habitat patches finding their way to newly habitable areas.
Increased connectivity among habitat patches would occur in two ways. First would be removal of tall
vegetation, which serves as a barrier to MCBB movement, by glading and clearing. Second would be
establishment of conditions that could lead to the development of suitable habitat in patches (e.g., gladed
areas) or linear features (e.g., cleared ski runs) in intervening areas between established patches. This would
reduce the barriers for individuals and subpopulations to move and populate existing or newly created
suitable habitat.
Should they occur as predicted, all of these processes would result in increased acreage of suitable habitat
as well as the eventual connection of currently distinct habitat patches. Anecdotal evidence from the recent
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Carpenter 1 fire, as well as observation of previous disturbance at the ski area, supports these anticipated
improvements.
If habitat were to expand, maintenance activities associated with control of erosion or encroaching forest
vegetation would protect the new habitat from being destroyed or shaded out. Some maintenance activities
such as grading of access road and trail surfaces have the potential to impact MCBB habitat that could
encroach on the margins of these features, but these impacts are impossible to quantify at this time.
Climate change could impact this species, as described in section 3.13.7. Any impacts of climate change
on this species would occur long after the project area had recovered from the initial disturbance of
construction and would not exacerbate the short-term impacts of this project.
While the primary impacts of the proposed action are described here, additional details of impacts on the
MCBB may be found in the final BA and biological opinion that will result from the conclusion of Section
7 consultation with the FWS.
While the overall effect of this project is likely to be beneficial to the MCBB, some adverse effects will
occur. Since all effects are not beneficial, and beneficial effects are uncertain, it is our determination that
these actions may affect and are likely to adversely affect the MCBB or its designated critical habitat. In
the absence of any potential beneficial effects, this determination would remain unchanged.
Spring Mountains Dark Blue Butterfly

There are an estimated 63 acres of habitat for this species in the surveyed area, based on host and nectar
plant presence. Approximately 5 acres of this habitat would be impacted by the proposed action. Of these
5 acres, approximately 1 acre of habitat would be impacted long term (e.g., habitat in the footprint of bike
trails, mountain coaster footings, parking, access roads, and structure footprints), the remainder would be
short term disturbance related to construction in areas that would not be subject to long-term ground
disturbance (e.g., ski runs, snowmaking and utility trenches, and construction disturbance buffers around
infrastructure).
This habitat is also in proximity to summer activities that have the potential to disturb adults. In the rare
circumstance of off-trail incidents (e.g., falls/crashes by hikers/bikers), summer activities also have the
potential to trample eggs, larvae, and pupae. It is anticipated that the magnitude of this impact would be
very small due to the propensity of mountain bikers at ski areas to stay on-trail, as well as mitigation in
place to protect MCBB habitat (Forest Service 2017). This is not necessarily because habitat for this species
and the MCBB is collocated, but that mitigation measures to protect the MCBB are intended to create a
culture of appropriate trail use at the ski area that would affect all habitats.
The proposed action could result in an increase in habitat for this species, over the long term. Currently,
suitable habitat exists in areas with low to moderate tree canopy cover. The gladed areas in the Chair 5 pod
are near existing habitat, and host and nectar plants for this species may eventually expand into these areas.
It is my determination that implementation of the proposed action may impact individuals but is not likely
to result in a trend toward federal listing or loss of viability for the Spring Mountains dark blue butterfly
within the planning area. The rationale for this determination is that only a small percentage of the habitat
on the SMNRA would be impacted, the majority of impacts would be short term, and long-term expansion
of habitat may offset some of the detrimental impacts.
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Morand’s Checkerspot
There are an estimated 48.5 acres of habitat for this species in the surveyed area, based on host and nectar
plant presence. Approximately 4.2 acres of this habitat would be impacted by the proposed action. Of these
4.2 acres, approximately 0.8 acres of habitat would be impacted long term (e.g., habitat in the footprint of
bike trails, mountain coaster footings, parking, access roads, and structure footprints), but the remainder
would be short term disturbance related to construction in areas that would not be subject to long-term
ground disturbance (e.g., ski runs, snowmaking and utility trenches, glading, and construction disturbance
buffers around infrastructure).
The proposed action could result in an increase in habitat for this species over the long term. Currently,
suitable habitat exists in open areas as well as areas with low to moderate tree canopy cover. The ski runs
and gladed areas in the Chair 5 and Chair 8 pods, as well as the glading above the snowmaking pond, are
near existing habitat and host and nectar plants for this species may eventually expand into these areas.
to result in a trend toward federal listing or loss of viability for the Morand’s checkerspot within the
planning area. The rationale for this determination is that only a small percentage of the habitat on the
SMNRA would be impacted, the majority of impacts would be short term, and long-term expansion of
habitat may offset some of the detrimental impacts.
Spring Mountains Icarioides Blue Butterfly

plant presence. Approximately 0.1 acres of this habitat would be impacted by the proposed action. The area
impacted would be subject to long term disturbance due to the proposed parking lot. This disturbed patch
of habitat is very low density habitat relative to the undisturbed patch, five lupine plants versus 50 plants.
The remaining patch of habitat would not be subject to any disturbance. The closest element of the proposed
action would be a mountain biking trail 10 meters from the habitat patch.
Habitat expansion as a result of the proposed action would be unlikely for this species since no tree clearing
would occur near the remaining patch of habitat at the ski area.
to result in a trend toward federal listing or loss of viability for the Spring Mountains icarioides blue
butterfly within the planning area. The rationale for this determination is that only a small percentage of the
habitat on the SMNRA would be impacted.
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Pale Townsend’s Big-eared Bat

No cliff or cave roosting habitat for this species would be impacted under this alternative. Approximately
124.1 acres of forested potential foraging habitat for this species would be altered. Of this area, 23.4 acres
would be gladed, resulting in better open-forest foraging habitat. The remaining 100.7 acres would be
cleared. Some edge foraging habitat would be created as a result but the remainder would no longer provide
preferred foraging habitat for this species. However, there is a substantial amount of open-forest type habitat
in the immediate area.
to result in a trend toward federal listing or loss of viability for the pale Townsend’s big-eared bat within
the planning area. The rationale for this determination is that there would be no impact on preferred roosting
habitat and only a small percentage of the foraging habitat on the SMNRA would be impacted.
Spotted Bat
No cliff or cave roosting habitat for this species would be impacted under this alternative. Due to the wide
variety of habitats that this species uses for foraging, the change from forested to open habitats would have
no impact on this species.
It is my determination that implementation of the proposed action will have no impact on the spotted bat.
Northern Goshawk
The alteration of approximately 124.1 acres of forested habitat would result in a reduction of both nesting
and foraging habitat at the ski area. However, forested habitat is extremely common in the immediate area
and no goshawks are known to have nested in the disturbance area.
to result in a trend toward federal listing or loss of viability for the northern goshawk within the planning
area. The rationale for this determination is that only a small percentage of the habitat on the SMNRA
would be impacted and the impacted habitat is not known to be occupied. Furthermore, design criterion 12
would prevent cutting of trees this species could use as nesting habitat, during the nesting season.
Peregrine Falcon
No cliff nesting habitat for this species would be impacted under this alternative. The tree cutting associated
with this alternative, particularly the Chair 5 and Chair 8 pods, would create additional open foraging
habitat. Given the open nature of the forest habitat in the vicinity and the existing open areas (e.g., ski runs,
meadows, campgrounds, and roadways), the additional foraging habitat would not be a substantial
improvement in the amount and quality of foraging habitat in the vicinity.
It is my determination that the implementation of the proposed action may benefit individuals and therefore
is not likely to result in a trend toward federal listing or loss of viability for the northern goshawk within
the planning area. The rationale for this determination is that no nesting habitat would be impacted and
foraging habitat would be slightly improved.
Flammulated Owl
and foraging habitat at the ski area. Based on the results of surveys in 2016, it is likely that there has been
flammulated owl nesting activity in the disturbance area, potentially in the areas of the Chair 5 pod and the
new parking lot. However, forested habitat suitable for nesting is extremely common in the immediate area
and flammulated owls are common in suitable habitat on the SMNRA (eBird 2017).
to result in a trend toward federal listing or loss of viability for the flammulated owl within the planning
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would be impacted. Furthermore, design criterion 12 would prevent cutting of trees this species could use
as nesting habitat, during the nesting season.
Palmer’s Chipmunk
The entire disturbance area for this alternative provides some sort of habitat for this species. The largest
impact on this species would be related to the alteration of approximately 124.1 acres of forest. Palmer’s
chipmunks in the area use these trees as shelter and the seeds they produce for food. Forested habitat is
extremely common in the immediate area.
It is my determination that the proposed action will not alter the existing trend for Forest-level populations
of this species although it will reduce the amount of potential habitat.
Brown-headed Cowbird
The proposed action would result in a substantial increase in the amount of edge habitat due to the increased
juxtaposition of forest and open areas created by new ski runs. The additional edge habitat would expose
more forest-nesting birds to potential brood parasitism by brown-headed cowbirds due to increased
visibility of the nests. However, brown-headed cowbirds are rare at the ski area, and it is unlikely that the
increase of edge habitat would result in a measurable increase in populations of this species in the area.
It is my determination that the proposed action will not alter the existing trend for Forest-level populations
of this species although it will increase the amount of potential habitat.
Spring Mountains Comma Skipper

plant presence. Approximately 42.8 acres of this habitat would be impacted by the proposed action. Of
these 42.8 acres, approximately 6.4 acres of habitat would be impacted long term (e.g., habitat in the
footprint of bike trails, mountain coaster footings, parking, access roads, and structure footprints), but the
remainder would be short term disturbance related to construction in areas that would not be subject to
long-term ground disturbance (e.g., ski runs, snowmaking and utility trenches, glading, and construction
disturbance buffers around infrastructure).
to result in a trend toward federal listing or loss of viability for the Spring Mountains comma skipper within
the planning area. The rationale for this determination is that only a small percentage of the habitat on the
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SMNRA would be impacted, the majority of impacts would be short term, and long-term expansion of
habitat may offset some of the detrimental impacts.
Charleston Ant
Given the unknown distribution of this species, impacts of the proposed action are unclear. Any individuals
or colonies present in the disturbance area could be destroyed by ground disturbing activities such as those
requiring grading or excavation (see Table 3-2).
to result in a trend toward federal listing or loss of viability for the Charleston ant within the planning area.
While the extent of this species and therefore the impacts are unclear, erosion control measures described
in section 3.4.5 will minimize impacts on subterranean habitat for this species.
Nevada Admiral
plant presence. Approximately 30.5 acres of this habitat would be impacted by the proposed action. Of
these 30.5 acres, approximately 5 acres of habitat would be impacted long term (e.g., habitat in the footprint
of bike trails, mountain coaster footings, parking, access roads, and structure footprints), but the remainder
would be short term disturbance related to construction in areas that would not be subject to long-term
ground disturbance (e.g., ski runs, snowmaking and utility trenches, glading, and construction disturbance
buffers around infrastructure).
to result in a trend toward federal listing or loss of viability for the Nevada admiral within the planning
would be impacted, the majority of impacts would be short term, and long-term expansion of habitat may
offset some of the detrimental impacts.
Carole’s Silverspot
There are no host plants (Viola charlestonensis) for this species in the surveyed area, but there are a
substantial number of nectar plants and individuals have been observed in the area. There are an estimated
249 acres of nectaring habitat for this species in the surveyed area. Approximately 66.7 acres of this habitat
would be impacted by the proposed action. Of these 66.7 acres, approximately 8.4 acres of habitat would
be impacted long term (e.g., habitat in the footprint of bike trails, mountain coaster footings, parking, access
roads, and structure footprints), but the remainder would be short term disturbance related to construction
in areas that would not be subject to long-term ground disturbance (e.g., ski runs, snowmaking and utility
trenches, glading, and construction disturbance buffers around infrastructure).
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Nectar plants for this species are found throughout the ski area, with the exception of the Chair 5 pod area.
The proposed action could result in an increase in nectaring habitat for this species in the Chair 5 pod, over
the long term.
to result in a trend toward federal listing or loss of viability for the Carole’s silverspot within the planning
area. The rationale for this determination is that only a small percentage of the nectaring habitat on the
SMNRA would be impacted and long-term expansion of habitat may offset some of the detrimental
impacts.
Western Small-footed Myotis

The alteration of approximately 124.1 acres of forested habitat would result in a reduction of roosting
habitat at the ski area. Foraging habitat would not be impacted. Forested roosting habitat is extremely
common in the immediate area.
to result in a trend toward federal listing or loss of viability for the western small-footed myotis within the
planning area. The rationale for this determination is that only a small percentage of the habitat on the
SMNRA would be impacted.
Long-eared Myotis and Long-legged Myotis

No cliff or cave roosting habitat for these species would be impacted under this alternative. The alteration
of approximately 124.1 acres of forested habitat would result in a reduction of forested roosting habitat at
the ski area. Foraging habitat would not be impacted by the proposed action. Forested roosting habitat is
to result in a trend toward federal listing or loss of viability for the long-eared myotis or the long-legged
myotis within the planning area. The rationale for this determination is that only a small percentage of the
habitat on the SMNRA would be impacted.
Fringed Myotis
No cliff or cave roosting habitat for this species would be impacted under this alternative. The alteration of
approximately 124.1 acres of forested habitat would result in a reduction of forested roosting and foraging
habitat at the ski area. Forested habitat is extremely common in the immediate area.
to result in a trend toward federal listing or loss of viability for the fringed myotis within the planning area.
The rationale for this determination is that only a small percentage of the habitat on the SMNRA would be
impacted.
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Silver-haired Bat
The alteration of approximately 124.1 acres of forested habitat would result in a reduction of both roosting
and foraging habitat at the ski area. However, forested habitat is extremely common in the immediate area.
to result in a trend toward federal listing or loss of viability for the spotted bat within the planning area. The
rationale for this determination is that only a small percentage of the habitat on the SMNRA would be
impacted.
3.6.3.2.6 Migratory Birds
The proposed action has the potential to impact migratory bird nesting in all disturbed areas. With design
criterion 12 (see section 2.6) in place, these impacts would be eliminated. Habitat impacts would occur as
a result of the proposed action, but none of the impacted habitats are rare or limiting in the immediate area
or on the SMNRA. Therefore, with design criterion 12 in place, the proposed action would not adversely
impact migratory bird species.
3.6.3.2.7 Summary
The proposed action would have no impact on spotted bats because no roosting habitat would be impacted
and value of the area as foraging habitat would not be changed.
The proposed action may affect and is likely to adversely affect the MCBB because habitat is present in the
disturbance area and short-term effects are likely to be detrimental.
The proposed action may impact individuals but is not likely to result in a trend toward federal listing or
loss of viability for the following species: Spring Mountains dark blue butterfly, Morand’s checkerspot,
Spring Mountains icarioides blue butterfly, pale Townsend’s big-eared bat, northern goshawk, peregrine
falcon, flammulated owl, Spring Mountains comma skipper, Charleston ant, Nevada admiral, Carole’s
silverspot, western small-footed myotis, long-eared myotis, long-legged myotis, fringed myotis, and silver-
haired bat because habitat is present for these species in the disturbance area but impacts are not substantial
relative to available habitat in the area.
The proposed action would not alter the existing trend for Forest-level populations of Palmer’s chipmunk
or brown-headed cowbird on the Forest because habitat for Palmer’s chipmunks is ubiquitous and brown-
headed cowbirds are rare in the project area.

In order to provide a clear contrast between the proposed action and the BCT alternative, the following
discussion focuses on how the impacts of the BCT alternative would differ from those of the proposed
action, as described above.

Effects of the BCT alternative would be similar to those discussed under the proposed action. However,
under this alternative, the amount of suitable habitat impacted by construction, maintenance, and operations
would be reduced to 18.6 acres and the acreage of trees to be removed would be reduced to approximately
93 acres. See discussion above in section 3.6.3.2.1 explaining why this is the maximum potential impact.
Only 1.5 acres of the 17.4 acres of MCBB habitat disturbance associated with the construction of BCT
alternative is due to summer activities (see Table 4 in Forest Service 2019a).
While the overall effect of this project is likely to be beneficial to the MCBB, some adverse effects will
occur. Since all effects are not beneficial, and beneficial effects are uncertain, it is our determination that
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these actions may affect and are likely to adversely affect the MCBB or its designated critical habitat. In
the absence of any potential beneficial effects, this determination would remain unchanged.
Spring Mountains Dark Blue Butterfly

There are an estimated 63 acres of habitat for this species in the surveyed area, based on host and nectar
plant presence. Approximately 1.8 acres of this habitat would be impacted by the BCT alternative. Of these
bike trails, parking, and access roads), the remainder would be short term disturbance related to construction
in areas that would not be subject to long-term ground disturbance (e.g., ski runs, snowmaking and utility
trenches, and construction disturbance buffers around infrastructure).
The BCT alternative could result in an increase in habitat for this species, over the long term. Currently,
suitable habitat exists in areas with low to moderate tree canopy cover. The gladed areas in the Chair 5 pod
are near existing habitat and host and nectar plants for this species may eventually expand into these areas.
Implementation of the BCT alternative may impact individuals but is not likely to result in a trend toward
federal listing or loss of viability for the Spring Mountains dark blue butterfly within the planning area. The
impacted, the majority of impacts would be short term, and long-term expansion of habitat may offset some
of the detrimental impacts.
Morand’s Checkerspot
plant presence. Approximately 2.3 acres of this habitat would be impacted by the BCT alternative. Of these
bike trails, parking, access roads, and structure footprints), the remainder would be short term disturbance
related to construction in areas that would not be subject to long-term ground disturbance (e.g., ski runs,
snowmaking and utility trenches, glading, and construction disturbance buffers around infrastructure).
circumstance of off-trail incidents (e.g., falls/crashes by hikers/bikers or unsanctioned off-trail
hiking/biking), summer activities also have the potential to trample eggs, larvae, and pupae. It is anticipated
that the magnitude of this impact would be very small due to the propensity of mountain bikers at ski areas
to stay on-trail, as well as mitigation in place to protect MCBB habitat (Forest Service 2017). This is not
necessarily because habitat for this species and the MCBB is collocated, but that mitigation measures to
protect the MCBB are intended to create a culture of appropriate trail use at the ski area that would affect
all habitats.
Alternative A could result in an increase in habitat for this species, over the long term. Currently, suitable
habitat exists in open areas as well as areas with low to moderate tree canopy cover. The ski runs and gladed
areas in the Chair 5 and Chair 8 pods, as well as the glading above the snowmaking pond, are near existing
habitat and host and nectar plants for this species may eventually expand into these areas.
federal listing or loss of viability for the Morand’s checkerspot within the planning area. The rationale for
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this determination is that only a small percentage of the habitat on the SMNRA would be impacted, the
majority of impacts would be short term, and long-term expansion of habitat may offset some of the
detrimental impacts.
Pale Townsend’s Big-eared Bat

No cliff or cave roosting habitat for this species would be impacted under this alternative. Approximately
114.9 acres of forested potential foraging habitat for this species would be altered. Of this area, 28.3 acres
would be gladed, resulting in better open-forest foraging habitat. The remaining 86.6 acres would be
cleared. Some edge foraging habitat would be created as a result but the remainder would no longer provide
preferred foraging habitat for this species. However, there is a substantial amount of open-forest type habitat
in the immediate area.
federal listing or loss of viability for the pale Townsend’s big-eared bat within the planning area. The
rationale for this determination is that there would be no impact on preferred roosting habitat and only a
small percentage of the foraging habitat on the SMNRA would be impacted.
Northern Goshawk
and foraging habitat at the ski area. However, forested habitat is extremely common in the immediate area
and no goshawks are known to have nested in the disturbance area.
federal listing or loss of viability for the northern goshawk within the planning area. The rationale for this
determination is that only a small percentage of the habitat on the SMNRA would be impacted and the
impacted habitat is not known to be occupied. Furthermore, design criterion 12 would prevent cutting of
trees this species could use as nesting habitat, during the nesting season.
Flammulated Owl
and foraging habitat at the ski area. Based on the results of surveys in 2016, it is likely that there has been
flammulated owl nesting activity in the disturbance area, potentially in the areas of the Chair 5 pod and the
new parking lot. However, forested habitat suitable for nesting is extremely common in the immediate area
and flammulated owls are common in suitable habitat on the SMNRA (eBird 2017).
federal listing or loss of viability for the flammulated owl within the planning area. The rationale for this
determination is that only a small percentage of the habitat on the SMNRA would be impacted.
Furthermore, design criterion 12 would prevent cutting of trees this species could use as nesting habitat,
during the nesting season.
Potential impacts to MIS species under the BCT alternative would be similar as described above under the
proposed action. The BCT alternative would reduce the amount of potential tree removal resulting in a
reduced amount of edge habitat when compared to the proposed action.
Spring Mountains Comma Skipper

plant presence. Approximately 40.4 acres of this habitat would be impacted by the BCT alternative. Of
footprint of bike trails, mountain coaster footings, parking, access roads, and structure footprints), the
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federal listing or loss of viability for the Spring Mountains comma skipper within the planning area. The
impacted, the majority of impacts would be short term, and long-term expansion of habitat may offset some
of the detrimental impacts.
Nevada Admiral
plant presence. Approximately 29.5 acres of this habitat would be impacted by the BCT alternative. Of
footprint of bike trails, mountain coaster footings, parking, access roads, and structure footprints), the
federal listing or loss of viability for the Nevada admiral within the planning area. The rationale for this
determination is that only a small percentage of the habitat on the SMNRA would be impacted, the majority
of impacts would be short term, and long-term expansion of habitat may offset some of the detrimental
impacts.
Carole’s Silverspot
There are no host plants (Viola charlestonensis) for this species in the surveyed area, but there are a
substantial number of nectar plants and individuals have been observed in the area. There are an estimated
249 acres of nectaring habitat for this species in the surveyed area. Approximately 63 acres of this habitat
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would be impacted by the BCT alternative. Of these 63 acres, approximately 8.5 acres of habitat would be
impacted long term (e.g., habitat in the footprint of bike trails, mountain coaster footings, parking, access
roads, and structure footprints), the remainder would be short term disturbance related to construction in
areas that would not be subject to long-term ground disturbance (e.g., ski runs, snowmaking and utility
trenches, glading, and construction disturbance buffers around infrastructure).
Nectar plants for this species are found throughout the ski area, with the exception of the Chair 5 pod area.
The BCT alternative could result in an increase in nectaring habitat for this species in the Chair 5 pod, over
the long term.
federal listing or loss of viability for the Carole’s silverspot within the planning area. The rationale for this
determination is that only a small percentage of the nectaring habitat on the SMNRA would be impacted.
Western Small-footed Myotis

The alteration of approximately 114.9 acres of forested habitat would result in a reduction of roosting
habitat at the ski area. Foraging habitat would not be impacted by the BCT alternative. Forested roosting
habitat is extremely common in the immediate area.
federal listing or loss of viability for the western small-footed myotis within the planning area. The rationale
for this determination is that only a small percentage of the habitat on the SMNRA would be impacted.
Long-eared Myotis and Long-legged Myotis

No cliff or cave roosting habitat for these species would be impacted under this alternative. The alteration
of approximately 114.9 acres of forested habitat would result in a reduction of forested roosting habitat at
the ski area. Foraging habitat would not be impacted by the BCT alternative. Forested roosting habitat is
federal listing or loss of viability for the long-eared myotis or the long-legged myotis within the planning
would be impacted.
Fringed Myotis
No cliff or cave roosting habitat for this species would be impacted under this alternative. The alteration of
approximately 114.9 acres of forested habitat would result in a reduction of forested roosting and foraging
habitat at the ski area. Forested habitat is extremely common in the immediate area.
federal listing or loss of viability for the fringed myotis within the planning area. The rationale for this
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Silver-haired Bat
The alteration of approximately 114.9 acres of forested habitat would result in a reduction of both roosting
and foraging habitat at the ski area. However, forested habitat is extremely common in the immediate area.
federal listing or loss of viability for the spotted bat within the planning area. The rationale for this
3.6.3.3.6 Migratory Birds
Similar to the proposed action, the BCT alternative has the potential to impact migratory bird nesting in all
disturbed areas. With design criterion 12 (see section 2.6) in place, these impacts would be eliminated.
Habitat impacts would occur as a result of the BCT alternative, but none of the impacted habitats are rare
or limiting in the immediate area or on the SMNRA. Therefore, with design criterion 12 in place, the BCT
alternative would not adversely impact migratory bird species. Potential impacts to migratory birds along
the Bristlecone Trail from trail removal would be greatly reduced.
3.6.3.3.7 Summary
Similar to the proposed action, the BCT alternative would have no impact on spotted bats because no
roosting habitat would be impacted and value of the area as foraging habitat would not be changed.
Impacts on the Spring Mountains icarioides blue butterfly, peregrine falcon, and Charleston ant would be
identical to those described under the proposed action.
Similar to the proposed action, the BCT may affect and is likely to adversely affect the MCBB because
habitat is present in the disturbance area and short-term effects are likely to be detrimental. However,
impacts under this alternative would be reduced relative to the proposed action.
Implementing the BCT alternative may impact individuals but is not likely to result in a trend toward federal
listing or loss of viability for the following species: Spring Mountains dark blue butterfly, Morand’s
checkerspot, pale Townsend’s big-eared bat, northern goshawk, flammulated owl, Spring Mountains
comma skipper, Nevada admiral, Carole’s silverspot, western small-footed myotis, long-eared myotis,
long-legged myotis, fringed myotis, and silver-haired bat because habitat is present for these species in the
disturbance area but impacts are not substantial relative to available habitat in the area. In each case, impacts
would be reduced under the BCT alternative relative to the proposed action.
Similar to the proposed action, the BCT alternative would not alter the existing trend for Forest-level
populations of Palmer’s chipmunk or brown-headed cowbird on the Forest.

3.6.4.1 Threatened, Endangered, and Candidate Wildlife Species

The analysis completed for the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project
indicates that, while there is no known historical use within the project area, there are 2.6 acres of marginal
MCBB habitat located within the interior of the campground loops that would be impacted by the project.
The lack of historic use, the location of the disturbed habitat within an already highly trafficked area, and
the small acreage make the loss of this habitat unlikely to interact cumulatively with the impacts of the
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proposed action or BCT alternative on the MCBB in any way that would jeopardize the viability of MCBB
populations in the area.
The analysis completed for the Foxtail Group Picnic Area Reconstruction Project indicates that no known
MCBB individuals or habitat exists within the project area yet concludes that the project is likely to
adversely affect the MCBB due to possible habitat expansion in the years following project implementation.
If MCBB populations and habitats were to expand into the Foxtail project area, this would constitute a
substantial expansion for both populations and habitat. Under this scenario, the detrimental impacts of
recreationists at Foxtail on the MCBB would be minimal in the context of the population and habitat gains
that brought the MCBB into conflict with Foxtail recreationists. These minimal impacts would not interact
cumulatively with the impacts of the proposed action or BCT alternative on the MCBB in any way that
would jeopardize the viability of MCBB populations in the area.
The analysis for the Old Mill WUI Hazardous Fuels Treatment project indicates that there will be no direct
effects of the project on the MCBB and that the only indirect effects would be the potential trampling of
nectar plants and the possible expansion of MCBB habitat into newly thinned areas. Due to the reduction
of treated area since the analysis was completed, trampling impacts should be substantially reduced. Since
all treatments are scheduled to be completed before the implementation of the elements of the proposed
action or BCT alternative are authorized, the trampling impacts associated with the Old Mill WUI project
will not overlap in time and space with the impacts of the proposed action or BCT alternative; therefore, no
cumulative effects are expected.
in gladed areas. In areas where these projects do not overlap directly, populations of MCBB would likely
be impacted to some degree by the Lee Canyon Fuels Reduction Project. Design criteria would be in place
to avoid MCBB habitat during the project. Any minimal impacts would not interact cumulatively with the
impacts of the proposed action or BCT alternative on the MCBB in any way that would jeopardize the
viability of MCBB populations in the area.
3.6.4.2 Forest Sensitive, CA, and MSHCP Covered Wildlife Species

The analysis documents for the three past cumulative actions indicate very few long-term impacts on Forest
sensitive, CA, and MSHCP covered wildlife species. Long-term impacts identified are very small acreages
of habitat loss due to cutting of trees or paving of surfaces. Since the determination for the Old Mill WUI
project was made, the treatment area has decreased substantially, reducing impacts of that project on these
species. While the proposed action and BCT alternative do include substantial amounts of tree cutting and
a small amount of paving, the long-term impacts of the cumulative actions do not interact cumulatively
with the impacts of the proposed action and BCT alternative in any way that would alter the determinations
made in this document for each species, due to the small magnitude of the impacts of the cumulative actions.
In other words, no populations of Forest sensitive, CA, or MSHCP covered wildlife species would be moved
in the direction of a trend toward federal listing or loss of population viability as a result of cumulative
effects.
likely be impacted to some degree by the Lee Canyon Fuels Reduction Project. Design criteria would be in
place to avoid substantial impacts on these species during the project. Any minimal impacts would not
likely interact cumulatively with the impacts of the proposed action or BCT alternative in any way that
would move these species in the direction of a trend toward federal listing or loss of population viability.
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3.6.4.3 Wildlife Management Indicator Species

The analysis documents for the three past cumulative actions indicate minimal long-term impacts on
Palmer’s chipmunk due to removal of downed woody debris that provides denning habitat for this species.
The Old Mill WUI project anticipated direct mortality associated with burning of fuel piles. Since the
reducing impacts of that project on this species. None of these projects anticipated an impact on Forest-
wide population trends for either Palmer’s chipmunk or brown-headed cowbird. Impacts of the Lee Canyon
Fuels Reduction Project would likely be similar to those of the past projects. The impacts of these
cumulative actions would not interact with the impacts of the proposed action or BCT alternative in a way
that would impact Forest-wide population trends for these MIS.
3.6.5 MITIGATION
In addition to the design criteria outlined in section 2.6, the determinations above require the following
mitigation measures to be in place. These mitigation measures may be revised in the Record of Decision
based on the outcome of Section 7 consultation with the FWS:
1. In order to ensure that these design criteria and mitigation measures are understood and followed,
assign a qualified biologist (see BA Appendix B for “qualified biologist” definition) to be on site
when construction begins to educate contractor and construction crews, and periodically to ensure
that mitigation measures are being followed throughout project implementation. These mitigation
measures have been compiled into an implementation table for use by managers and biologists to
assure compliance during implementation (BA Appendix C). The project will be monitored as
required by the Humboldt-Toiyabe National Forest Land and Resource Management Plan and
supplemental General Management Plan for the SMNRA, and as outlined in BA Appendix B
(Forest Service 2019a).
2. Establish and mark suitable habitat, as described in BA Appendix B, prior to implementation of
construction activities in an area.
3. Wherever practical, avoid impacting marked suitable MCBB habitat within the construction
disturbance area. If areas of marked habitat must be disturbed, delineate the disturbed habitat and
subtract the acreage from the incidental take allowance described in the determination section of
the BA.
4. Do not stage equipment or materials within suitable MCBB habitat.
5. Do not store or chip slash (i.e., small woody debris) within suitable MCBB habitat.
6. To maximize the potential for colonization of host and larval plants in disturbed areas, spread
chipped slash with a depth of no more than 2 inches above the soil surface at any point
(NalleliCarvajal-Acosta et al. 2015). Do not spread chipped slash in areas of suitable MCBB
habitat.
7. Do not burn slash piles within 5 meters of suitable MCBB habitat.
8. When broadcast burning for slash cleanup, remove slash or other fuels from a 5-meter buffer around
suitable MCBB habitat, if suitable habitat is adjacent to the area to be burned.
9. If possible, use access routes that do not cross suitable habitat. If not possible, see measure 16.
10. Complete final layout of hiking and mountain biking trails after suitable MCBB habitat has been
marked. No mountain biking or hiking trails will be placed within suitable MCBB habitat.
11. Do not deposit excavated material within suitable habitat or directly upslope of suitable habitat
unless controls are put in place to ensure material does not erode into suitable habitat.
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12. Conduct activities around suitable habitat outside the adult MCBB flight period (mid-June through
mid-September) when possible.
13. Maintain snow cover in areas where suitable habitat exists while the ski area is open for skiing. If
insufficient snow cover exists in an area of suitable habitat (i.e., rocks and vegetation are visible),
mark the area as a hazard so skiers will avoid damaging habitat or individual MCBB with their
skis.
14. Maintain snow cover in areas where suitable MCBB habitat exists while the ski area is open for
skiing. If insufficient snow cover exists in an area of suitable habitat, mark the area as a hazard and
ensure that no grooming takes place in areas where the tiller could hit the ground.
15. Do not plow/blow snow from roads or parking lots into areas of suitable habitat.
16. When access across suitable habitat without snow cover is necessary, designate construction
travel routes that minimize the amount of habitat impacted in coordination with the SMNRA
Wildlife Biologist prior to implementation. Install rope lines on the boundaries of travel routes to
constrain ground disturbance. When working in or passing through suitable habitat, minimize
impacts on adults and habitat to the extent possible by:
• Avoiding disturbance on host and nectar plants by stepping in the spaces between plants.
• Minimizing solid and rock disturbance.
• Avoiding unnecessary disturbance to adults.
• Inspecting and clearing equipment and clothing to prevent the introduction of invasive
organisms.
17. All equipment must be fueled and lubricated outside of the suitable habitat area to minimize the
potential for chemical spills and exposure of MCBB to chemicals.
18. Felling of trees in or adjacent to suitable habitat must be done such that trees are felled in the
direction that the impact of the tree on the ground will affect the smallest possible amount of
MCBB suitable habitat.
19. If glading of trees (as described in section 2.2.1.4) would result in habitat removal, do not conduct
glading operations in the areas where habitat removal could occur.
20. Conduct any revegetation according to guidelines and specifications established between the
Forest Service and FWS at the time such revegetation is proposed. Seed mixes must be approved
by the Forest Service and FWS.
Education, signage, and fencing measures (1–4 in section 3.5.5) and erosion control measures (section
3.4.5) would also be necessary to protect special status wildlife, particularly the MCBB.
3.6.6 FOREST PLAN COMPLIANCE

The only wildlife-related standard or guideline that the proposed action and BCT alternative do not comply
with is standard 11.57. This standard allows for limited expansion at Lee Canyon provided that the
expansion, among other things, “does not impact any threatened, endangered, or sensitive species or species
of concern, or its habitat.” As described above in sections 3.6.3.2 and 3.6.3.3, the proposed action and BCT
alternative would impact several species that fall within the categories listed in standard 11.57.
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3.7 CULTURAL RESOURCES

Issue 1 – Historic Properties: The Spring Mountains have a rich pre-history and history, including Native
American use dating back to the Paleoindian era. Construction of the proposed infrastructure would entail
grading and excavation which could inadvertently damage cultural sites.
Indicator: Assessment of the potential for project-related disturbance to affect historic properties through
identification of properties and determination of proximity to ground-disturbing project elements.
Issue 2 – Historic Integrity of the Ski Area: Lee Canyon ski area dates back to 1964. While most of the
facilities were developed more recently, some may date back to over 50 years ago. How would construction
and use of the proposed infrastructure affect historic properties in the permit area that relate to the historic
integrity of the ski area?
Indicators: Assessment of the potential for any project-associated activity to affect the historic integrity of
the ski area through identification of any structures eligible for listing on the National Register of Historic
Places (NRHP) and determination of effects of project disturbance.
Issue 3 – Native American Concerns: The Spring Mountains remain an important feature in the culture of
local and regional Tribal groups. Nuvagantu (literally “where snow sits,” or the Spring Mountains
landscape) is sacred to some and considered to be the site of their creation. Construction-related disturbance,
the resulting permanent, physical changes, and the increased level of year-round human activity may affect
Tribal cultural concerns for the area as a whole.
Indicator: Government-to-government consultation with the Southern Paiute (Nuwuvi) completed in
accordance with the Consultation Handbook, Nuwuvi (Southern Paiute), the Spring Mountains National
Recreation Area and the Desert National Wildlife Refuge Complex (Spoon et al. 2012), defining
consultation as:
Formal consultation is a continuous process involving good faith, two-way diplomatic
communication requiring some level of response with stated or understood goals of results and
timing; with expression of clear action and agreement of boundaries where both agency and tribe
can move forward with a process of redress, with mutual understanding and respect of tribal
sovereignty. (p. 22)

Most of the following historic background information is excerpted from the Historic Resources
Documentation & Analysis: Big Horn Lodge Lee Canyon Ski Resort (Sladek 2017), and Cultural Resource
Narrative Report (Santarone et al. 2017). These documents are incorporated by reference and are included
in the project record.
3.7.2.1 Historic Properties

3.7.2.1.1 Prehistoric Era
The Spring Mountains have a history of human presence dating back thousands of years. The region was
originally inhabited by prehistoric peoples who left behind scattered remnants of their lives, including
pictographs, petroglyphs and stone tools. Southern Paiutes settled in the Las Vegas Valley by around 2,700
before present (BP) and were the primary group residing there when the first Euro-Americans arrived in
the nineteenth century. Small numbers of Paiutes lived in the desert valley during the winters and moved
into the Spring Mountains to escape the summer heat.
For archaeological purposes the Great Basin is generally treated as a single entity or culture area.
Traditionally, the prehistory of the Great Basin has been divided up into four periods, based on changes in
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subsistence strategies and practices, and inferred changes in technology. These periods are discussed briefly
below.
Paleoindian/Paleoarchaic (12,500–8,500 BP)

Based on excavations at Paisley Caves in Oregon, people have been present in the Great Basin for at least
the last 12,500 years. Paleoindian sites in the Great Basin tend to be closely associated with pluvial lakes,
wetlands and related areas. Paleoindian sites in the uplands are extremely rare and very poorly known in
comparison to the lower elevations. Expansive wetlands and relatively low population densities are argued
to have allowed a subsistence strategy focused on movement between and within productive wetland
environments, without the need to incorporate comparatively “expensive” upland resources. Studies of the
movement of volcanic glass across the landscape using geochemical sourcing have been used to posit lithic
conveyance zones, which are argued to reflect past mobility patterns. The results of these studies are argued
to support large territorial ranges.
In terms of subsistence, the Paleoindian peoples of the Great Basin are characterized as having a broad diet-
breadth, relying on small animals and highly ranked plant resources, with a focus on wetland tethered
resources. Grinding stones are known to occur in Paleoindian contexts, suggesting that at least some seed
processing was also being practiced. Isotopic results from the burial of a Paleoindian woman near Buhl,
Idaho indicate a diet that relied on game and the exploitation of fish. This burial also included several
artifacts including a stemmed biface (typologically consistent with a Great Basin Stemmed series projectile
point).
The later Paleoindian period can be characterized as a time of technological and subsistence diversification.
The desiccation of pluvial lakes, at the close of the Pleistocene, led to changes in patterns of subsistence,
and a general widening of the diet-breadth. To actualize the wider diet-breadth, a greater diversity of
ecological niches was exploited. Presumably, the diversification of projectile point forms during this period,
reflect changing cultural or technological parameters.
To summarize, the Paleoindian period in the Great Basin is generally poorly known due a lack of well-
provenanced sites and limited organic preservation, despite being subject to intense research interest and
exploration. The poor existing chronological controls likely obscure changes to culture and technology that
occurred within this time period.
Archaic (8,500–700 BP)

The Archaic is marked by a continued drying trend, leading to the continued reduction and often complete
desiccation of lakes and wetlands. This environmental trend is argued to have led to economic and
technological changes for the peoples of the Great Basin. Changes in subsistence and residence patterns at
the terminal end of the Paleoindian period can be viewed as the transition to a fully Archaic lifeway. The
reduction of wetlands led to the necessity of incorporating upland resources into the economic system. In
terms of subsistence, the already wide diet-breadth is further widened by the introduction of labor intensive,
low-ranked resources like small seeds. This inference is supported by the fact that grinding stones become
a much more common artifact class, and the degree of use shown on the surface of grinding stone increases.
This suggests that intensive plant (particularly small seed) use increases in importance during the Archaic.
Some researchers have proposed the Great Basin Archaic consists of two interfacing adaptive strategies—
a lowland focused strategy counterpoised against, an upland focused strategy. The lowland strategy is a
continuation or evolution of the lacustrine adaptation of the Paleoarchiac. Groups employing the lowland
adaptation used a pattern of low-residential mobility to exploit productive niches along and within lakes
and wetlands. Residential movement was cyclical, but the overall territory was protracted.
The lowland adaptive strategy is contrasted with an upland adaptive strategy, in which the vertical relief
that characterizes the Great Basin was exploited to provide an elevationally keyed, serially available,
resource base. The upland strategy relied on high residential mobility and large catchment areas. Low-land
and upland adaptations are likely to be spatially patterned on a regional scale. Low-land adaptations will be
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more common on the comparatively well-watered periphery of the Great Basin. It is unlikely that the
lowland/upland strategies are dichotomous, more likely these pure strategies represent poles on a
continuous range of behaviors keyed to local conditions.
Presumably, based on the similarity in tool kits, these two lifeways reflect differential subsistence strategies
engaged in by related groups of people. However, the material culture inventory of peoples using the
lowland strategy is less well known, due to the location of the sites and related preservation issues.
Ethnohistorical information suggests that the lowland adaptation may have employed a considerably more
diverse and specialized material cultural assemblage. Given what has been observed ethnographically,
membership between groups practicing these strategies was likely quite fluid.
Late Prehistoric (Post 700BP)

The Late Prehistoric period is marked by material culture attributes which strongly resemble those in place
when first Europeans and Euroamericans arrive in the area. The Late Prehistoric is marked by a return to a
pattern of high residential mobility and broad-spectrum seasonally arranged subsistence, broadly similar to
the Archaic. The exploitation of ecological zones formed by changes in altitude was an important element
of this lifeway. The lowland adaptive strategy discussed in the Archaic section was also still viable in some
areas. Large, semi-sedentary populations remained in some particularly favorable areas.
In this period, Numic speaking peoples are thought to have moved into the area, either replacing, displacing,
or absorbing the existing population. These Numic speaking peoples are the groups in residence at the time
of Euroamerican contact.
Ethnohistoric and Ethnographic Overview

The project area lies within the traditional territory of the Southern Paiute. European/Euroamerican
interactions and documentation of the Southern Paiute began in the late eighteenth century. Two Spanish
expeditions (Father Francisco Garces explorations and the Dominguez-Escalante expedition) in 1776
documented interactions with natives who were most likely Southern Paiute. These explorations traveled
primarily through what are now the Four Corners states of Colorado, Utah and Arizona. The Spanish
encountered people in small extended family groups, practicing a combination of horticulture and hunting
and gathering.
Sporadic contact with Southern Paiute people continued through the 1840s, with Spanish expeditions giving
way to expeditions mounted by citizens of the United States. The springs at Las Vegas were mapped and
became a stopping point along the Old Spanish Trail, running between Santa Fe and Los Angeles. The
impacts of the merchant caravans along the Old Spanish Trail, through the Las Vegas area from 1831-1848
on the Southern Paiute are poorly documented. However, they probably resulted in frequent contact
between native and non-native peoples. In 1855 Mormon settlers established a fort near Las Vegas. As
Euroamerican encroachment in the area increased, tensions between groups mounted, and hostilities
became more common place.
By the 1850s-1860s the material culture of the Southern Paiute shows a prevalence for Euroamerican
manufactured goods, as traditional lifeways were undergoing considerable change. By the 1870s, most
Southern Paiute were located on reservations, or tied to Euroamerican settlements. By the first decade of
the twentieth century the traditional life of the Southern Paiute had been largely abandoned.
From an ethnographic perspective, the Southern Paiute closely resemble surrounding groups in terms of
language, sociopolitical structure, and subsistence. Linguistically, the Southern Paiute are a Numic
speaking people of the Shoshonean branch of the Uto-Aztecan language family. The Southern Paiute
maintained good relations with the neighboring Shoshoni groups, engaging in cooperative support in the
event of crop failures or food shortages.
Southern Paiute subsistence consisted of mixed horticulture and hunting and gathering, depending on the
area. Horticulture was not sufficient for subsistence without the addition of hunted and gathered foods.
Cultigens included maize, squash, beans and sunflower. Potatoes were added in the nineteenth century.
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Important gathered resources included: grass seeds, yucca, agave, prickly pear fruit, and pinyon nuts. The
Spring Mountains were a particularly important area for the gathering of pinyon nuts. Pinyon tracts were
owned by men and were inherited father to son. Women gathered pinecones from their husband’s tracts.
Pinecones were gathered from trees using long wooden hooks and placed in baskets. Piles of cones were
burned to extract the nuts. Extracted nuts were transported to the winter village location. Unprocessed cones
were stored in the mountains in pits.
Large and small game were taken as part of Southern Paiute subsistence, although the scarcity of game
limited the role of hunted foods. Important hunted foods included: rabbits, pronghorn, mountain sheep, and
deer. Some researchers report that cooperative rabbit drives; such as those practiced by the Shoshoni were
not practiced by the Southern Paiute. However, historical references to rabbit nets as part of Southern Paiute
material culture call this assertion into question.
The Spring Mountains were an important deer hunting location. Deer were hunted by individuals or small
groups without formal leadership. Animals taken were butchered and dried in the mountains. The preserved
meat and skins were transported back to the village location. Hunting territories were not owned.
3.7.2.1.2 Historic Era
Trade, Exploration, and Surveying (1830 –1890s)

In the late 1820s and 1830s, American and Mexican traders established and utilized a northern branch of
the Old Spanish Trail that traversed the Las Vegas Valley. Throughout the middle decades of the nineteenth
century, this served as a preferred route between New Mexico and California. The primary feature that
attracted travelers to the area, as it had for generations of Southern Paiutes, was the Las Vegas Springs.
This oasis in the desert provided drinking water and grassy meadows (Las Vegas translates from Spanish
as “the Meadows”) for their horses and livestock.
American explorer Captain John C. Fremont arrived at the Las Vegas Springs in May 1844 leading a team
of surveyors from the U.S. Army Topographical Corps. They mapped the region for the first time, and
Fremont is credited with naming Mount Charleston in the Spring Mountains after his hometown of
Charleston, South Carolina. With cessation of the MexicanAmerican War in 1848, Nevada became part of
the United States. Congress established the Nevada Territory in 1861 and 3 years later the State of Nevada
was admitted to the Union. In 1867, southern Nevada and the Springs Mountains were added to the state
when Congress carved the area from the Arizona Territory.
Detailed surveying and mapping still needed to be completed to divide the land into legal parcels that could
be bought and sold. This was also important for the United States and State of Nevada to understand the
character of the landscape and its resources, and to arrange for the transfer or retention and management of
public lands. The Spring Mountains, including the 36-squaremile area within Township 19 South-Range
56 East that contains Charleston Peak and the upper reaches of Lee Canyon, were first surveyed in the
summer of 1881 by contractor Theodore Binge.
On the plat map he submitted to the Surveyor General’s office in Virginia City, Binge noted that the area
was characterized by “Mountains broken by high Ridges and Spurs” and contained “Pine, Fir and
Mahogany Timber.” Also marked on the map were a number of drainages along with “Clark’s Steam Saw
Mill,” situated in the north half of Section 6 over 3 miles west of Lee Canyon. The sawmill and an associated
cabin were the only developed features Binge encountered in the entire township. Through the end of the
century, most of the land in and around Lee Canyon continued to be owned by the federal government,
although it was beginning to attract the attention of private parties interested in the area’s natural resources.
Logging in the Spring Mountains (1890s–19010s)

Limited logging had already begun in the Spring Mountains by the early 1880s, when the region was first
mapped, and appears to have continued at a low level through the 1890s. During the first decade of the
twentieth century, logging increased due to regional developments that spurred an increase in the demand
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for milled lumber. Surrounded by extensive desert lands devoid of trees, the Spring Mountains were one of
the few sources of lumber in southern Nevada.
In 1905, the San Pedro, Los Angeles & Salt Lake Railroad was completed through the desert and into Las
Vegas, which at the time was the site of a ranch. Because of its location and the presence of water, the site
became a division point along the rail route, where repair shops and workers’ houses were soon built. This
marked the birth of the town of Las Vegas. During the first several years of the century, gold was discovered
at Tonopah and Goldfield, launching a mining boom in the southern area of the state. In 190607, the Las
Vegas & Tonopah Railroad was constructed from Las Vegas toward the northwest, passing through Indian
Springs along the broad valley north of the Spring Mountains. Although not completed to Tonopah, the
route connected Las Vegas to the mines and growing communities of Beatty, Rhyolite and Goldfield.
With these developments, the region’s railroads, mines and mining camps were suddenly in dire need of
milled lumber. Logging increased throughout the Spring Mountains to meet the demand, and sawmills
emerged in several locations, including Kyle and Lee Canyons. From the forests that carpeted the upper
reaches of these canyons, lumber was hauled to the Las Vegas & Tonopah Railroad line below and likely
provided the ties used in its construction. Once the route was in operation, the lumber was loaded onto rail
cars and transported to Las Vegas and the mining camps to the northwest. Many of the earliest buildings
still standing in Las Vegas and Goldfield are likely to contain wood harvested from the Spring Mountains
and perhaps even Lee Canyon.
To accommodate logging activities, a dirt road was extended up Lee Canyon during the first few years of
the twentieth century that followed the same basic alignment as present-day State Route 156. This was
designated on maps from 1908 and 1914 as the “Lee Canyon Steam Traction Road,” indicating that it was
used by steam-powered tractors carrying heavy loads of lumber out of the mountains. By 1906, a sawmill
had appeared along the road in Section 2, in the forest just over 1-mile northeast of the current ski resort
base area. Heavy logging came to an end in the Spring Mountains and Lee Canyon during the mid-1910s
due to federal intervention, closure of a nearby rail line, and the fact that milled lumber shipped by rail
became available from Los Angeles.
Recreation in the Spring Mountains (1900s–1950s)

In addition to the remarkable growth of Las Vegas during the twentieth century, the development of
recreation in the Spring Mountains was aided by the corresponding increase in automobile ownership and
personal mobility. The automobile made it convenient for Americans to travel and visit the nation’s forests
and parks, where they could engage in recreational activities. This was especially the case with sites located
within a short drive of urban areas. As Las Vegas grew during the twentieth century and tourism increased,
the Spring Mountains west of town became an attraction for recreationists and those interested in the
development of recreational opportunities.
During the first two decades of the twentieth century, the Lee Canyon Road’s southern terminus was south
of the sawmill at a location identified on maps as “McWilliams.” This geographic spot, which appears to
have been close to or just north of today’s Clark County Youth Camp, held two small buildings. The name
McWilliams has long been associated with both Lee Canyon and the birth and early development of the
City of Las Vegas.
In April 1929, just a few months after the State of California announced that it would be improving the Los
Angeles Highway, the Automobile Club of Southern California published an article in its monthly Touring
Topics magazine titled “A Yosemite in the Sagebrush.” Focusing upon the Spring Mountains, the author
regaled readers with information about the range’s rugged topography, isolated beauty, and animal and
plant life. He also wrote of its forests and early history of logging and sawmills. Motorists from Southern
California were encouraged to drive through the desert and visit the Spring Mountains, accessing its heights
for hiking and camping by way of the logging roads that had been cut into Kyle and Lee canyons.
Through the 1930s, winter sports in the Spring Mountains continued to be concentrated in Kyle Canyon.
However, in 1939, Forest Supervisor Alonzo Briggs speculated that “Winter sports are developing rapidly
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and Lee Canyon rather than Kyle Canyon will be the center of these sports activities.” Exactly what led
him to make this comment is unknown. While cross-country skiing seems likely to have taken place in Lee
Canyon through the 1940s and into the 1950s, any development of downhill skiing was delayed for a
number of years.
The Forest Service produced a pamphlet in 1946 titled Charleston Mountain: A Division of the Nevada
National Forest, Nevada. This document hailed the range’s year-round recreational opportunities, including
not only the campsites and resort in Kyle Canyon but also the Youth Camp and nearby McWilliams
campground in Lee Canyon. By that time, a Forest Service guard station had been installed in Lee Canyon,
along with a telephone line that connected the Youth Camp to Kyle Canyon and Las Vegas. In terms of
winter activities, the pamphlet stated that “Practice slopes, ski runs, and jumping hills are now developed
in Kyle and Lee Canyons. Roads are kept open winter-long. The children’s camp in Lee Canyon is always
open as a refuge for travelers who come to explore the almost endless winter trails.” No mention of lifts or
facilities that would have served downhill skiers appears in any of the period’s literature.
In 1952, the Las Vegas Review-Journal reported that the Clark County recreation board was considering
the possibility of establishing a largescale winter sports facility in Lee Canyon. However, this plan was
not followed through to completion. The Lee Canyon Recreation Area was established in 1956 through a
Forest Service public land order, and since then it has been managed and developed in accordance with
agency rules, guidelines and restrictions.
3.7.2.2 Historic Integrity of the Ski Area

The Lee Canyon Ski Resort opened in January 1965 with a 3,000-footlong Tbar lift that cost about
$150,000 and transported skiers to the top of the single run. The area proved immensely popular and drew
hundreds of visitors each week. In the summer and fall of 1965, the facility was expanded with a 700-foot
rope tow along with a beginner’s slope and both intermediate and expert runs. Ken and Margaret Highfield
operated the resort, and Bill and Jan Bonazelli provided ski lessons for those wishing to sign up. A ski
patrol unit offered assistance to visitors who ran into trouble on the mountain.
During the same period, the Highfields also oversaw construction of the twostory Big Horn Lodge. The
new building, which served as the resort’s base facility, housed a cafeteria, ski shop, and equipment rental
shop. It also offered skiers a place to warm up between runs, with a second floor deck that looked south
over the lift and ski mountain. On 18 December 1965, the lodge’s completion was celebrated with a grand
opening party attended by at least 75 guests, including Nevada’s lieutenant governor, Paul Laxalt.
Just over 2 weeks later, in early January 1966, the Las Vegas Sun ran a large article on the Lee Canyon ski
area in its Sunday Scene magazine:
A new era in winter sports life for Southern Nevada residents is now underway with the
recent opening of the Big Horn Lodge in Lee Canyon. For those who would prefer simply
to take it easy on a visit to Lee Canyon, the new lodge affords ample comfort, food and
sunshine for the sun-porch skiers. Plans for the lodge include a lounge, expected to be
opened soon, and ultimately some overnight accommodations. Proprietors Ken and
Margaret Highfield recently opened a ski shop in the lodge where a complete line of
domestic and imported skiwear and equipment is available.
With the building completed and opened for use, the lodge became the center of the ski resort.
A full-page photo spread on the Lee Canyon ski area appeared in the January 19, 1968, edition of the Las
Vegas Review-Journal. One photograph shows the lodge’s upper floor deck filled with skiers, with the
following caption: “Half the fun of skiing is getting together with friends at the Mount Charleston Lodge
[Big Horn Lodge] after a day of runs and regaling each other with stories of those spills, nearmisses, and
perfectly executed schusses.” The No. 1 double chair lift opened that same month, transporting skiers a
distance of 3,000 feet up the mountain. This was in addition to the 1965 T-bar lift that was still operating.
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As the Lee Canyon Ski Resort became established, the space provided by the Big Horn Lodge soon proved
inadequate. In 1970, the Highfields had a larger two-story lodge constructed on the adjacent ground to the
west. Known as the Main Lodge, the new building was designed to hold a cocktail lounge, coffee shop,
restrooms, ski school and a ski shop. It also offered a much larger patio than the deck on the Big Horn
Lodge. The original building continued to be used by the rental shop and administrative offices.
In 1983, Ken and Margaret Highfield turned management of the Lee Canyon Ski Resort over to their son
Russell. By that time, the Big Horn Lodge had been remodeled, with changes made to its exterior
architecture. During the early 1980s, the double chair No. 2 and No. 3 lifts were installed to replace the
original T-bar and rope tow. From that point on, the three lifts were capable of transporting hundreds of
skiers up the mountain each hour. Most of the 13 runs were named for gambling terms, including Blackjack,
Keno, High Card, Low Card, Kings, Queens, Jacks, Slot Alley, and The Strip. Snowboarding was first
allowed at the resort in the late 1980s. By the end of the decade, the small resort was handling about 60,000
skiers each season.
Night skiing was launched at Lee Canyon in the early 1990s. Lee Canyon was acquired in 2003 by the
Powdr Corporation of Park City, Utah, together with the Thomas & Mack Company. Improvements were
launched that included a Magic Carpet surface lift for beginners and the tubing run, an expanded terrain
park, and the purchase of new snowmaking equipment. The chairlifts were also replaced during the first
two decades of the twenty-first century as the No. 1 became the triple Sherwood Lift and the No. 2 became
the quad Bluebird Lift. The quad Rabbit Peak lift was also built to serve the beginner’s slope by the same
name.
In 2008, the resort’s owners presented an expansion plan to the Forest Service that called for additional
lifts, a new lodge to replace the two existing ones, a groomed tubing area, and increasing the number of
runs to 51. The 10-year project was expected to involve an expenditure of tens of millions of dollars.
Although the work was not completed, improvements continue to be made there to the present day, and
more are planned for the coming years. The 1965 Big Horn Lodge continues to stand on the site, housing
the rental shop and administrative offices.
3.7.2.3 Native American Concerns

As discussed above (section 3.7.2.1), the Spring Mountains have long been culturally important to the
Southern Paiute, and they remain so today. The Southern Paiute Nation is comprised of seven bands,
including Paiute, Chemehuevi, and Colorado tribes, collectively known as the Nuwuvi. In their own value
system, the Nuwuvi describe their history differently than the account provided above. They especially
disagree that they are descendants of Numic speaking people who migrated to the area during the Late
Prehistoric period. This theory contradicts their belief in their creation story and their understanding of who
they are. The background information provided below is adapted from the Collaborative Resource
Stewardship Plan (Spoon et al. 2013) and Nuwu Kanee, Nuwu Tooveenup (Our Home, Our Story): Nuwuvi
(Southern Paiute) and the Spring Mountains (Spoon et al. 2011).
The Nuwuvi history explains that they have been in the southern Great Basin and northern Mojave Desert
since the beginning of the world. They believe that this land is a living being, and that the Nuwuvi have the
responsibility of caring for it. This history, and the Nuwuvi’s connection to the area, are encapsulated in
the welcome statement they prepared for visitors to the Spring Mountains:
Welcome to our sacred land, Nuvagantu. It is a place that is alive and has power. The land
has feelings to greet you, eyes to see you, and ears to hear you. It talks from every place in
your sight. All of the plants, animals, rocks, water, snow, and air in this landscape are living
and need to be in balance to remain healthy. To sustain this balance, we treat all beings
with the utmost respect, as we have since the beginning of time. We are inseparable from
these mountains, which are powerful, yet delicate. Our language and songs resonate
through the springs, trees, rocks, and animals. We harvest resources here and renew our
cultural and familial ties.
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Nuwuvi (Southern Paiute/Chemehuevi) continue to care for this land as we have for
thousands of years, long before it became a National Recreation Area. We along with the
U.S. Forest Service actively strive to keep the land in balance in culturally appropriate
ways. Although you may not see us, you will surely hear our voices and feel our presence.
Take a moment to get acquainted with this special place and allow it to know you. Use
your senses and open your heart. This is a landscape where your spirit can be replenished
and you can learn valuable lessons. Please walk softly on these grounds as we do and it
will continue to thrive for generations. (Spoon et al. 2011)
The Spring Mountains are the annual gathering place for the Nuwuvi. The first Gathering for Our Mountains
event was in 2012. This is a 3-day annual event meant to allow the Nuwuvi to reunite with the creation
landscape, harvest pine nuts, and perform cultural demonstrations. This gathering serves as an opportunity
transmit knowledge from one generation to another and to all parties involved in the current setting of the
Spring Mountains.
Many of the traditional Nuwuvi songs describe details about the landscape and locations within the Spring
Mountains. Songscapes are transmitted orally from generation to generation and serve as a cultural history,
and a way to bring the land into balance. Nuwuvi believe this balance is essential to maintain and heal the
mountains. Nuwuvi believe their ecological knowledge can aid in maintaining this balance through respect
and interaction. Blessing of the land is a way to respectfully prepare the mountains prior to disturbance and
to maintain their health.
Since the Charleston Forest Reserve was established in 1906 followed by the SMNRA in 1993, Nuwuvi
input has been limited. Lack of active involvement accounts for land management practices that have not
taken into consideration the ecological knowledge of the Nuwuvi people.
Since the opening of the ski area in 1964, it has operated largely without the involvement of the Nuwuvi.
On April 27, 2017, the SMNRA Area Manager met with the Nuwuvi Working Group (NWG), that is made
up of representatives from the Southern Paiute bands whose ancestral home is the Spring Mountains. Since
that date, this working group has been designated to represent the seven bands and to provide input on
projects and issues related to the SMNRA. Accordingly, the NWG has been active in this NEPA process
(see Chapter 4, Consultation and Coordination).
In addition to this Nuwuvi involvement, the Coalition of Colorado River Indian Tribes responded to the
public scoping notice in March 2017 and requested that cultural resources be avoided if feasible, and that
they be contacted in the event that any human remains or cultural resources are discovered during
construction. As documented below in section 3.7.3, avoidance of cultural resources was incorporated into
project planning. Design criteria intended to protect undiscovered cultural resources have been included in
section 2.6. Also see sections 5.3.2 and 5.3.3.

3.7.3.1.1 Historic Properties
In October 2016, in compliance with section 106 of the NHPA, archaeologists working under the direction
of the HTNF completed a file search at the State Historic Preservation Office (SHPO) and a pedestrian
survey to identify any historical properties in the area affected by the proposed projects. As a result of these
efforts, one previously identified prehistoric site was relocated, re-recorded, and determined to be eligible
for listing on the NRHP. Due to the sensitive nature of the site, it will not be described further in this
document.
The survey also identified two sites comprising the remains of structures. One was not recorded because it
showed no evidence of being more the 45 years old. The other was not recorded because it was outside the
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project area. Neither site was evaluated.for listing on the NRHP, and neither is discussed further in this
analysis.
The NRHP-eligible prehistoric site is not in an area impacted by current ski area operations or activities but
is being impacted by dispersed recreation use in upper Lee Canyon.
3.7.3.1.2 Historic Integrity of the Ski Area
The file search noted above also identified one building, the Bighorn Lodge, that merited investigation of
its eligibility for listing on the NRHP. As discussed above under affected environment, this lodge was built
in 1965, making it more than 50 years old. As documented in the assessment report (Historic Resources
Documentation & Analysis: Big Horn Lodge Lee Canyon Ski Resort; Sladek 2017) the building has
undergone several remodels and renovations and currently serves as the ski area’s administrative offices
and rental shop. The assessment report concludes that the building no longer conveys its original
architectural style, age, or historical significance to modern day visitors. It recommended that the lodge did
not warrant listing on the NRHP. The SHPO (2019) concurrence letter confirmed this determination.
No other existing structures date back beyond the 50-year threshold. As a result, no historic properties from
the ski area’s early years exist, and there is no historic integrity to be affected.
3.7.3.1.3 Native American Concerns
Tribal involvement in ski area operations would remain negligible. Physical and less tangible impacts of
ski area operations on Nuwuvi culture and cultural values would continue due to lack of awareness of these
people and their relationship with the Spring Mountains.

Following the re-recording of the NRHP-eligible site, elements of the proposed action were relocated to
avoid any direct impact on the site. However, additional dispersed use of upper Lee Canyon, spurred by
new summer activities at the ski area, has some potential to increase activity at the NRHP-eligible site,
resulting in indirect effects such as trampling and collection of artifacts. However, dispersed recreation is
not expected to increase substantially, and mitigation is proposed to protect the site from damage due to
dispersed recreation (section 3.7.5). Mitigation centers on interpretive information, barriers, and signage to
protect the endemic plants that share the site without divulging the site’s location.
The Cultural Resources Narrative Report concludes that this alternative would have no adverse effect on
the NRHP-eligible site after mitigation measures recommended in the report were implemented (Santarone
et al. 2017).
In accordance with the section 106 process, a report documenting these efforts and findings was prepared
and submitted to the HTNF (Cultural Resources Narrative Report; Santarone et al. 2017), where it was
reviewed by the SMNRA Archaeologist. The report was then submitted to the SHPO for review and
concurrence. The SHPO concurred with the finding of no adverse effect in a letter dated October 14, 2019
(SHPO 2019).
As discussed above (section 3.7.3.1.2), the Bighorn Lodge building has been recommended as not
warranting listing on the NRHP. The SHPO (2019) concurrence letter confirmed this determination. As this
was the only structure warranting assessment for the NRHP, no historic properties or other evidence of the
ski area’s early days could be affected by the proposed action. No impact on the ski area’s historic integrity
is possible.
As stated in section 3.7.2.3, Nuwuvi believe that the Spring Mountains are alive and that they are all
connected to the mountains. The primary concern raised by the Nuwuvi is that the rest of society does not
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recognize this relationship–the importance of mountains to the Nuwuvi and of the Nuwuvi to the mountains.
This lack of awareness underlies most of the potential cultural impacts associated with the proposed action.
To increase cultural awareness and help identify the full range of potential effects associated with ski area
operation currently and in the future, the NWG will work with Nuwuvi knowledge holders to prepare a
cultural assessment of the ski area and its surroundings. This assessment will provide a comprehensive
baseline description of cultural values in the area, which will increase cultural awareness on all fronts and
provide a basis for identifying and avoiding potential cultural impacts in the future. For now, a number of
specific effects were raised in regard to the current proposed action.
The first effect of the lack of cultural awareness is the behavior of ski area visitors as they interact with the
land. Careless movement that damages plants and disturbs wildlife, loud talking and other noise that disturb
the serenity of the place, litter that defaces nature, and an overall lack of recognition and respect for a sacred
place all damage Nuwuvi culture. Under the proposed action, visitor numbers would grow, increasing the
potential for this cultural damage. Skier numbers are projected to increase from 1,880 to 2,850 on peak
days (section 3.11.3.2). Summer use is projected to increase from virtually nothing to up to 2,450 visitors
per day (section 3.9.3.2).
Increasing visitors’ awareness of the Nuwuvi and their perception of the land would be necessary to mitigate
the potential for this type of cultural damage. This could be achieved through interpretive programs of
various kinds including, as a starting point, interpretive signs, panels, and printed materials introducing the
Nuwuvi, explaining what the Spring Mountains mean to them, what they take and what they give to the
mountains, and how visitors should behave in order to respect this place and the Nuwuvi’s relationship to
it. At some point, cultural demonstrations might be developed to add depth and detail to visitors’
understanding. Mitigation would be complete when visitors came to share the Nuwuvi’s relationship with
the Spring Mountains.
A second important effect is the damage to the earth resulting from construction of the proposed
infrastructure. The proposed action would have a total land disturbance of 103.5 acres through grading and
excavation (Table 3-2; for a full analysis of soil disturbance see section 3.4). The Nuwuvi view such
disturbance as an injury to the land, resulting in an imbalance with nature. This imbalance should be avoided
or regained through land preparation as noted above, known as a blessing on the land. These blessings
respectfully prepare the land before ground disturbance takes place and maintain its health.
Tree removal is another concern, as trees and forests provide specific materials important to Nuwuvi culture
as well as being an important component of the landscape. As discussed above, that landscape is the subject
of traditional songs used by the Nuwuvi to preserve their culture. The proposed action includes glading
(selective tree removal to open up the forest) of 23.4 acres and clearing of 91.6 acres. Section 3.8.3.2
addresses the scenic effects of the proposed action in detail.
The Nuwuvi feel that their traditional ecological knowledge would be useful in completing glading and
clearing in the least impactful way. Employing a Nuwuvi environmental inspector to check glading and
clearing operations would serve this purpose. Also, making any trees removed available to the Nuwuvi
would help meet their religious, ceremonial, or community needs.
Another impact of concern to the Nuwuvi is noise, especially in the currently less developed area traversed
by the Bristlecone Trail (BCT). It is another introduced feature with the potential to break the natural
serenity and unbalance the relationship with the land. As noted above, increased visitation is anticipated to
be one source of noise. The other is operation of summer recreational infrastructure, particularly the
mountain coaster and the zip line. As these features would be sited in close proximity to the BCT, they
would be most impactful. Section 3.9.5.2.1 addresses noise impacts of the proposed action in the context
of effects on recreational use of the BCT.
The ski area could take steps to involve the Nuwuvi more in overall operations. The annual Gathering for
Our Mountains is an important event for the Nuwuvi, and the ski area could provide additional financial
support as well as hosting activities at the ski area and providing shuttles as appropriate. To help integrate
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Nuwuvi and their values into ongoing operations, providing mutual benefits, the ski area could notify tribal
contacts of any job openings throughout the year.

The impacts of this alternative with regard to historic properties would be the same as those described under
the proposed action.
The impacts of this alternative with regard to the ski area’s historic integrity would be the same as those
described under the proposed action.
The impacts of this alternative with regard to cultural concerns would be similar to those of the proposed
action with three exceptions. In regard to the impacts associated with soil disturbance, the BCT alternative
would entail 14.3 acres less grading and 0.4 acre more excavation. In terms of tree removal, this alternative
would increase glading by about 5.5 acres and reduce clearing by 14.7 acres. These differences would not
generate notable differences from the effects described for the proposed action.
Of more importance, the BCT alternative would reduce all forms of disturbance in the area crossed by the
BCT through the changes described in section 2.4.2. The mountain coaster and zip line would be shifted
across to the far eastern portion of the ski area, and the pod 8 ski runs and access road would shifted up the
slope, away from the trail. This would substantially reduce impacts of visitor numbers, ground disturbance,
tree removal, visual impact, and noise on this sensitive area.

directly or indirectly by the proposed action and alternatives. In regard to historic properties, none of the
cumulative actions identified would affect eligible sites, so there would be no cumulative interaction with
any potential indirect effects of the proposed action and BCT alternative.
In regard to cultural concerns, the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction, Foxtail
Group Picnic Area Reconstruction, Old Mill WUI Hazardous Fuels Treatment, and Lee Canyon Fuels
Reduction projects meet the spatial and temporal overlap requirements. A brief summary of these projects
is provided above in section 3.3.
Both the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail Group
Picnic Area Reconstruction Project have likely led to increased summer visitation and noise in upper Lee
Canyon, adding to the direct and indirect effects of the proposed action on the level of respect expressed by
visitors as well as the natural character and serenity of the area due to noise and litter. It is likely that
improvements at McWilliams Campground led to an increase in users of the BCT since both the upper and
lower trailheads are in close proximity to the campground. This additional use most likely increased noise
and litter. The improvements at the Dolomite, Old Mill, and Foxtail recreation sites may also have had an
effect on the level of use on the BCT, with the noted associated effects. Overall, the cumulative impact of
increased visitation due to these projects constitutes a notable cultural impact on the Nuwuvi and their
relationship with the Spring Mountains.
The Lee Canyon Fuels Reduction Project would impact the cultural resources affected by both the proposed
action and BCT alternative. However, the impacts of the fuel reduction project on the viewshed would not
likely be noticeable, similar to the proposed glading discussed in section 3.8.3.2. No substantial cumulative
impact on the viewshed or songscapes is anticipated.
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3.7.5 MITIGATION
The analysis of potential effects on heritage and cultural resources identified the following measures to
mitigate adverse impacts.
3.7.5.1 Historic Properties

As discussed above, elements of the proposed action and BCT alternative were relocated to avoid direct
impacts on the NRHP-eligible site. To address ongoing impacts and potential indirect impacts on the site,
mitigation measures described in the Cultural Resources Narrative Report are necessary (see section 11 in
Santarone et al. 2017). Design criteria listed in section 2.6 will also serve to protect any undiscovered
archaeological resources.
3.7.5.2 Native American Concerns

The mitigation measures identified in section 3.7.3.2 can be summarized as follows:
1. Invite tribal knowledge holders to conduct a cultural assessment.
2. Develop interpretive signs, panels, and brochures to make the public aware of Nuwuvi culture and
the importance of the Spring Mountains, in consultation with the affected Tribes.
3. Invite tribal representative to conduct blessings on the land prior to construction projects.
4. Invite tribal knowledge holders to conduct monitoring of glading and clearing.
5. Give tribal leaders access to wood from felled trees, that can be used for religious ceremonies or
other culturally appropriate practices.
6. In addition to the current support provided for the Gathering for Our Mountains, financial, building
use, and shuttles could be provided. This would be proponent-provided mitigation.
7. Notify Nuwuvi leaders of ski area job openings as they become available. This would be proponent-
provided mitigation.
3.8 SCENERY RESOURCES

Issue – Scenic Integrity: The permit area landscape has been affected by more than 50 years of ski-area
development but generally retains its natural character. The proposed addition of more infrastructure at the
base area and on the mountain would alter the landscape and may adversely affect the area’s scenic integrity.
Indicator: Analysis of effects using the methods prescribed in the Forest Service Visual Management
System (VMS; Forest Service 1974) and other relevant agency direction, in accordance with the TNF Forest
Plan and GMP. ROS classifications are used as a reference.

The TNF Forest Plan and GMP direct how scenic resources factor into SMNRA management activities,
with the overall objective of maintaining or enhancing scenic quality and desired landscape character. The
Forest Plan includes this goal (p. IV-3): “The Forest will be managed with a sensitivity for visual quality.”
The GMP provides similar direction specific to the SMNRA (p. SMNRA-wide 7): “Under the Spring
Mountains National Recreation Area Act, the SMNRA is managed to achieve six general purposes, which
provide themes for organization of more specific goals, objectives, and standards and guidelines:
- The conservation of scenic, scientific, historic, cultural, and other values contributing to public
enjoyment…”
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More specifically, for Management Area 11 – Developed Canyons, the GMP states (p. Management Area
11-30): “Lands are managed to maintain high levels of scenic quality, with an emphasis on views from
major roads and use areas. From these areas, management activities are not visually evident or are visually
subordinate to the characteristic landscape. Regularly scheduled maintenance of facilities under special use
permit reduces their visual contrast.”
In terms of analysis methods, the Forest Plan’s Analysis of the Management Situation (p. II-6) notes that
“An inventory of the scenic resources has been completed using the visual management system outlined in
National Forest Visual Management, Vol. 2.” Under the VMS, Visual Quality Objectives (VQOs) are
assigned to all management areas based on land allocations established by the Forest Plan. VQOs define
how the landscape will be managed, the level of acceptable changes to the natural landscape character
permitted in the area, and under what circumstances management activities or recreational development
may be allowed.
The Forest Plan (p. IV-14) includes this standard and guideline for recreation: “Protect the scenic quality
of the Forest by achieving the designated visual quality objectives (VQO), unless modified by a site-specific
environmental assessment.” The GMP (p. Management Area 11-32) provides the following guideline:
“(11.12) Designate ski area sub-basin visual quality objective as Partial Retention. (Guideline)” The Forest
Plan (p. IV-3) defines the VQO of partial retention as “Management practices are visually subordinate,” a
very broad definition. Compliance with VQOs is assessed according to the “…degree of acceptable
alteration of the natural landscape based upon the importance of aesthetics. The degree of alteration is
measured in terms of visual contrast with the surrounding natural landscape” (Forest Service 1974).
A second piece of management direction that factors into this analysis is the Recreation Opportunity
Spectrum (ROS). The Forest Service developed the ROS “to help determine the scale, amount, and type of
development at different sites. It is based on the premise that people expect certain levels of development
related to the character of the setting and the type of recreation they prefer” (Forest Service 2007). The ski
area has been assigned two ROS classifications: Roaded Natural (RN) for roughly the lower half of the
permit area, and Semi-Primitive Non-Motorized (SPNM) for the upper half (Forest Service 1982). RN is
defined as:
Area is characterized by predominantly natural-appearing environments with moderate
evidences of the sights and sounds of man. Such evidences usually harmonize with the
natural environment. Interaction between users may be low to moderate, but with evidence
of other users prevalent. Resource modification and utilization practices are evident, but
harmonize with the natural environment. Conventional motorized use is provided for in
construction standards and design of facilities. (Forest Service 1986b)
SPNM is defined as:
Area is characterized by a predominantly natural or natural-appearing environment of
moderate to large size (2,500 acres). Interaction between users is low, but there is often
evidence of other users. The area is managed in such a way that minimum on site controls
and restrictions may be present, but are subtle. Motorized use is not permitted.
The third piece of direction considered in this analysis deals with the built environment. Both the Forest
Plan and GMP support developed recreation, including the ski area, making the built environment (e.g.,
roads, trails, ski lifts, buildings, and other infrastructure) part of the landscape. The built environment of
the SMNRA serves as a viewing platform from which the public enjoys the predominantly natural landscape
as well as being part of that landscape.
To ensure that the built environment blends as well as possible with the natural landscape, the HTNF
developed the Spring Mountains National Recreation Area Built Environment Image Guide (BEIG, Forest
Service 2007). The BEIG provides recommendations focused “on the appearance and function of facilities.
Facilities should have a uniform character and use of materials that both reflect and fit into their setting.
Final design must respond to the specific environment and user needs.” That guidance is used in this
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analysis to assess how much the existing and proposed elements of the built environment alter and depart
from the natural landscape.”
The fourth and final management direction pertinent to this analysis focuses on highways. The GMP calls
for several SMNRA highways, including Lee Canyon Road (SH 156) to be designated as state and/or
national scenic byways (p. PMP-62). In 1998, Nevada designated SH 156 as a Nevada Scenic Byway. This
means that the Nevada Department of Transportation (NDOT) shall:
• Maintain designated routes and enhance their scenic qualities.
• Assure and maintain the proper signing of all scenic routes.
• Facilitate Federal funding for projects related to scenic routes.
• Coordinate with Nevada Commission on Tourism and the Scenic Byways Committee to
perform evaluations on roadways that have been nominated for review.
• Prepare agreements to ensure federal funds are expended properly on projects related to
Scenic Byways.
• Update biannually the Scenic Byways procedural manual.
• Recommend to the Director of NDOT that a route be designated as scenic.
(https://web.archive.org/web/20141220125438/http://www.nevadadot.com/traveler_info/scenic_byways/n
evada_scenic_byways.aspx)
Based on these four pieces of management direction, the methodology for this analysis can be summarized
as follows. First, the accuracy of current VQO and ROS classifications are assessed to ensure an accurate
baseline for comparison. Second, changes to the project-area landscape due to the proposed action and
alternatives are assessed for compliance with these baseline VQO and ROS classifications, and with
management direction for Nevada scenic byways. Impacts are then summarized from three viewpoints: SH
156 at upper Lee Meadows, the Bristlecone Trailhead, and the scenic viewpoint about 1.7 miles up the BCT
(see Figure 3-3). These viewpoints were selected because they are the primary places, on roadways or trails,
from which large numbers of visitors to the area who are not ski area guests, and thus may not expect or
appreciate the proposed ski area infrastructure, would view the project area. They are the most sensitive
and highly used viewpoints. The analysis area is the viewshed – i.e., the area visible from – these three
viewpoints.

The three points define the high-use areas from which the ski area and proposed improvements are visible.
Intervening terrain blocks it from view from SH 156 outside the ski area itself, both below and above the
Meadows, and it is not visible from McWilliams Campground, Camp Lee Canyon, or the few private
residences between the Meadows and ski area entrance. In short, the ski area is in a hidden pocket at the
extreme upper end of Lee Canyon.
The natural aspects of the analysis area include the cliffs, rock bands, and talus falling steeply from the
ridgelines of Mummy Mountain east of the ski area, Charleston Peak to the south and west, and the Sisters
to north. Sparse coniferous forest begins on the higher slopes, dominated by limber pine, bristlecone pine,
and white fir. Moving down the slope, forest vegetation thickens and shifts to ponderosa pine and white fir.
Stunted aspens grow in avalanche chutes, erosion gullies, and drainage bottoms. Understory vegetation is
thin throughout.
As to the built environment, the ski area was first permitted in 1964, and the lodge (now the administration
and rental building) was constructed in 1965. The main lodge was completed in 1970. Aside from these
major developments, piecemeal additions to the built environment, primarily at the lower (maintenance
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facilities and ski patrol) and mid-mountain base areas (main lodge and administration/rental building) have
been constructed over the intervening years.
The result is a mixture of wood-faced buildings (main lodge and administration/rental buildings), steel
structures of various sizes (largest is the maintenance shop; others include generator and storage buildings),
house trailers, yurts, and shipping containers. There is no consistent architectural theme.
On the mountain, the first major lift, a T-bar, was constructed in 1965. The first chairlift, Chair No. 1 (now
Sherwood) was completed in 1970. In the early ‘80s, Chair No. 2 and Chair No. 3 (now Bluebird and Rabbit
Peak, respectively) were installed. These lifts access about 385 acres of groomed ski runs. In 2012-13, about
10 acres of forested terrain on the west side of the Sherwood Forest lift alignment was gladed (i.e., thinned
to reduce tree density, similar to what is included in the proposed action for other areas) to provide tree
skiing opportunities.
The top lift terminals are colored to blend with the natural background, and from several perspectives they
are screened by trees. The cleared lift alignments are visible where they cut through forest vegetation,
particularly in winter when the snow contrasts sharply with the surrounding vegetation. Similarly, the
groomed ski runs are clearly visible, particularly in winter. However, they are not linear features and have
a similar appearance to avalanche paths in some instances. Run edges are cleanly cut, not feathered, which
increases the contrast. The gladed area is difficult to discern from most viewing angles because the density
of forest vegetation varies so much at the ski area. Some service roads are visible, but most are within
groomed ski runs. The photos below in section 3.8.3.2 illustrate existing conditions from the target
viewpoints.
In terms of the indicators for this analysis, the BEIG establishes criteria to make the built environment of
the SMNRA blend more effectively into the landscape. These criteria vary for different elevations and
ecosystems. The ski area falls under the Forested classification, where the criteria include emphasis of
vertical design elements, use of stone and milled wood in construction, peaked roofs, and windows and
doors on south and east exposures. Building should be limited to two levels, with smaller footprints to
reduce surface impacts. Despite the variety of current architectural styles and materials, no existing
structures truly match these criteria.
As noted above, the VQO for the permit area is Partial Retention, defined by the Forest Plan as
“Management practices are visually subordinate.” The current setting generally complies with this
management direction with the exception of the base-areas, where the concentration of existing buildings,
parking lots, and other infrastructure matches the VQO or Modification. The lack of a consistent
architectural theme makes these facilities a greater departure from the natural setting. Based on the current
setting, baseline conditions are a VQO or Modification for the base areas and their immediate surroundings,
and a VQO or Partial Retention for the remainder of the permit area.
Regarding ROS assignments, the lower roughly half of the ski area is classified as RN, as described above,
a designation that also does not fit the existing base areas. By definition, those areas are not predominantly
natural appearing. They do not harmonize with the natural setting, especially without a consistent
architectural theme and BEIG compliance, and low to moderate interaction with other users is not realistic
for a ski area base area. As a result, the current setting in and around the base areas better matches an ROS
of Rural. Beyond the base area, the lower ski lifts and runs, as well as the expected level of interaction with
other users conform to the RN description. Accordingly, baseline conditions are an ROS classification of
Rural for the base areas and their immediate surroundings, and a RN classification for the remainder of the
permit area.
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Figure 3-3. Three viewpoints.
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The upper slopes of the ski area lie in SPNM classification, defined by a largely natural-appearing
environment, low level of interaction among users, few site controls, and no motorized use. The first
criterion is met on the upper mountain, and the ski area’s use of motor vehicles for maintenance and
operations is not precluded by last criterion, which addresses public use. Compliance with the second and
third criteria is an issue. Interaction among guests on a busy day can be high, and the timing and location
of guest use is dictated by operating hours, rope lines, signage, and area closures for safety concerns. Like
the lower mountain outside the base areas, the upper mountain more accurately reflects the RN
classification.
As to the scenic byway designation, except for the very top of Bluebird pod, the ski area is not visible from
SR 156 outside the ski area boundary, and that point is only visible from a short stretch of the road through
Lee Meadow. Once the highway enters the ski area, it is functionally part of the ski area, which is
responsible for road maintenance and snow removal for the short distance from the entry to Bristlecone
Trailhead. Based on these considerations, the ski area is consistent with management direction for Nevada
scenic byways.

Under this alternative, little change is anticipated in ski area development and infrastructure, and the
conclusions outlined above for the current setting would remain valid. BEIG criteria would not be met,
retaining the built environment’s departure from the natural landscape. The mid-mountain and lower base
areas would continue to reflect the Modification VQO and the Rural ROS designation. The rest of the
permit area would remain consistent with the Partial Retention VQO and RN ROS classification.
Management would be consistent with stipulations for SR 156.
From Viewpoints 1 and 3, at Lee Meadow and the BCT scenic overlook, these conclusions would be
inconsequential; only undeveloped portions of the ski area are visible from these locations except in distant
background (i.e., the upper end of Bluebird pod). However, from Viewpoint 2, at the Bristlecone Trailhead,
the entry gates and building tops at the mid-mountain base areas are visible (terrain screens the lower base
area). As a result, visitors who are not there to ski would continue to find the ski area – and particularly the
mid-mountain base area – to be a significant departure from the natural landscape. The current views from
the three viewpoints are shown in Figures 3-4 through 3-6 below. (Note that impacts on the recreational
experience of BCT users, including visual impacts, are addressed in section 3.9, Recreation.)

Implementation of the proposed action would have mixed effects on the project area’s landscape character.
New development of both base-area structures and on-mountain recreational infrastructure would be
widespread across the ski area.
In terms of the built environment, several elements of the proposed action would replace existing structures
and facilities (e.g., the equipment rental/food & beverage building and the first aid/ski patrol building). In
accordance with project design criteria (section 2.6), these new structures would be designed and built in
accordance with the BEIG. As a result, they would blend more effectively with the natural setting and start
the process of establishing a consistent architectural theme at the ski area.
Other proposals (e.g., the gatehouse, toilet facility at the overflow parking lot, and new parking lot) would
be additions to the built environment, but they would be designed and built in accordance with the BEIG.
As a result, they would blend with the landscape better and further establish the consistent architectural
theme.
On-mountain infrastructural changes would be more widespread. In terms of acreage, development of the
Chair 5 (including Lift 6) and Chair 8 pods would be the biggest changes to the landscape, adding
approximately 73 acres of cleared lift corridors and ski runs to the landscape. By necessity, the lift corridors
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would be linear, while the ski runs would generally mimic more natural features such as avalanche chutes
and drainage channels. In accordance with project design criteria, the edges of both lift alignments and ski
runs would be feathered (i.e., cut to leave an irregular fringe of trees) to reduce contrast and blend with the
background vegetation.
Glading would be done on 33.5 acres to reduce tree density and allow tree and glade skiing. As noted above,
previously gladed areas are indistinguishable from most viewing angles, and this element of the proposed
action is expected to have similar effects.
The 1.2-mile mountain coaster track would be a new and, at least initially, unexpected addition to the
landscape. In foreground views, the loading/unloading terminal would be a clear departure from the natural
landscape, as would the curving track. From more distant perspectives, its visual impact would vary
according to distance and intervening terrain and vegetation. Higher sections of the track would be more
evident from more viewing angles, relative to lower sections of the track.
The hiking trail and mountain bike trail system would add 13 miles of trails up to 4 feet wide to the ski area
landscape. The trails would be non-linear, generally conforming with natural features. Alignments would
not require tree clearing, and forest vegetation would screen the majority of the trails. While section of trail
would be visible from some perspectives, particularly prior to site rehabilitation, the trail system overall
would blend with the landscape increasingly over time. The joint-use hiking and biking trail might be an
exception due to its greater width and central location, as would the flow trail in the Bluebird pod due to
the number of terrain features it would include and its central location. Both of these trails would be in more
heavily developed parts of the ski area.
The zip line itself would be difficult to discern except where it required tree clearing. This is anticipated to
be a small part of the alignment, and clearing would be done in accordance with the design criterion
requiring feathered edges. The four launch and landing towers, up to 25 feet high, pose more of a visual
concern. However, most would be on higher slopes, and design criteria call for coloring these towers, like
the lift terminals, natural colors blending with the background earth, rock, and vegetation. Overall, the zip
line would have little effect on the landscape.
Lift 4, snowmaking system expansion, and the new water tank would have negligible effect on the natural
landscape. The lift would replace an existing handle tow on the side of the cleared Rabbit Peak beginner
run. The snowmaking expansion would be buried and not visible after site rehabilitation. The water tank
would be painted to blend in with the environment and screened from most viewing angles by vegetation.
In terms of the indicators in this analysis, bringing the BEIG into effect would improve integration of the
built and natural environments, but not to a large degree. The lower and mid-mountain base areas would
continue to be consistent with the VQO of Modification, with no major change from current conditions but
a positive trend established due to the BEIG.
The on-mountain infrastructure of lifts, ski runs, hiking and biking trails, the mountain coaster, and the zip
line would, in general, be more of the same type of development at the ski area. The greater extent would
be offset in part by the design criteria established to reduce contrast with the natural setting. As to
consistence with the Partial Retention VQO, the question is whether these additions would result in an
unacceptable degree of change from the natural landscape. Given the baseline of past development at the
ski area, the change would be incremental rather than something entirely new, and therefore acceptable.
Visitors expect to see ski area infrastructure ski lifts and runs at a ski area.
Regarding ROS classifications, the base areas would remain consistent with the Rural classification for the
reasons outlined above for current conditions. The slopes above would remain consistent with the current
RN classification.
From Viewpoint 1, none of these changes would be visible. See Figure 3-4. The proposed action would
have no impact on the viewed landscape.
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From Viewpoint 2, portions of the Chair 5 pod and the zip line would be visible – an increased departure
from the natural landscape but consistent with the changes made to date. Terrain would block most
development at the mid-mountain base and portions of the ski area west of there, including the mountain
coaster. Distance would reduce or eliminate any visual impact of development higher on the mountain.
Glading would not be discernible to the casual observer. See Figure 3-7.
From Viewpoint 3, development of the Chair 8 pod and the Chair 8 top-terminal access road would be a
clearly noticeable change. The lift, most of the cleared runs, and the cut and fill slopes of the access road
would contrast sharply with unbroken forest currently visible from that vantage point. Terrain and
vegetation would block views of the mountain coaster, base-area elements, and Chair 5 pod. Glading would
not be discernible. Distance would reduce or eliminate views of more easterly elements of the proposed
action on the higher slopes. See Figure 3-8.

This alternative would basically shorten the Chair 8 pod so it did not extend down to the BCT (including
associated shortening of snowmaking system coverage of Chair 8 ski runs), shift the mountain coaster to
an alternative location in the Chair 5 pod, and shift the zip line to a new alignment in the Sherwood Forest
and Chair 5 pods.
These changes would reduce the visual impact of these three elements on BCT users, but they would not
alter the conclusions regarding VQO, ROS, or scenic byway considerations outlined above for the proposed
action.
As to the three viewpoints, the most striking difference would be that some zip line clearing and towers
would be visible from Viewpoint 2. As discussed above under the proposed action, this would be an
increased departure from the natural landscape but consistent with the changes made to date. Shortening
the Chair 8 pod would generally not be visible from Viewpoint 3, but the ski run alignments would be
shifted. The viewshed from Viewpoint 1 would remain unchanged from the current conditions. See Figures
3-4, 3-9, and 3-10.

directly or indirectly by the proposed action and alternatives. Only the Lee Canyon Fuels Reduction Project
described in section 3.3 would impact the viewshed impacted by the proposed action and BCT alternative.
Impacts of this project on the viewshed would not likely be noticeable, similar to the proposed glading
discussed in 3.8.3.2. The Lee Canyon Fuels Reduction Project would not interact cumulatively with the
impacts of the proposed action or BCT alternative in any way that would alter the conclusions regarding
VQO, ROS, or scenic byway considerations outlined above for the proposed action.
3.8.5 MITIGATION
Beyond the design criteria listed in section 2.6, no additional mitigation measures are required for this
resource.
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Figure 3-4. Viewpoint 1, no-action alternative.
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Figure 3-7. Viewpoint 2, proposed action.
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Figure 3-8. Viewpoint 3, proposed action.
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Figure 3-9. Viewpoint 2, Bristlecone Trail alternative.
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Figure 3-10. Viewpoint 3, Bristlecone Trail alternative.
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3.9 RECREATION
Issue 1 – Impacts on BCT Users: The upper BCT passes through the permit area, and the upper trailhead is
within the permit area. This trail is one of the most heavily used in the SMNRA, and use occurs year round.
The proposed Chair 8 and associated ski runs, mountain coaster, zip line, and mountain bike trails would
all intersect the BCT, altering the viewscape, generating noise, bringing more people to the area, and overall
shifting to a less natural setting. This may affect the recreational experience provided by the BCT.
Indicator: A qualitative assessment of current recreational use of the BCT and how visual character, noise,
and use levels would change. ROS classifications are used as a reference.
Issue 2 – Climate Change and Ski Area Viability: Reductions in snowpack due to climate change are a
major concern for the ski industry. Lee Canyon could be particularly vulnerable given its southern location.
Climate change could affect the future viability of this area as a winter recreation site.
Indicator: A review of recent research on regional climate change and its effects on resources and resource
uses, specifically snowpack depth and duration and developed winter sports sites, to assess likely effects
on Lee Canyon.

3.9.1.1.1 Impacts on BCT Users
The TNF Forest Plan and GMP direct how recreation factors into SMNRA management activities,
recognizing that recreation use of the Forest and the SMNRA is extremely high. The Forest Plan includes
this Forest-wide goal: “The Toiyabe will increase the quality and quantity of developed and dispersed
recreation opportunities with particular emphasis in the Sierra Nevada and the Spring Mountains of
southern Nevada” (p. IV-1).
on the Forest, a number that is likely higher today. A decade after the forest plan, the GMP recognized the
SMNRA’s unique resources as the management priority, listing the following SMNRA-wide goals (p. 7):
Trails of various types, including multi-use trails, are emphasized in the GMP. They are among the current
uses specifically noted in discussion of the third goal listed above, as is skiing. BCT is a popular multi-use
trail, pre-dating creation of the SMNRA in 1993. In accordance with the third and fourth goals above,
disruption of the trail and its users should be avoided in the development of additional recreational
opportunities such as those considered in this proposed action.
Potential disruptions identified through public scoping and internal, interdisciplinary review of the
proposed action include adverse impacts on the landscape viewed from the trail, noise impacts associated
with new recreational infrastructure (e.g., the mountain coaster), increased levels of trail use, and
introduction of incompatible uses, specifically skiers and snowboarder traveling down a trail where
snowshoers may be climbing up. There will also be some temporary, construction-related disruption.
In terms of analysis methods, the Forest Service developed the ROS “to help determine the scale, amount,
and type of development at different sites. It is based on the premise that people expect certain levels of
development related to the character of the setting and the type of recreation they prefer” (Forest Service
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2007). The ski area has been assigned two ROS classifications: Roaded Natural (RN) for roughly the lower
half of the permit area, and Semi-Primitive Non-Motorized (SPNM) for the upper half (Forest Service
1982). RN is defined as:
Area is characterized by predominantly natural-appearing environments with moderate
evidences of the sights and sounds of man. Such evidences usually harmonize with the
natural environment. Interaction between users may be low to moderate, but with evidence
of other users prevalent. Resource modification and utilization practices are evident, but
harmonize with the natural environment. Conventional motorized use is provided for in
construction standards and design of facilities. (Forest Service 1986b)
SPNM is defined as:
Area is characterized by a predominantly natural or natural-appearing environment of
moderate to large size (2,500 acres). Interaction between users is low, but there is often
evidence of other users. The area is managed in such a way that minimum on site controls
and restrictions may be present, but are subtle. Motorized use is not permitted.
Within the ski area boundary, the BCT starts in the RN classification and continues for about 0.8 miles
before crossing into the SPNM classification for the remaining 0.4 miles to the ski area boundary.
Based on these four pieces of management direction, the methodology for this analysis can be summarized
as follows. Disruption of BCT use and users is assessed for compliance with assigned ROS classifications.
The variables used to assess compliance are visual impacts, noise impacts, increased interaction with other
users, and incompatible uses. The analysis area is the roughly 1.7-mile section of the BCT from which the
ski area is visible, the first 1.1 miles of which is inside the ski area boundary.
Figures 2-1 – 2-3 illustrate the proposed action, and Figure 2-4 shows the BCT Alternative.
3.9.1.1.2 Climate Change and Ski Area Viability
Extensive analysis completed by the Forest Service addressing the HTNF (Tausch 2011) and the western
U.S. (Halofsky et al. 2018) provides the best projections currently available on climate change and its
effects on ecosystems, resources, and resource uses. While these broad studies do not provide detailed data
to support in-depth site-specific analysis and conclusions, they do provide meaningful insight into this issue.
The studies address effects on both snowpack and winter recreation.

3.9.2.1 Impacts on BCT Users
BCT is a roughly 6-mile loop, with a lower trailhead below McWilliams Campground on SR156 and an
upper trailhead in the ski area, at the end of SR 156. Due to parking availability at the ski area and other
considerations, many Forest visitors prefer out-and-back hikes from the upper trailhead. Roughly at the
midpoint on the loop a linking trail connects to the Bonanza Trail. The trail is very popular as an easily
accessible option to escape the valley heat. Peak use occurs from late spring through fall.
Section 3.5.2 addresses potential impacts on scenic resources, with a focus on effects visible from three
sensitive viewpoints. Two of these viewpoints are on the BCT, one at the upper trailhead and the other
about 1.7 miles up from the trailhead (Viewpoints 2 and 3 on Figure 3-3). This analysis addresses the whole
trail segment within the ski area boundary, but section 3.5.2 provides a good description of the overall ski
area landscape and potential effects on it. Relevant parts of that description are summarized here. Potential
effects are noted below in section 3.9.3.
The ski area is in a hidden pocket at the extreme upper end of Lee Canyon. The natural aspects of the
landscape include the cliffs, rock bands, and talus falling steeply from the ridgelines of Mummy Mountain
east of the ski area, Charleston Peak to the south and west, and the Sisters to north. Sparse coniferous forest
begins on the higher slopes, dominated by limber pine, bristlecone pine, and white fir. Moving down the
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slope, forest vegetation thickens and shifts to ponderosa pine and white fir. Stunted aspens grow in
avalanche chutes, erosion gullies, and drainage bottoms. Understory vegetation is thin throughout.
From the upper trailhead, the BCT climbs quickly northwest to a sparsely forested ridge then across a dry,
southeast-facing slope about 0.4 miles before dropping into a shaded, more heavily forested drainage
bottom with some aspens and an overall cooler, more moist environment. At the upper end of this drainage
bottom, roughly a mile from the trailhead, the trail crosses the ski area boundary and climbs northwest onto
a drier, thinly forested southeast-facing slope. At about 1.7 miles, it crosses a ridge and drops into the next
drainage.
From this section of the trail, ski area development is visible only for the first 1,500 feet up from the
trailhead. Further up the BCT, and particularly from the drainage bottom, topography and forest vegetation
screen developed portions of the ski area. While the northern and western parts of the permit area are used
by some skiers, no ski area infrastructure exists. The same situation holds as the trail leaves the ski area,
climbs the ridge, and then crosses to the other side, leaving the ski area viewshed. Figures 3-5 and 3-6
illustrate current views from the trailhead and the scenic viewpoint near where the trail crosses into the next
drainage.
In terms of noise, a number of human activities potentially add to the sounds of nature on the affected
section of the BCT, including trail use, ski area maintenance and operations, traffic on SR 156 and parking
lots near its upper end, and activity at Camp Lee Canyon and McWilliams Campground. However, similar
to the visual setting, intervening terrain and vegetation provide the trail some screening from these sounds.
A study conducted for this analysis (Cirrus 2017a) measured average ambient noise levels on the BCT in
July and early August at 31.4 dBA. This is similar to other coniferous forest environments recorded in
published literature with values ranging from 25 to 35 dBA and is categorized as a forest with no wind or
a light wind.
Regarding the level of interaction among users, a survey conducted for this analysis indicates that from July
7, 2017, through August 7, 2017, 4,996 used the BCT above the upper trailhead, for an average of 156 per
day (Cirrus 2017b). The survey identified a 14-hour active-use period, so this translates to about 11 users
per hour. This is indicative peak-season use, when the number of trail users potentially impacted by the
proposed action would be greatest. This measurement was taken just above the trailhead; given the casual
nature of the user group, use falls off sharply with distance from the trailhead.
In terms of types of use, the BCT is a multi-use trail, open to hikers, mountain bikers, horseback riders,
snowshoers, and cross-country skiers. Dogs must be leashed. While peak use occurs from late spring
through fall, some snowshoeing and cross-country skiing use occurs through the winter.
Based on the definitions of the trail’s ROS classifications provided above (section 3.9.1.1), portions of the
trail in the RN classification are generally consistent with that designation. A natural-appearing
environment characterizes the viewshed but, as outlined above, there is moderate evidence of man-made
sights and sounds. As discussed in section 3.8, the view of the base areas from the trailhead does not
harmonize particularly well with the natural environment, but the base areas are not visible beyond the first
1,500 feet of the trail. Resource utilization practices blend with the natural setting. At 31.4 dBA, ambient
noise levels reflect the range of human activity in the area.
During peak season, with an estimated 11 people per hour using the trail, interaction between users is low
to moderate, with evidence of other users prevalent. Given the blend of authorized uses, this interaction
involves diverse forms of recreation from hikers to bikers and horseback riders.
The upper portion of the trail passing through the SPNM classification also complies with its designation,
primarily because the base areas are at sufficient distance that their sights and sounds are not evident. With
less than 11 users per hour on average at this distance from the trailhead, interaction among users is low.
Site controls are minimal.
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3.9.2.2 Climate Change and Ski Area Viability

The Tausch (2011) and Halofsky et al. (2018) studies address potential climate change effects on snowpack,
and latter addresses developed winter recreation. In terms of snowpack, precipitation is one of the more
difficult variables to predict, especially in mountainous areas. However, temperature can be predicted more
reliably, and both precipitation and temperature come into play in determining depth and duration of
snowpack. Precipitation is the more important factor in colder areas, while temperature is more influential
in warmer areas.
The Sierra Nevada Range, and to a greater degree the Spring Mountains, are at the warmer end of the snow
zone, making their snowpacks more sensitive to temperature change. The Halofsky et al. (2018) study
projects a 4 degree F increase in both minimum and maximum temperatures by the mid-21st century. The
study’s precipitation projections are highly variable with no discernible trend, and no projections were made
for the SMNRA area. However, the projected temperature increase will likely decrease the depth and
duration of snowpack to some extent.
In terms of winter recreation, the studies cite a number of sources who conclude that overall warming is
expected to reduce season length and the likelihood of reliable winter recreation seasons. Halofsky et al.
(2018) also notes that “although developed downhill skiing sites are fixed improvements, potential
adaptations include snowmaking and new run development at higher elevation. Warmer temperatures and
increased precipitation as rain may increase availability of water for snowmaking in the near term during
winter, but warmer temperatures may also reduce the number of days per season when snowmaking is
viable. Large ski resorts owned and operated by corporations will probably be more resilient and have more
options for maintaining viable skiing opportunities than smaller, locally-owned businesses” (p. 721).

Under this alternative, little change is anticipated in ski area development and infrastructure, and the
conclusions outlined above for the current setting would remain valid. The landscape viewed from the BCT
would remain generally natural appearing with moderate exposure to man-made sights and sounds,
particularly the mid-mountain base area. Resource modification and utilization practices would be evident
but generally harmonize with the natural environment. Noise levels would be consistent with a coniferous
forest setting. The level of user interactions would remain low to moderate, with other users evident. Those
interactions would continue to involve users of various types. Overall, the recreational experience on the
potentially affect section of the BCT would remain consist with assigned ROS classifications.
As it relates to Lee Canyon and this analysis, the Tausch (2011) and Halofsky et al. (2018) studies
underscore the risk posed by climate change. Halofsky et al. (2018) also identifies adaptations being made
in the ski industry to offset this risk, including increased snowmaking and offering summer recreation
opportunities and year-round operations, a shift that is evident across the mountain resort industry.
Under this alternative, snowmaking would remain as it currently exists, and much of the developed ski
terrain would not be covered by the system. Summer recreation infrastructure would also not be developed,
and the ski area would continue to close when the snowpack was not sufficient for skiing. In short, Lee
Canyon would not make any meaningful adaptions and would remain highly vulnerable to any warming
effects of climate change.
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Implementation of the proposed action would have a number of effects on BCT users. In terms of impacts
on the trail’s viewscape, the main impacts would be associated with proposed summer recreation
infrastructure. This infrastructure would be in use during the same season the trail use peaks, adding to its
impact.
Both the up and down legs of the proposed mountain coaster would cross the lower portion of the trail, and
farther up the alignment the coaster’s down leg would parallel the trail at a distance of less than 50 feet.
Other parts of the 1.2-mile coaster alignment would be visible from various trail viewpoints. The movement
of carriers when the coaster was in operation would increase its visual impact beyond the track itself.
Both legs of the proposed zip line would cross the BCT roughly midway up the affected trail section, and
the terminals between the two legs would likely be visible from some viewpoints. While the lines
themselves would not stand out visually, any clearing necessary to accommodate them would be a change
from the natural setting. Feathered edges would help reduce this impact (see section 3.8). Similar to the
mountain coaster, riders on the zip line would be a visual distraction from the natural landscape.
According to preliminary alignments, proposed mountain bike trails would intersect the BCT at three
locations, near the trailhead, near the midway point, and near the ski area boundary farther up the trail.
These would be easier and intermediate bike trails. The visual impact of the trails themselves would be
minimal, but riders on them would be a visual distraction, as would cautionary signage identifying the
intersections.
Proposed winter infrastructure would also affect the trail’s viewshed, particularly the access roads, lift
alignment, and ski runs in Chair 8 pod. These would be clearly visible from the upper portion of the affected
trail section – a clear break from the current, more natural landscape. They would be visible year-round.
The bottom-terminal access road is a particular concern. It would be a permanent road used to build and
maintain the lift and ski runs, and it would basically overlap the portion of the BCT passing through the
drainage bottom, roughly 1,200 feet. It would be a sharp deviation from the narrow trail currently in place.
In terms of noise, the mountain coaster is the main concern. The analysis of its noise impact completed for
this EIS (Cirrus 2017a) projected that 3,915 feet of the BCT, or 44 percent of the 1.7-mile affected section,
would be subject to noise above the ambient level of 31.4 dBA. Small increases above ambient levels would
not be noticeable to casual observers. However, of those 3,915 feet, 1,546 feet (17 percent of the affected
trail section) would experience an increase of 10 dBA over ambient, and 407 feet (5 percent) would see a
20-dBA increase. The 10 dBA increase would be discernible to many trail users. The 20 dBA increase
would be clear to all. Effects would be greatest where the coaster alignment crossed the BCT and generally
decrease with distance from the coaster. The proposed zip line would also result in increased noise but is
anticipated to be less than the mountain coaster because the lines would cross the BCT overhead at a greater
height.
Trail-use would likely increase. Ski area visitation would increase as a result of the new summer amenities,
and some visitors would likely take advantage of the BCT. However, the user groups would be different.
The mountain bike trails are projected to be the biggest draw, and mountain bikers are unlikely to either
take their bikes on the BCT (after having paid for lift-accessed, purpose-built mountain bike trails) or to
hike the BCT. The mountain coaster and zip line would attract primarily families and young adults looking
primarily for the element of excitement these facilities would offer. While some visitors might opt to walk
up the BCT while others in their group took advantage of the coaster or zip line, their number would likely
be low.
The ski area provided the following projections of summer visitors using the proposed facilities on a peak
day: mountain bike trails, 650; mountain coaster, 1,500; and zip line, 300 (Hooper 2017). Average use is
projected to be 70 percent of those figures. For purposes of this analysis, it is assumed that no mountain
bike trail visitors would use the BCT but that 5 percent of the projected mountain coaster and zip line
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patrons would. That indicates 6 additional trail users per hour on a peak day, 5 on an average day. Those
figures represent increases of 58 and 40 percent, respectively. Most of the increase would likely be near the
trailhead.
The proposed action would also result in incompatible uses. The Chair 8 pod lower terminal access road,
discussed above in terms of scenic impact, would also be a cat track and skiway in winter. It would be used
by snowcats and by skiers leaving the pod to return to the mid-mountain base area. Skiers would drop onto
the skiway from the Chair 8 pod ski runs and turn downward toward the base area. This would conflict with
any snowshoer or cross-country skier traffic coming up the trail.
Another notable impact of Chair 8 pod development would result from construction of the lift and ski runs.
The access road would be used heavily during construction by heavy equipment and other construction
vehicles. To avoid the risk of injury to BCT users, approximately 0.5 miles of the trail would be closed for
all or most of one spring-through-fall construction season.
Most of the affected section of the BCT falls under the RN classification. The users’ experience of the trail
under the proposed action may be consistent with that classification, but by a narrow margin. The BCT
viewshed would remain predominantly natural appearing, with moderate evidence of the sights and sounds
of man. However, the proposed summer recreation infrastructure – particularly the mountain coaster and
the zip line – would not harmonize with the natural environment. The zip line would be a fairly minor
deviation, but the mountain coaster would be a clearly unnatural feature. Regarding winter infrastructure,
co-locating the Chair 8 bottom-terminal access road with a section of the BCT would also detract noticeably
from the natural environment.
In terms of noise, an increase of up to 20 dBA over ambient sound levels may be considered moderate
evidence of human activity. However, the mountain coaster would be most audible on the section of the
BCT that drops from the initial ridge toward the drainage bottom – where trail users have left the sights and
sounds of the highway, parking area, and trailhead behind them. Beyond that, part of the added sound would
be the excited voices of riders, which would be distinctive and highly unnatural. Similarly, the zip lines
would be most audible where the proposed lines pass over the BCT.
With the projected increase in user numbers, interactions would remain at moderate levels, though evidence
of other users would grow. During winter, the introduction of snowcats and downhill skiers on the trail
section shared by the access road/skiway might not be strictly incompatible given the trail’s multi-use
designation, but it would certainly alter the experience of winter trail users.
In regard to resource modification, the Chair 8 pod development would be the most striking element of the
proposed action. However, in accordance with project design criteria, the edges of both the lift alignment
and ski runs would be feathered (i.e., cut to leave an irregular fringe of trees) to reduce contrast and
harmonize with the background vegetation. Access roads would appear less natural.
The upper portion of the affected BCT section in the SPNM classification would be altered only by one
mountain bike trail crossing and views of the Chair 8 pod, and it would remain consistent with this
classification. The impact of the bike trail crossing would be minor and manageable, and design criteria in
place would reduce the visual impact of ski runs.
As discussed above, the Halofsky et al. (2018) report identifies some factors that mitigate the risk posed by
climate change to ski areas. Most important is probably the timeframe; the 4 degree F temperature increase
is projected for 2050, by which time the proposed improvements would have provided decades of high-
quality recreation and probably reached the end of their useful life. They would have served their intended
purpose.
Snowmaking is another adaptation that will likely become more important as the climate continues to warm.
As reflected in the proposed snowmaking system expansion, Lee Canyon recognizes this emerging need.
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The last key adaptation to climate change is the shift across the mountain resort industry to offering summer
recreation opportunities and year-round operations. This shift is evident in Lee Canyon’s proposal.
Collectively, these adaptations would help Lee Canyon offset the most likely impacts of climate change,
increasing its prospects of remaining a viable mountain resort.

As indicated in Chapter 2’s discussion of alternatives, this alternative was developed specifically to reduce
the adverse impacts of the proposed action on BCT users. To summarize, it would move or modify the three
projects with the greatest potential impacts: the mountain coaster, zip line, and Chair 8 pod. The coaster
and zip line would shift to the other side of the ski area, where they would be visible only in background
views from the trailhead and lowest trail section. The Chair 8 lower access road/skiway would be shifted
up slope away from the trail, and the runs feeding onto it would be shortened, reducing interactions of uphill
BCT users with downhill skiers and eliminating interactions with snowmobiles and snowcats. A forested
buffer would screen it from the trail. The mountain bike trail intersections would remain, but as noted they
would be a minor and manageable impact.
Only the first 345 feet of trail (less than 4 percent) would be subject to a sound increase of 10 dBA over the
ambient level. The projected increase in trail users would not change but separating the Chair 8 pod lower
access road/skiway from the BCT would eliminate the potential for incompatible uses. In other respects,
the effects of this alternative would be similar to those of the proposed action. The greatest sound increase
for the zip line would occur at the end of the line around the Chair 3 pod and the mid-mountain base area.
There would be very little impact on BCT users due to the distance of the lower platform from the BCT.
The BCT alternative would retain consistence with both ROS classifications. The reduction in the sights
and sounds of human activity would eliminate any doubt about consistence with the RN classification on
the lower trail section, and not enough of the added trail users would reach SPNM-classified section to
generate more than a low level of interaction among users. These are the only two factors potentially
threatening ROS consistence.
The potential effects of climate change on ski area viability under this alternative would be the same as
under the proposed action.

Campgrounds Reconstruction and Foxtail Group Picnic Area Reconstruction projects meet the spatial and
temporal overlap requirements. A brief summary of these projects is provided above in section 3.3.
Both the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail Group
Picnic Area Reconstruction Project impacted recreation in Lee Canyon. In each case the recreation
conditions were improved within the campgrounds and day-use areas. Impacts of these projects on users of
the BCT are unclear. It is likely that improvements at McWilliams Campground led to an increase of users
on the BCT since both the upper and lower trailheads are in close proximity to the campground. The
improvements at the Dolomite, Old Mill, and Foxtail recreation sites may also have had an effect on the
level of use on the BCT. However, the impacts of all of these projects on the use of the BCT are reflected
in the BCT use data presented in section 3.9.2.1. Therefore, no additional cumulative interactions impacting
users of the BCT between the cumulative actions and the proposed action and BCT alternative are expected.
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With regard to climate change and the continued viability of the ski area, the improvements made by the
Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail Group Picnic Area
Reconstruction Project would likely interact with the addition of summer activities included in the proposed
action and BCT alternative to promote the continued viability of the ski area. The moves to improve
conditions at the recreation sites and increase the number of day-use sites would likely continue to provide
a base for activities and services that the ski area would be more equipped to provide under a scenario where
the proposed action or BCT alternative were implemented.
3.9.5 MITIGATION
Beyond the design criteria listed in Section 2.6, no additional mitigation measures are required for this
resource.
3.10 SAFETY
Issue 1 – Collision Hazard: The proposed action includes mountain bike trails and a dual-use, hiking and
biking trail. Some of the mountain bike trails cross the BCT, as do some of the proposed ski runs. This mix
of trail types and uses may result in collision hazards for trail and ski run users.
Indicator: An assessment of collision risk on multiple-use trails and trail intersections based on use levels
and the efficacy of design criteria and proposed mitigation.
Issue 2 – Emergency Services: Most medical and fire services in the SMNRA are based in Kyle Canyon,
and the distance to Lee Canyon, coupled with traffic congestion, can result in slow response times. As a
result, additional, year-round visitation associated with the proposed infrastructure may affect provision of
emergency services.
Indicator: A quantitative assessment of the estimated increase in demand for emergency services and an
evaluation of the ability of new and existing infrastructure to accommodate any increase.

3.10.2.1 Collision Hazard
From late spring through fall, hiking is a poplar recreational activity in Lee Canyon. The upper canyon
offers a unique opportunity to escape the heat in the valley below. The BCT is one of the most heavily used
trails in the canyon. A mixed user group of hikers, mountain bikers, and occasional horseback riders use
the trail.
The BCT has two trailheads, generally referred to as the upper and lower trailheads due to one being higher
up the canyon than the other. The more popular upper trailhead is at the ski area, at the upper end of SR
156. That portion of the roadway has been widened to provide parking for BCT users as well as ski area
visitors. Approximately 150 people per day use this trailhead during peak season (see section 3.9).
With so many users on the trail, interactions between user groups are common (e.g., hikers moving to the
side to let bikers pass). The nature of the BCT (i.e., a relatively straight trail through open forest with little
understory) reduces the potential for collisions since trail users have good visibility down the trail ahead of
them. No data exists on collisions involving trail users of different types, but despite the high use on the
trail these are reportedly rare events.
In the winter, use of the BCT declines substantially (see section 3.9). The occasional snowshoer or
backcountry skier uses the trail, but these activities are restricted by the specialized equipment required for
uphill winter travel. The predominant use of the BCT in the winter is as egress from the backcountry-like
skiing in the portion of the ski area where the Chair 8 pod is proposed. This terrain is used frequently, and
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a well-packed path usually coincides with the BCT for roughly 1,500 feet in the gully, approximately 0.4
miles up from the trailhead, leading back to the mid-mountain base area.
Trail conflicts in the winter are extremely rare. This is partially due to the mostly unidirectional flow of
trail users (i.e., skiers going downhill to the mid-mountain base area) but also because winter users going
either direction are not restricted to the actual trail since the snow cover allows them to easily shift on and
off the trail.
3.10.2.2 Emergency Services

Whenever the ski area is open, there are trained and certified emergency medical technicians (EMTs) on
duty to provide appropriate on-site treatment. In addition to medical qualifications, these personnel have
avalanche rescue, lift evacuation, and vehicle accident training and experience. However, they do not have
the capability to transport accident victims to hospitals. The nearest provider of ambulance service and
outside emergency support is the Mount Charleston Fire Protection District (MCFPD) in Kyle Canyon,
14.6 road miles from the ski area via SR 157, SR 158, and SR 156.
Emergency service calls at the ski area are currently very limited during the summer due to the few days
the area is open and the limited activities available. When calls for emergency services do occur, response
time is limited by the distance from the MCFPD facility. Traffic and road conditions are generally not
factors delaying emergency response in the summer (see section 3.11).
During the winter, the number of emergency service calls is higher due to the increased activity at the ski
area. The area is open virtually every day of the average 120-day ski season, the range of activities available
is greater, and visitation is higher. Activities such as skiing, snowboarding, and tubing have inherent risks,
and accidents requiring a response from emergency service providers are more common than in the summer.
Over the last five ski seasons, the average skier-visits per season was 63,348 and the average number of
MCFPD responses to calls from the ski area was 40.8. On average, MCFPD emergency services responded
once per every 1,553 skier-visits at the ski area (Cirrus 2017c).
Skier-visits are not distributed evenly throughout the ski season but are concentrated on weekends and
around holidays. Data obtained from MCFPD did not include the date of individual responses but was
summarized for the ski season. For this analysis, it is assumed that MCFPD responses are concentrated
around high-use periods at the ski area, since the number of people engaged in higher-risk activities is
logically correlated with the number of incidents requiring emergency services.
Currently the MCFPD stages an ambulance at the ski area during most of these high-use periods. This is
done not only because of the greater likelihood of a call but also because the high-use periods at the ski
area correlate to high-use and high-traffic periods in Lee Canyon (see section 3.11). During these periods,
the travel time from Kyle Canyon to the ski area can be excessive. A summer response time of 20 minutes
from the MCFPD facility to the ski area can increase to 45 minutes or more on weekend days in the winter.
This ties up MCFPD emergency service resources and delays overall response time and effectiveness in the
service area.

3.10.3.1.1 Collision Hazard
Under this alternative, no trail development would occur and the situation described in the affected
environment section above would continue. The number of trail conflicts would likely increase with growth
in the number of trail users reflecting expansion of the Clark County population.
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3.10.3.1.2 Emergency Services

Under this alternative, no changes in summer activities or levels of winter use would occur. The emergency
services situation described in the affected environment section would continue. Growth in the county
population, equating to increased SMNRA visitation, would increase demand for MCFPD emergency
services overall, as well as traffic on SMNRA roads.

Under this alternative, expanded summer operations would bring many more visitors to the ski area.
However, due to a variety of factors, it is unlikely that a substantial number of these visitors would use the
BCT, and the ones who did would not change the overall trail experience (see Section 3.9). A marginal
increase in BCT users would not change the collision risk situation described in the affected environment
section.
Mountain bike trails operated by the ski area would cross, or come very near to, the BCT in four places.
Unmitigated, these crossings would present a substantial collision risk due to the high speed of bikers on
the downhill-traffic-only trails, and the high density of hikers on the BCT. In order to reduce this risk to an
acceptable level, mitigation measures would be required.
Mitigating collision risk would involve a combination of signage notifying bikers that a crossing with a
multi-use trail was approaching and features intended to slow riders. Multiple signs would be used, and
each successive sign would tell bikers the distance to the crossing. Slowing features could include
narrowing of the trail, sharp turns, obstacles such as rocks, or less steep grades. Trail design would ensure
that the intersection was visible from an adequate distance and that mountain bikers could see up and down
the BCT before arriving at the intersection. With the mitigation measures detailed in section 3.10.5 in place,
the collision risk for users of the BCT under this alternative would remain low in the summer.
In the winter, there would be more downhill skier traffic on and around the BCT. Most of the Chair 8 pod
ski runs would terminate on, or cross, the BCT. Furthermore, the path of egress from the Chair 8 pod would
continue to be down the BCT, and substantially more skiers and snowboarders would be using the pod due
to the proposed developments. However, the risk of collisions with uphill traffic would remain low for the
same reasons they are low currently. Specifically, there are very low numbers of uphill users in the winter
and, due to snow cover, the optimal uphill route is not necessarily the same as the downhill route, and the
uphill and downhill traffic are separated as a result.
Under this alternative, the ski area anticipates that annual skier visits would increase by approximately
96,000. Using the average ratio of skier visits to MCFPD responses of 1,553 to 1, this would result in an
increase of 61.8 MCFPD responses per year relative to the no-action alternative. Assuming once again that
MCFPD responses are primarily concentrated around high-use periods at the ski area, these responses
would likely occur at times when MCFPD already stages an ambulance at the ski area (i.e., around holidays
and busy weekends).
According to projected skier visit data provided by the ski area, there would be 38 days over the course of
the season where the expected MCFPD responses would be greater than or equal to 1 (i.e., with 1,553 or
more expected skier visits), with a range of 1 to 1.8. All of these days occur during the holiday season or
on weekends. The increase in the likelihood of calls during this period would likely be accommodated by
the current MCFPD practice of staging an ambulance at the ski area during high-use periods, but this
practice may need to be extended to a few additional weekends. Additional calls outside high-use periods
would require MCFPD response from Kyle Canyon; however, these would occur during times of low
traffic, so response times would be on the lower end of the 20-to-45-minute range.
Of the summer activities that would be added under this alternative, only the mountain bike park has the
potential to lead to noticeably increased MCFPD responses due to injuries. It is anticipated that the
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mountain bike park at the ski area would draw approximately 10,000 biker visits the first year of operation
and gradually increase to a maximum of 25,000 biker visits in 5 to 10 years (Kelly 2017).
Based on industrywide data for mountain bike parks across the country, the rate of injuries requiring
ambulance transfer is approximately 1 per 1,000 biker visits, yielding 10 to 25 MCFPD responses per
season (Kelly 2017). Calls for service would be concentrated around weekends and holidays, when higher
numbers of bikers would be expected at the mountain bike park. In order to deal with the increased need
for ambulance services during high-use periods, it may be advisable to station an ambulance at the ski area
on weekends and holidays that the mountain bike park is open.
The new ski patrol/first aid building and associated staff would provide substantially better suited facilities
than currently exist at the ski area, including a dedicated ambulance-loading area. However, the ski area
would still not have the capability to transfer patients to facilities in the valley.
An increase of approximately 87 MCFPD responses per year once buildout of all infrastructure was
completed, and peak visitation was reached (~10 years after buildout), would likely be taxing on the existing
resources of the MCFPD. Additional medical staff at the ski area, or arrangements with private ambulance
companies may be needed to ensure adequate patient care. Efforts by NDOT and other agencies to improve
traffic flow on SMNRA highways under their management could also alleviate this issue.

Under this alternative, summer trail collision risk would be the same as under the proposed action. The
same mitigation measures would be in-force.
Winter collision risk would be less than under the proposed action – approximately the same as under the
no-action alternative and current conditions. While substantially more people would be using the Chair 8
pod, the egress route from the pod would be shifted upslope from the BCT, and no ski runs would terminate
on, or cross, the BCT. Some Chair 8 pod users would likely continue down to the old egress route from the
pod that they used in the past but this option would be far less attractive than the official egress route created
under this alternative.
Under this alternative, impacts related to emergency services would be the same as under the proposed
action.

Any impacts of the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail
Group Picnic Area Reconstruction Project related to trail conflicts on the BCT and provision of emergency
services are reflected in sections 3.10.2.1 and 3.10.2.2 since they would have already occurred. Increased
use of these facilities could result in more injuries, adding cumulatively to demands on MCFPD emergency
services. Given the limited increase in campground and day-use facility capacity, this potential change is
likely small. No further cumulative effects are expected.
3.10.5 MITIGATION
The impacts described above depend on the following mitigation measures being in place:
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1. Use at least four signs to notify riders of each intersection with the BCT. Signs will be spaced
approximately 100, 50, 25, and 0 feet from the intersection. Additional signs may be used if
deemed necessary.
2. For each intersection of mountain bike trails with the BCT, use two signs on the BCT, one facing
each direction, to notify BCT users of the intersection.
3. Where appropriate, use slowing features to reduce the speed of mountain bike trail users at
intersections with the BCT.
4. When determining the final layout of mountain bike trails, ensure that users of the trail can see at
least 20 feet up and down the BCT from a distance of 30 feet away from the intersection.
3.11 TRAFFIC
Issue – Traffic Congestion: The road network serving the SMNRA provides adequate service with one
exception. On winter weekends and holidays, people flock to the SMNRA for the novel snow-play
opportunity. The Lee Meadows area is especially popular, and county-provided parking is insufficient. As
a result, traffic flow is often impaired by vehicles parked on the roadway, drivers slowing to find parking
places, and overall congestion. Additional winter visitation associated with the proposed infrastructure may
contribute to traffic congestion.
Indicators: An assessment of existing and expected traffic volumes and patterns, and how these patterns
would affect the level of service (LOS) on Lee Canyon road (SR 156), based on existing information.

SR 156, also known as the Lee Canyon Road, is a state highway under the administration of the NDOT. It
is one of two highways accessing the SMNRA from U.S. Highway 95. The SR 156/US 95 junction is 18
miles northwest of Las Vegas. SR 156 is about 17 miles long, ending at the ski area. The Forest Service’s
avalanche control artillery piece is deployed in a turnaround at the end of the highway during the winter,
and the upper 1,700 feet of the road are used for ski area parking as well as parking for the upper BCT
trailhead. The ski area is responsible for snow removal on SR 156 within the ski area boundary.
The last traffic study that addressed SR 156 was the 2005 Spring Mountains National Recreation Area
Traffic Study, completed by an interagency team including representatives of the Forest Service, NDOT,
the Regional Transportation Commission of Southern Nevada, Clark and Nye counties, the Las Vegas
Metropolitan Police Department, and the Federal Highway Administration (Core Team 2005). No traffic
counts or other data collection efforts have occurred since that study was completed. As a result, the 2005
study and anecdotal information from various people involved in and affected by the traffic situation are
the basis for this description of the current setting.
Traffic on SR 156 has increased incrementally since the 2005 study was completed, reflecting population
growth in Las Vegas and its surrounding communities, but traffic patterns and LOS remain similar. During
normal winter days, traffic on SR 156 normally flows fairly freely, operating at acceptable LOS ratings of
A to C (free flow to stable flow near free flow), with uphill traffic during the morning peak period
experiencing minor delays in certain stretches (Core Team 2005). However, during busy periods LOS on
SR 156 drops substantially.
There is little current, quantitative information on LOS on SR 156 during congested winter weekends and
holidays, when the novelty of snow in the desert brings valley residents of all types to Lee Canyon. On
January 1, 2005, over 6,600 vehicles were counted entering the SMNRA (Core Team 2005). No breakdown
of where on the SMNRA those vehicles went was provided in the report. However, data on vehicle
occupancy, in the same report but from a different date, shows 41 percent of the inbound weekend traffic
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was in Lee Canyon on SR 156. Assuming a similar traffic distribution for the 6,600 vehicles observed in
on January 1, 2005, yields 2,706 vehicles entering the SMNRA via SR 156 on a very busy day.
Between 2005, when the Core Team study was completed, and 2015, the population of Clark County grew
from 1,708,800 to 2,114,800 people, an increase of 24 percent (U.S. Census Bureau 2017). Applying a
corresponding increase to the 2005 traffic data yields 8,184 vehicles in the SMNRA, and 3,355 vehicles in
Lee Canyon, on a winter peak day. Factors other than population growth contribute to changes in the
number of vehicles in Lee Canyon on peak days, and the number of vehicles Lee Canyon can accommodate
has a physical upper limit. However, it is reasonable to assume that traffic has increased roughly
proportionally to population growth in the surrounding area.
The ski area currently has 728 parking spaces available in the winter. Other than parking at the ski area,
there are 218 designated, plowed parking spaces at the three campgrounds in Lee Canyon during the winter
(66 at Foxtail, 62 at Old Mill, and 90 at Sawmill). On a peak winter day, with an estimated 3,355 vehicles
in Lee Canyon as discussed above, this leaves up to 2,409 vehicles without legal parking in the canyon.
This is a conservative estimate, as most vehicles are not in the canyon all day, so parking spaces may
accommodate more than one vehicle per day, and some visitors are just out for a drive. In any case, many
vehicles park illegally on the side of the road or even in the road. Much of this illegal parking is concentrated
around Lee Meadows, since it is a popular snow-play destination.
The combination of a large number of vehicles in the canyon and a substantial amount of illegal, unsafe
parking causes serious congestion around popular recreation areas such as Lee Meadows. The LOS on SR
156 around the meadows falls to a rating of F (severe traffic congestion and roadway failure) during busy
periods. These conditions occur on an estimated 20 days per year.
In an attempt to address the congestion problems around Lee Meadows, the NDOT blocked approximately
40 roadside parking spaces at the meadows during the winter 2017/2018 season. The goal was to prevent
the congestion caused by vehicles moving in and out of parking spaces in this area and vehicles waiting in
the roadway for a parking space to open up. The decision to block these spaces was based on observations
during the winter of 2016/2017, when unusually high snowfall resulted in snow piled by snowplows in this
parking area and along both sides of SR 156 through the meadows. Traffic flowed freely under these
conditions; since no parking was available, motorists had no reason to slow down or stop and wait.
Based on the estimated peak-day vehicle count on SR 156 (i.e., approximately 3,355 in 2015) and the limit
that parking availability places on ski-area visitation (currently 728 spaces, or 22 percent of the vehicles
entering the canyon), the ski area is a relatively minor contributor to traffic in the canyon and to congestion
around snowplay areas.
Regional population growth is the driving factor. The Census Bureau identified Nevada as the second fastest
growing state in the nation in 2016, with growth near 2 percent. Clark County accounted for 86 percent of
the statewide growth, with 47,828 new residents, or an annual growth rate of 2.3 percent. (Brean 2017)

Under this alternative, no development would occur at the ski area, and traffic volumes and patterns would
remain similar to those described above. Ski area parking would remain at 728 spaces, limiting ski area
visitation on peak days and offering few surplus spaces for recreationists not visiting the ski area. Over
time, as the population of the Las Vegas area grew, traffic volumes and congestion problems would get
worse without improvements to SR 156, further decreasing LOS during high-use periods.

Implementation of the proposed action would have mixed effects on winter traffic volumes and patterns,
and thus on the LOS on SR 156.
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The most notable adverse impact would be the additional skiers attracted by the proposed improvements.
While new skiers would be accommodated at the ski area and not add to parking demand lower in the
canyon, they would add to congestion in areas where illegal parking limited the LOS. Under the proposed
action, skier numbers are projected to increase from 1,880 to 2,850 on peak days. At an industry-standard
of 2.5 skiers per car, this would equate to 388 additional vehicles on SR 156, a 12 percent increase over the
2005 peak-day vehicle count. However, the majority of skier vehicles would be on the road during 1.5-hour
periods around the ski lift start time of 9 a.m. and the closing time of 4 p.m. The net effect would be to
prolong periods of congestion and low LOS at existing choke points like Lee Meadows.
One potential positive impact would be increased parking in the upper canyon. The additional 500-car lot
would bring the ski area total to 1,228 spaces. This increase may reduce the number of illegally parked cars
in the canyon by providing non-skiing visitors with more legal options. However, two factors may limit
this benefit. First, the new parking lot would be at the lower base area, roughly 0.6 miles from the meadows.
This distance would limit the lot’s attraction to some canyon visitors.
Second, the ski area would charge for parking in the new lot, as it does for parking in existing lots at the
ski area and at canyon campgrounds maintained by the ski area under permit during the winter. The HTNF
authorizes this practice to allow the ski area to offset their costs for snow removal from these parking areas.
This cost may discourage some potential parking lot users. Based on these limitations, the new ski area
parking in itself may not significantly reduce illegal parking and associated congestion down canyon.
Another potential positive impact would be a shift toward ski area recreation as an alternative to snowplay
at undeveloped sites. The entire package of proposed ski area amenities – including additional parking,
restrooms, food service, and tubing and other recreational opportunities – would likely draw some winter
canyon visitors to the ski area rather than the undeveloped areas where parking was problematic and other
services limited or unavailable. This would reduce the rate of growth in congestion associated with regional
population growth and help maintain an acceptable LOS on SR 156.
Overall, the ski area would remain an important contributor to traffic on SR 156 but far less important than
regional population growth. Beyond that, the additional parking in the upper canyon may reduce parking-
related congestion to some degree, and the proposed improvements as a whole may draw an increasing
proportion of canyon visitors to the ski area.

The impact on traffic volume, traffic patterns, and LOS on SR 156 under this alternative would be the same
as those described for the proposed action.

Any impacts of the Dolomite-McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail
Group Picnic Area Reconstruction Project related to traffic on SR 156 are reflected in section 3.11.2 since
they have already occurred. No further cumulative effects, beyond increases in traffic proportional to
population growth, could be expected.
3.11.5 MITIGATION
In terms of mitigating any potential adverse effect on traffic, providing for adequate LOS and safety on
state highways in the SMNRA is primarily the responsibility of the NDOT and NHP. The Forest Service
works with these agencies and others (i.e., Clark County, the MCFPD, Las Vegas Metropolitan Police
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Department, the National Weather Service, the ski area, and the Southern Nevada Conservancy) in the Mt.
Charleston Winter Alliance (MCWA). The MCWA was organized to promote public safety, including
timely emergency response, during winter months when sharp peaks in Kyle and Lee canyon visitation
occur. A recent press release from the MCWA advised winter visitors that “To ensure timely emergency
response and public safety, [NHP] and Las Vegas Metropolitan Police Department (Metro) monitor traffic
congestion and road conditions in both Lee and Kyle canyons and regulate access. Depending on traffic
volume and available parking, periodic road closures may occur on Nevada State Routes 156 (Lee Canyon
Road), 157 (Kyle Canyon Road) and 158 (Deer Creek Rd.).” The press release went on to advise ski-area
visitors to have their passes available to show law enforcement personnel monitoring traffic in order to
bypass road closures.
In short, the appropriate agencies are actively working to address traffic and parking issues in Lee Canyon,
and the MCWA recognizes that these issues are not caused by the ski area. To mitigate any adverse impact
of the proposed action on SR 156 traffic and parking, the Forest Service will continue to participate in and
support MCWA efforts.
3.12 LAND USE

Issue – Adjacent Land Uses: The ski area adjoins or is in close proximity to other permitted facilities (i.e.,
Camp Lee Canyon and McWilliams Campground). Additional year-round visitation associated with the
proposed infrastructure may result in property damage, disruption, or other adverse effects on these adjacent
land uses.
Indicators: A qualitative assessment of the potential for property damage or disruption of permitted uses
and the effectiveness of design criteria and proposed mitigation.

There are two permitted facilities on NFS lands adjacent to or in close proximity to the ski area, namely,
Camp Lee Canyon and McWilliams campground. While use of these areas is non-exclusive, damage and
disruption can occur when other members of the public enter these areas.
Camp Lee Canyon is a 17-acre camp operated by Clark County Parks and Recreation Department under
special use permit from the SMNRA. It is located adjacent to the ski area permit boundary on the northeast
side. The camps seven buildings were constructed in 1936 by the Works Progress Administration, and the
camp is included on the National Register of Historic Places as a historic district. The camp has sleeping
accommodations for 145 people and a variety of recreational amenities. It is used primarily by youth groups,
and use occurs sporadically throughout the year.
McWilliams Campground is a 45-acre Forest Service operated campground located adjacent to the ski area
permit boundary on the northwest side. The campground contains 75 single- and double-family sites with
picnic tables, grills and campfire rings. Sites accommodate both tent and recreational vehicle use. Flush
toilets, drinking water and trash collection are provided. Roads and parking spurs are paved. The
campground is open year-round with 14 campsites available in the winter, as well as winter parking for
snowplay.
There is no data on the frequency of incidents of property damage or disruption caused by ski area visitors
on adjacent facilities; however, anecdotal observations indicate that some incidents have occurred. Such
incidents are most likely limited to the winter season since the only summer activity that takes place near
the boundaries of the ski area is a single disk golf hole, north of the maintenance shop, near Camp Lee
Canyon. Use levels for the disk golf course are very low, and it is unlikely that the few participants in the
vicinity of Camp Lee Canyon are creating a substantial summer issue.
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During the winter, people have been known to sled down the hill on the east side of the ski area’s lower
parking lot. This unsanctioned run starts within the ski area permit boundary and ends within the Camp Lee
Canyon permit boundary. Skiers and snowboarders have also been observed coming down from slopes in
the proposed Chair 5 pod into Camp Lee Canyon and either hiking back up to the ski area or continuing
down through the camp to SR 156. Entry into Camp Lee Canyon can lead to property damage and can cause
disruption of camp activities, if the camp is in use.
Incidents of property damage or disruption by ski area visitors have not been reported at McWilliams
Campground. This is likely because there is no direct, downhill access from the parking lots or lift-served
terrain at the ski area to the campground.

Under this alternative, no development would occur at the ski area and any problems related to property
damage or disruption would remain as described above in the affected environment section.

Under the proposed action, summer activities at the ski area would increase substantially, and infrastructure
near Camp Lee Canyon and McWilliams campground would be developed. The new parking lot would be
constructed within approximately 70 feet of the permit boundary between Camp Lee Canyon and the ski
area. A single bike trail would be constructed on the slope approximately 450 feet above McWilliams
Campground.
It is unlikely that any bike-trail users would choose to go off-trail down toward McWilliams Campground
(see section 3.9). The majority of the new parking lot would not be used during the summer since it would
be providing stormwater control functions (see section 3.4). A few parking spaces near the new first aid
building and existing maintenance buildings would be used, but mostly by ski area employees. However, it
is likely that the overall increase in the number of people at the ski area during the summer would increase
the potential for property damage or disruption at Camp Lee Canyon.
In order to mitigate this increase, a fence and signage would be erected along the northeast permit boundary
between the ski area and Camp Lee Canyon. This fence would be approximately 500 feet long and span the
drainage below the new parking lot. The fence would not need to be a permanent installation and could be
removed during the winter to prevent snow damage. The fence would inform ski area visitors about the
boundary and deter casual access to Camp Lee Canyon; therefore, it does not need to be a substantial barrier.
During the winter, the potential for property damage or disruption at Camp Lee Canyon would increase due
to the increased number of skiers and snowboarders in the Chair 5 pod and the proximity of the new parking
lot to the camp. With the increased usage of the area there is a greater chance for ski area visitors to either
accidentally enter the camp or intentionally attempt to pass through the camp to SR 156.
In order to mitigate this increase, snow fencing would be erected along the north edge of the Chair 5 pod
ski runs and between the north edge of the new parking lot and the permit boundary. Signage would indicate
that the area beyond the fence is outside the ski area boundary. Such in-bounds area closures are common
at Forest Service-permitted ski areas.
With mitigation measures in place, implementation of this alternative would not result in a substantial
increase in the incidents of property damage or disruption at Camp Lee Canyon or McWilliams
campground.

Impacts related to property damage or disruption under this alternative would be the same as those described
for the proposed action.
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directly or indirectly by the proposed action and alternatives. Each of the cumulative actions described in
section 3.3 could have impacts that would temporally and spatially overlap with those of the proposed
action. Increased visitation in the upper canyon, particularly growth associated with the Dolomite-
McWilliams-Old Mill Campgrounds Reconstruction Project and the Foxtail Group Picnic Area
Reconstruction Project, would increase the potential for cumulative effects on property damage or
disruption of Camp Lee Canyon.
3.12.5 MITIGATION
The impacts described above require the following mitigation measures to be in place.
1. Construct a fence and signs along the northeast permit boundary between the ski area and Camp
Lee Canyon. This fence will be approximately 500 feet long and span the drainage below the new
parking lot. The fence does not need to be a permanent installation and may be removed during the
winter to prevent snow damage. The fence will inform ski area visitors about the boundary and
deter casual access to Camp Lee Canyon; therefore, it does not need to be a substantial barrier.
2. Erect snow fencing along the north edge of the Chair 5 pod ski runs. Signage will indicate that the
area beyond the fence is outside the ski area boundary.
3.13 OTHER DISCLOSURES

3.13.1 HEALTHY FOREST RESTORATION ACT
This proposed action would implement a land management plan and is not authorized under the Healthy
Forest Restoration Act. As a result, it is subject to subparts A and B of the Project-level Predecisional
Administrative Review Process (36 CFR 218).
3.13.2 FOREST PLAN AMENDMENT

As discussed in sections 1.3, 1.4, 1.5, and 1.6, a project-specific Forest Plan amendment to exempt the
proposed action and alternatives other than the no-action alternative from standards 0.31 and 11.57 is
necessary for Forest Plan compliance. Section 2.2.5 describes the amendment, and sections 3.5.6 and 3.6.6
describe in detail the effects on vegetation and wildlife, respectively, that establish the need for this
amendment.
As stated in section 1.4, the proposed action could not be revised, or an alternative developed, in a way that
complied with these standards and still met the stated purpose and need for action. Accordingly, if the
proposed amendment were not made, the project could not be authorized, and resource conditions would
remain as described in the affected environment discussions for each resource addressed in Chapter 3.
3.13.3 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY

NEPA requires that an EIS considers “the relationship between short-term uses of man’s environment and
the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). This includes using all
practicable means and measures, including financial and technical assistance, in a manner calculated to
foster and promote the general welfare, to create and maintain conditions under which man and nature can
exist in productive harmony, and to fulfill the social, economic, and other requirements of present and future
generations of Americans (NEPA, Section 101).
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Lee Canyon’s permit allocates the NFS lands occupied by the ski area to provision of recreation
opportunities through the term of the permit. This land use has some inherent impacts. This analysis
identifies several adverse environmental effects, but few have important implications for the long-term
productivity of the site. Surface and subsurface water systems are largely absent and would not be notably
affected. Changes in soil loss and fertility would be minimal. Vegetation changes would be reversible
through succession. The question here is whether this land use justifies any loss in long-term productivity
of the resources involved.
Through issuance of ski area permits, the Forest Service helps provide outdoor recreation for a high number
of visitors on a relatively small proportion of our NFS lands; in 1986, the most recent year for which Forest
visitor data is available, the SMNRA accounted for 22 percent of the total recreational site visits on the
TNF but involved only a small percentage of the Forest’s area. Lee Canyon is the only ski area on the
SMNRA, so Forest users have no other option for the types of recreation offered there.
In short, the potential impacts of this proposal on the long-term productivity of the ski area are minimal,
especially in relation to the value of the short-term use. No important distinction among the proposed action
and alternatives can be drawn.
3.13.4 UNAVOIDABLE ADVERSE EFFECTS

The preceding resource-specific analyses identify a range of impacts of the proposed action and alternative.
Where appropriate, these impacts are assessed – generally post mitigation – on the basis of some regulatory
or procedural scale or classification to determine their severity or importance. The purpose of this section
is to summarize adverse impacts that would be unavoidable. These are impacts that would not be eliminated
by design criteria or mitigation. While the analyses might conclude that these impacts were not severe or
important, they would be adverse nevertheless.

Given the project area’s steepness and erodible soils, a fairly high erosion risk is inherent. Soil disturbance
under these conditions can only elevate the erosion risk. As discussed in sections 3.4.3.2 and 3.4.3.3, the
suggested mitigation would maintain low risk levels for all elements except the ski runs in the Chair 5 and
Chair 8 pods. However, a low risk rating does not mean there would be no adverse effect. A major runoff
event occurring during or immediately following construction, when bare ground was exposed and physical
erosion-control measures were incomplete, would generate increased erosion.
As to the ski runs, these disturbances, totaling 70.7 acres under the proposed action and 56.8 acres under
the BCT alternative, would create moderate erosion hazard until revegetation was established. The lack of
an approved seed mix would prolong this period.
As discussed above, the ski area routinely repairs gullying on their ski runs, so this adverse effect on erosion
hazard would not be anything new, but the risk of erosion occurring would unavoidably increase
temporarily during and after construction, then remain somewhat higher until revegetation was complete.
3.13.4.2 Vegetation
The SMNRA supports a unique suite of plants and animals, many of which are only found there. This
limited distribution in itself makes most of them special-status species of one classification or another. The
ski area occupies a “biodiversity hotspot,” defined by the Forest Plan, and virtually any surface disturbance
has an adverse effect on at least potential habitat for some special-status species, if not on occupied habitat
or plants themselves.
As discussed in section 3.5.3.2, the proposed action would have a small adverse effect (i.e., disturb a small
proportion of the occupied habitat within the ski area) on 11 special-status plant species and a moderate
effect on one, Clokey’s eggvetch. These effects were a primary driver for development of the BCT
alternative, which affect the same suite of species but reduce the amount of habitat affected for nearly all
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of them. For Clokey’s eggvetch, the figure drop from 13 percent of habitat effected to 2 percent, a small
impact.
In terms of formal determinations, the proposed action “May impact individuals but is not likely to cause a
trend toward federal listing or loss of viability” for the 11 species and “May impact individuals and likely
to result in a trend toward federal listing or loss of viability” for Clokey’s eggvetch. Under the BCT
alternative, the former determination would apply to all 12 species.
This unavoidable adverse effect might be temporary. As discussed throughout the EIS (e.g., sections 2.2,
3.6.3.2, 3.6.3.3), one objective of the proposed development was to increase the amount and connectivity
of MCBB habitat. The same habitat supports a number of these special-status plant species. To the degree
that habitat improvement efforts are successful, this adverse effect would be reversed over time.
3.13.4.3 Wildlife
As discussed above under vegetation, the SMNRA and the ski area support a unique suite of species,
including wildlife as well as plants. This includes many endemic species. The proposed action would have
a small impact on 18 special-status wildlife species, including the federally listed MCBB. The BCT
alternative would reduce this to 14 species subject to small impacts due to habitat disturbance. The formal
determination for all but one of these species, under either alternative, would be “May impact individuals
but is not likely to cause a trend toward federal listing or loss of viability.”
The exception would be the federally listed MCBB. The Forest Service’s determination under both
alternatives is “this project may affect and is likely to adversely affect the MCBB or its designated critical
habitat.” However, that determination reflects immediate effects and, as discussed above, improving habitat
conditions for the MCBB was an objective in designing the proposed development. To the degree that that
objective is met, this adverse impact will be reversed over time. The adverse effects noted above for several
other special-status wildlife species may also be offset by MCBB habitat improvement.
3.13.3.4 Cultural Resources

As discussed in section 3.7.3 and in the Cultural Resources Narrative Report (Santarone et al. 2017)
prepared as part of this analysis, one previously identified prehistoric site was relocated, re-recorded, and
determined to be eligible for listing on the NRHP. The analysis concluded that under the no-action
alternative, no ski-area related activities would impact the site and that the proposed action and BCT
alternative would not affect the site. There would be no unavoidable adverse effects with regard to cultural
resources.
3.13.4.5 Scenery Resources

Section 3.8 concludes that the effects of the proposed action and the BCT alternative on the area’s scenic
integrity would be mixed. The base area is currently a striking departure from the natural landscape, and
the proposed new structures and facilities would increase the scope of the base area’s impact. However,
new structures would be designed and constructed in accordance with the SMNRA BEIG. As a result they
would blend better with the landscape and help establish a more consistent architectural theme for the ski
area.
Similarly, on-mountain infrastructure, particularly the Chair 5 and Chair 8 pods, would substantially
increase the footprint of ski area development. Two factors would mitigate this impact. First, the new
development would be a quantitative increase in the visual impact of existing facilities – basically more of
the same. Second, design criteria and required BMPs would help blend new ski runs with the natural setting.
While changes both at the base area and on the mountain would be consistent with viewers’ expectations
for a ski area, some people would likely perceive the expansion of infrastructure as an adverse effect. Design
criteria and BMPs would mitigate but not eliminate this effect.
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3.13.4.6 Recreation
The analysis of potential impacts on recreation documented in section 3.9 identifies the BCT as main
resource affected. This popular trail passes through the ski area now, but through a relatively undeveloped
portion of it. While trail users experience the sounds and views of ski area operations, most of these effects
are limited and distant. The proposed action would alter that scenario substantially by putting both winter
and summer infrastructure in close proximity to the trail. Trail use is considerably reduced in winter, but
those choosing to ski or snowshoe would have to share the trail with downhill skier traffic from the new
Chair 8 pod. Summer trail users would be exposed to views of the Chair 8 pod, the mountain coaster, the
zip line, and bike trails. The noise generated by the summer attractions – primarily from the riders – would
affect a substantial portion of the trail through the ski area.
These impacts were one of the primary considerations in developing the BCT alternative. It would reduce
winter impacts on the BCT by shortening the Chair 8 pod to provide separation from the trail. More
importantly, it would shift most of the summer infrastructure to the other side of the ski area, away from
the trail, substantially reducing the sights and sounds experienced by trail users. Nevertheless, the proposed
developments – particularly development of the Chair 8 pod – would affect the viewshed of the trail through
the ski area, and the dramatic increase in summer use of the ski area would affect the experience of BCT
users accustomed to a less active and active setting.
3.13.4.7 Safety
The safety analysis documented in section 3.10.3 addresses two issues, and both analyses indicate minor
unavoidable adverse effects. The first issue is increased risk to BCT summer users associated with the
proposed mountain bike trail system that would cross or pass near the BCT in four places. With suggested
mitigation in place to reduce collision hazard, the risk would remain low, but mitigation would not eliminate
it entirely. This minor risk does not warrant changing the layout of the mountain bike trail system.
Winter use of the BCT is much lower than summer use, but skiers returning to the base area from the Chair
8 pod could pose a collision risk to anyone coming up the BCT. This would be a minor but unavoidable
risk under the proposed action.
The BCT alternative would pose the same minor risk to summer BCT users, but by shifting the Chair 8 pod
upslope and constructing a separate, new egress skiway, it would eliminate the risk to winter BCT users.
The second safety issue is increased demand for emergency services, specifically ambulance service for
injured ski area visitors needing transportation to Las Vegas-area medical facilities. The analysis projects
61.8 more ambulance calls per season due to the projected growth in annual skier numbers. As accidents
would be more likely on peak skier days, an ambulance would probably be stationed at the ski area to
shorten the response time. However, the number of days requiring an ambulance to be on-site may increase.
The mountain bike trail system might attract up to 25,000 visitors per year and generate a projected 25
additional ambulance calls. That would bring the total increase in ambulance calls to 87.
This increase in demand for emergency services, particularly the logistics necessary to station an ambulance
at the ski area during busy winter periods, would be a minor but unavoidable effect of the proposed action.
This scenario would not change under the BCT alternative.
3.13.4.8 Traffic
The traffic issue addressed in this analysis (section 3.11) is additional winter visitation associated with the
proposed infrastructure may contribute to traffic congestion on the Lee Canyon highway (SR 156). Under
the proposed action, skier numbers are projected to increase from 1,880 to 2,850 on peak days. At an
industry-standard of 2.5 skiers per car, this would equate to 388 additional vehicles on SR 156, a 12 percent
increase over the last peak-day traffic count in 2005. The majority of skier vehicles would be on the road
during lower traffic periods (i.e., 1.5-hour periods around the ski lift start time of 9 a.m. and the closing
time of 4 p.m.), but overall the additional vehicles are projected to prolong periods of congestion and low
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LOS at existing choke points like Lee Meadows. This adverse effect would be the same under the BCT
alternative. In the near term, it could only be avoided by action on the part of the NDOT to improve traffic
flow on SR 156.
3.13.4.9 Land Use

The primary concern addressed in this analysis was the potential for vandalism or disruption at adjacent
permitted facilities, particularly Camp Lee Canyon, associated with increased year-round visitors to the ski
area (section 3.12). The analysis concludes that the potential for such effects could increase with visitation,
but that proposed mitigation (i.e., fences to deter entry) would minimize it. However, some small increase
in the potential for property damage or disruption at the camp would remain. The BCT alternative would
not be different in this regard.
3.13.5 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

Irreversible commitment of a resource means that, once committed to a given use, the resource is lost to
other uses. In general, this term applies to non-renewable resources (e.g., minerals, geologic features, or
historic sites) or to resources which are renewable only over a very long period of time (e.g., soil fertility
or perhaps old-growth forests). Most of the impacts identified in this analysis do not fall in this category.
If the decision were made to terminate the resort’s permit, the site could be reclaimed, and most resource
functions could be returned to their previous levels. However, there may be some exceptions:
• Soil productivity at some of the larger grading areas, such as the Chair 8 pod and the new parking
lot, would likely not return to previous levels for a long time, if ever.
• Succession to pre-disturbance vegetation types would also be a slow process, particularly for old-
growth forest stands.
Irretrievable commitments of resources involve lost use or productivity of resources. Any lost use or
production resulting from this proposal’s commitment of resources to recreation development would fall in
this category. This could include the timber production lost to maintenance of open ski runs, access roads,
and trails. However, the productivity of the forest stands in question is low, and logging is not permitted in
the SMNRA.
While this proposal involves both irreversible and irretrievable commitments of resources, most of the
commitments were made decades ago when the ski area was developed, and they are likely to continue.
The incremental impact of this proposal would be minimal, and no important distinctions can be made
among the proposed action and alternatives in this regard.
3.13.6 INCOMPLETE AND UNAVAILABLE INFORMATION

No information necessary to appropriate analysis and disclosure of the environmental effects of the
proposed action and alternatives was incomplete or unavailable.
3.13.7 ENERGY REQUIREMENTS AND CONSERVATION

Implementation of the proposed action or BCT alternative would increase the ski area’s energy demands in
the short-term due to the need for construction vehicles and machinery. In the longer term, the additional
ski lifts and buildings would consume energy, but the increase would be offset by removal of less efficient,
older facilities with modern, high-efficiency technology. Lee Canyon is a participant in the National Ski
Areas Association’s Climate Challenge program, which is dedicated to helping participating ski areas
reduce greenhouse gas emissions and reduce costs for energy use. Energy use and conservation would be
similar under the proposed action and the BCT Alternative.
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3.13.8 POLLINATORS
A Presidential Memorandum was signed June 20, 2014, establishing the Pollinator Heath Task Force
(PHTF), calling for the creation of a national pollinator health strategy, and directing federal land
management agencies to review any new or renewing land management contracts and grants for the
opportunity to include requirements for enhancing pollinator habitat (Obama 2014). The resulting 2015
National Strategy to Promote the Health of Honey Bees and Other Pollinators discusses Forest Service
efforts to, among other things, restore pollinator habitat through prescribed fire and silvicultural thinning
of forested stands and educate the public about pollinators (PHTF 2015).
The USDA-Agricultural Research Service’s Bee Biology & Systematics Laboratory completed a study in
Clark County to determine which pollinator species are present in the area (USDA-ARS 2006). The results
of this study indicate that Clark County is a hotspot of bee diversity, with over 600 bee species alone.
Additional pollinators inhabiting the area likely include birds, bats, and other insects, including the special-
status butterflies discussed above in section 3.6.3. This diverse group pollinates a wide number of plant
species. Both the proposed action and BCT alternative would decrease tree cover in forested stands on
proposed ski runs, lift alignments, and in gladed areas. Those treatments would likely increase plant species
diversity and likely benefit pollinator species.
Climate change could temper this positive conclusion. Recent research on climate change effects on the
HTNF (Tausch 2011) and on western lands managed by the Forest Service and the National Park Service
Halofsky et al. 2018) indicates several relevant conclusions. First, in alpine ecosystems forbs are important
for bees and other pollinators. Second, changes in the winter climate can expose alpine and subalpine plants
and seeds to frost damage, disease outbreaks, and habitat fragmentation, and can result in plant phenology
that is out of sequence with pollinators. Third, these effects may favor generalist pollinators over alpine
specialist pollinators. These include some of the butterflies endemic to the Spring Mountains.
Overall, the net effect of the proposed development on pollinators will depend on the degree to which alpine
forb communities respond to the removal of tree canopy, which has the potential to increase and link MCBB
habitat, as well as habitat for other pollinators in the area. A good response would offset some of the adverse
effects of climate change.
3.14 CONSISTENCE WITH LAWS, REGULATIONS, POLICIES,

AND PROCEDURES
3.14.1 ENDANGERED SPECIES ACT
The analysis of potential impacts on federally listed plant and wildlife species documented in sections 3.5
and 3.6, respectively, and in the BA prepared for this analysis document compliance with the ESA. The BA
concludes that both the proposed action and BCT alternative may affect and are likely to adversely affect
the MCBB or its designated critical habitat. However, as discussed in section 3.6, the net effect on this
species is anticipated to be beneficial over time.
3.14.2 CLEAN WATER ACT

The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological
integrity of all waters of the U.S. in order to protect their beneficial uses – in this case, those assigned by
the Nevada Department of Environmental Protection (NDEP). Beneficial uses reflect resources or activities
that would be directly affected by a change in water quality or quantity.
As discussed in the soil, water, and watershed resources analysis (section 3.4), the project area includes no
live water and has no surface hydrologic connectivity with waters outside the project area. These factors
limit the scope of potential impacts on water quality. The disturbed site rehabilitation practices, design
criteria, and mitigation measures (section 2.6 and Appendix B) include a requirement for HTNF approved
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site rehabilitation plans incorporating BMPs, including those described in Ski Area BMPs: Guidelines for
Planning, Erosion Control, and Reclamation (Forest Service 2001). However, given the lack of surface
water and hydrologic connectivity, such mitigative considerations bear more on soil loss and productivity
than water quality.
The only issue addressed in the water and watershed resources analysis (section 3.4.3) that falls under the
purview of the CWA is the potential for groundwater contamination associated with the proposed parking
lots. Required permitting would ensure that the septic system for the proposed first aid building complied
with regulations. As this analysis concludes, no reduction in groundwater quality would occur as a result
of these actions under the proposed action (section 3.4.3.2) or the BCT alternative (section 3.4.3.3).
3.14.3 AMERICANS WITH DISABILITIES ACT

In accordance with Forest Service regulations, compliance with the accessibility guidelines of the
Americans with Disabilities Act of 1990 (ADA) and Uniform Federal Accessibility Standards (UFAS) of
Section 504 of the Rehabilitation Act of 1973 apply to the design of structures proposed as part of this
project. The ADA applies because Lee Canyon operates as a “public accommodation,” that is, it is a
business open to the public. Section 504 applies because the ski area operates under a special-use permit
authorized by a federal agency, the Forest Service. Implementation guidelines for Section 504 that apply to
recreation special-use permit holders are located in 7 CFR 15b.
UFAS and ADA accessibility guidelines were combined in November 8, 2005, and are now known as the
Architectural Barriers Act Accessibility Standard (ABAAS). The ABAAS replaces the former guidelines
as the current standard for federal agencies, including the Forest Service. These guidelines are included in
the Accessibility Guidebook for Ski Areas Operating on Public Lands – 2012 Update (Forest Service
2012b). HTNF engineering review of construction plans prior to notification to proceed will ensure
compliance with ABAAS.
3.14.4 EXECUTIVE ORDER 11644 - USE OF OFF-ROAD VEHICLES ON PUBLIC

LANDS
Public use of off-road vehicles is not authorized within Lee Canyon’s permit area. Only the ski area may
use such vehicles in conducting authorized activities. The proposed action and BCT alternative would not
alter this.
3.14.5 EXECUTIVE ORDERS 11988 AND 11990 - PROTECTION OF FLOODPLAINS

AND WETLANDS
As discussed in the soil, water and watershed analysis (section 3.4), there are no wetlands in the project
area and thus no potential for direct effects. The analysis states that there are also no surface waters and
thus no floodplains subject to direct effects. The lack of surface hydrologic connectivity effectively
eliminates the potential for indirect impacts on these resources.
3.14.6 EXECUTIVE ORDER 13186 - PROTECTION OF MIGRATORY BIRDS

This order and the protection it affords to migratory birds is discussed in the wildlife analysis (section 3.6).
That analysis concludes that potential impacts on migratory birds would be eliminated by the addition of
design criterion 12, which requires trees to be cut outside of the nesting season unless they are specifically
determined to be free of nesting birds. A small fraction of available habitat for forest nesting species would
be lost under either alternative, but populations would not be impacted given the large amount of habitat in
the area.
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3.14.7 EXECUTIVE ORDER 12898 - ENVIRONMENTAL JUSTICE

The proposed action or BCT alternative would not have a disproportionately high or adverse effect on
minority or low-income populations. Scoping did not reveal any issues or concerns associated with the
principles of environmental justice. No mitigation measures to offset or improve adverse effects on these
populations have been identified. All interested and affected parties will continue to be involved with the
public involvement and decision process.
3.14.8 USDA CIVIL RIGHTS POLICY

The proposed action and BCT alternative would not result in any civil rights impacts on Forest Service
employees, visitors to Lee Canyon, or the general public. All would be free from reprisal or discrimination
based on race, color, national origin, sex, religion, age, disability, sexual orientation, marital or familial
status, political beliefs, parental status, receipt of public assistance, or protected genetic information.
3.14.9 PRIME FARMLAND, RANGELAND, AND FOREST LAND

The proposed action and BCT alternative do not include any use of prime farmland or rangelands, and the
term “prime forest land” does not apply to NFS lands. Under the proposed action and BCT alternative,
NFS lands would be managed with sensitivity to the effects on adjacent lands.
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CHAPTER 4: LIST OF PREPARERS
Name Position Contribution

Forest Service Team
Donn Christiansen SMNRA Area Manager Project oversight.
Deborah MacNeill SMNRA Area Manager Project oversight.
Jim Winfrey Land Management Planner Project NEPA Lead.
Chris Linehan Recreation Staff Officer Project Interdisciplinary Team Lead.
Developed Recreation
Jonathan Stein Project Interdisciplinary Team Lead.
Director
Jim Hurja Forest Soil Scientist Watershed resources review and oversight.
John McCann Forest Hydrologist Watershed resources review and oversight.
Forest Botanist/Invasive
Dirk Netz Vegetation resources review and oversight.
Plant Program Supervisor
Corrin Floyd District Botanist Vegetation resources review and oversight.
Charles Woodard Wildlife Biologist Wildlife resources review and oversight.
Butterfly species analysis review and
Katy Gulley District Ecologist
oversight.
Wildlife Program
Kristie Boatner Manager/Forest Wildlife Wildlife resources review and oversight.
Biologist
Kelly Turner District Archaeologist Cultural resources review and oversight.
Cirrus Ecological Solutions, LC Team
Project management, NEPA oversight,
Neal Artz Project Manager QA/QC review, and preparation of cultural,
scenery, and recreation analyses.
Management assistance and preparation of
Assistant Project Manager
Matt Westover wildlife, safety, traffic, and land use
and Wildlife Biologist
analyses.
Preparation of soil, water, and watershed
Eric Duffin Hydrologist
resources analysis.
Botanist and Wetland
Tim Royer Preparation of vegetation analysis.
Specialist
Document Production Document production and preparation of the
Judy Seamons
Specialist project record.
Cannon Heritage Consultants, Inc.
Completion of cultural resources survey and
Ken Cannon Archeologist
report.
JUB Engineers, Inc.
Hydrological modeling and run-off
Nathan Smith Project Engineer
projection report.
Tatanka Historical Associates, Inc.
Completion of historical structures survey
Ron Sladek Archaeologist
and report.
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CHAPTER 5: CONSULTATION AND

COORDINATION
5.1 PUBLIC SCOPING
On March 23, 2017, the Humboldt-Toiyabe National Forest (HTNF) issued a public scoping notice
summarizing Lee Canyon’s proposed project elements (the proposed action) and inviting comments
regarding the scope of the associated NEPA review. The elements included in the proposed action are
included in Lee Canyon’s current MDP, accepted by the HTNF in June 2011.
Information regarding the scoping period, available materials for review, and a public meeting was sent to
the agencies, organizations, and individuals on the HTNF mailing list. The scoping notice was posted on
the HTNF website at https://www.fs.usda.gov/project/?project=50649 and made available on CD or in
hard-copy form to anyone requesting it.
The scoping period began on March 23, 2017, when a Notice of Intent to Prepare an Environmental Impact
Statement (NOI) was published in the Federal Register (Vol. 82, No. 55, p. 14865). The scoping period
closed 45 days later on May 8, 2017. The scoping notice, NOI, comment letters, and scoping report
identifying the issues raised and their disposition in the EIS are included in the project record.
Comment letters were received from the following five agencies, six organizations, and 89 individuals
(including multiple letters from single individuals):
Agencies:
• Bureau of Land Management, Las Vegas Field Office
• Mt. Charleston Fire District
• Nevada Department of Wildlife, Southern Region
• Nevada Department of Conservation and Natural Resources, Division of State Lands, State Land
Use Planning Agency, State Clearinghouse
• National Park Service
Organizations:
• Red Rock Audubon Society, Conservation Chair
• Center for Biological Diversity, Nevada Wildlife Advocate
• Colorado River Indian Tribes, Tribal Historic Preservation Office
• Friends of Nevada Wilderness, Southern Nevada Director
• International Mountain Bicycling Association, Southwest and Alaska Regional Director
• The Nature Conservancy, Southern Nevada Field Office, Mojave Desert Program Director
Individuals:
• Andrea Acosta • Barrett Casella • Bobbye and Pat
• Adam • Ian Cattanach Fitgibbons
• Mike Angel • Chad • Bill Freberg
• Jeffrey Bagdade • Jeannette Chapman • Ken Freeman
• Ronald Beehler • Thomas Dellavalle • Robert Furtek
• Greg Bernhardt • Corey DeMaio • Andria Garbiso
• Kay Blackwell • Lynn Dickton • Jim Gentleman
• Jim Boone • Justin Doucette • John Giacomello
• Steve Brittingham • June Egi • Michelle Gregory
• Victoria Brogan • Frank Evans • Pam Gullickson
• Skip Canfield • Maria Gutierrez
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 Steve Hartley  Ron McMenemy  Jamie Schofield

 George Hasse  Ryan McPhee  Read and Carol
 Hermi Hiatt  Troy Meier Schrotel
 Jeanette Hogue  Brenda Morrow  Robert Sherman
 Tim Hopson  Robert Morrow  Richard Sinden
 Brian Johnson  Susan Murphy  Neal and Mora
 Kevin Johnston  Stephanie Myers Snyder
 Jean Perry-Jones  Richard Naito  Harlan Stockman
 Lynn Kantor  Thomas O’Neill  Lisa Taylor
 David Kress  Jason Otter  Sebastian Trost
 Liz Langille  Janine Packer  Robert Ungar
 Martha Law  Robin Padden  Joanne Urioste
 Kurtis Lee  Tom Padden  John Ward
 Lisa Lorenzo  Rita Peerenboom  Judy Warner
 Jack Mabry  Jean Public  Timothy Williams
 Dolores Mack and  Natalie Rath  Quinn Winter
Norman Angell  Richard Rosenheim  Jose Witt
 Mike McDonald  Sam Scheller  Kathleen Womack
5.2 NOTICE AND COMMENT ON THE DRAFT EIS

The HTNF prepared a Draft Environmental Impact Statement (DEIS) addressing proposed implementation
of Lee Canyon Ski Area Master Development Plan Phase I, in accordance with agency’s NEPA procedures
(36 CFR 220). A Notice of Availability (NOA) for the Draft EIS was published in the Federal Register on
August 17, 2018, initiating a 45-day comment period, in accordance with 36 CFR 218 Sub-parts A and B.
The document was also posted to the HTNF website at https://www.fs.usda.gov/project/?project=50649.
Specific notifications were sent to those who provided scoping comments.
On August 17, 2018, an email bulletin was also sent to 466 individuals, organizations, agencies, and others
on the project mailing list notifying them of the DEIS’s availability on the Forest Service website and
providing instructions on submitting comments. Hard copies of the DEIS were made available by the Forest
Service to those requesting a copy. A Legal Notice of Proposed Action was published in the Las Vegas
Review-Journal on September 19, 2018. Comments were received from 9 agencies, 8 organizations, and
344 individuals.
A report identifying commenters, detailing the comments received, and providing HTNF responses to
substantive comments, in accordance with agency regulations at 36 CFR 215.6, is attached as Appendix C.
Since the full list of commenters on the DEIS is included in Appendix C, it is not reproduced here.
5.3 OTHER CONSULTATION

5.3.1 ENDANGERED SPECIES ACT SECTION 7
As discussed in the wildlife analysis (section 3.6), the HTNF consulted with the FWS regarding impacts on
the endangered MCBB. Informal consultation with FWS biologists and administrators began in 2014 when
Forest Service, FWS, and contractor personnel met to discuss the ski area’s development plans and how
they could be refined to reduce potential adverse effects and increase benefits for the MCBB, listed as
endangered in 2013.
A BA was prepared based on ongoing interaction among these three entities, addressing potential effects
of the BCT alternative on the MCBB (Forest Service 2019a).
185
Formal consultation between the HTNF and the FWS was initiated on July 31, 2019, with the submittal of
the BA. Between July 31 and December 13, 2019 (135-day consultation period), the FWS will prepare a
biological opinion (BO) based on the BA and conduct any additional consultation necessary. The BO will
document the FWS opinion as to whether or not the preferred alternative is likely to jeopardize the
continued existence of the MCBB or result in the destruction or adverse modification of critical habitat.
The BO may also include an amount of incidental take of MCBB that will be permitted along with
mitigation measures and monitoring requirements. Consultation documentation will be included in the
project record.
5.3.2 NATIONAL HISTORIC PRESERVATION ACT SECTION 106

As discussed in the cultural resources analysis (section 3.7), all consultation regarding heritage resources
required under the National Historic Preservation Act and Executive Order 11593 has been completed. A
specialist report addressing the Big Horn Lodge at the ski area (Sladek 2017) and another dealing with the
remaining elements of the proposed action were submitted for State Historic Preservation Office (SHPO)
review. The SHPO concurrence letter confirming the determination of no adverse effect was issued October
14, 2019 and is included in the project record (SHPO 2019).
5.3.3 TRIBAL CONSULTATION

Also discussed in section 3.7, government-to-government consultation directed by Executive Order 13175
has been conducted. On April 27, 2017, the SMNRA Area Manager met with the Nuwuvi Working Group
(NWG) that is made up of representatives from the seven Southern Paiute bands whose ancestral home is
the Spring Mountains. This working group has been designated to represent the various bands and to
provide input on projects and issues related to the SMNRA. The Area Manager made a brief presentation
of the proposed ski area developments offered a site visit to view the area.
On August 23, 2018, the SMNRA provided an overview of the proposed action to the NWG at a Bi-Annual
Meeting. NWG members described the cultural significance of the area and expressed interest in helping
to properly evaluate the proposed undertaking. Tribal representatives reminded the SMNRA officials of
their April 2017 request for a site visit and a meeting. In response, the SMNRA scheduled a tour and
meeting for the NWG, SMNRA, and project proponent on October 26–28, 2018, to ensure tribal comments
could be considered prior to completing the FEIS. Concurrently, the SMNRA sent letters to Tribal
leadership and NWG members to maintain appropriate government-to-government consultation within the
expedited timeline.
Based on these activities, the NWG presented formal comments to the SMNRA in December 2018. The
SMNRA reviewed those comments and scheduled another meeting to discuss them with the NWG and
project proponent on June 25, 2019. The FEIS was revised based on the outcome of that meeting with
additional analysis of cultural issues and identification of appropriate mitigation. Interaction with the
Nuwuvi is ongoing.
The Coalition of Colorado River Indian Tribes responded to the public scoping notice in March 2017 and
requested that cultural resources be avoided if feasible and that they be contacted in the event that any
human remains or cultural resources are discovered during construction. As documented in EIS section
3.7.3, avoidance of cultural resources was incorporated into project planning. In order to address
undiscovered cultural resources, design criteria have been included in section 2.6.
186
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193
194
APPENDIX A: FOREST SERVICE STANDARDS

AND GUIDELINES
Table A-1. Relevant standards and guidelines from HTNF Forest Plan Amendment 5, General
Management Plan for the SMNRA.
In
# Relevant Standards & Guidelines Compliance
(Y, N)
0.16 Use seed mixtures or seedlings for site rehabilitation, fire rehabilitation, or Y
permit requirement, in order of preference: (Guideline)
1. Native plants;
2. No seeding (only if erosion is not a serious concern and there is no
cheatgrass invasion);
3. Non-persistent (sterile) exotics;
4. Persistent exotics.
0.24 Reseed/rehabilitate at a minimum all disturbed areas outside Wilderness and Y
WSAs meeting the following criteria (Standard):
LTA Size Slope
Creosote, Blackbrush >50 acres any
Creosote, Blackbrush ≤50 acres 20%
Pinyon-Juniper, Mixed >100 acres any
Conifer
Pinyon-Juniper, Mixed ≤100 acres 25%
Conifer
Notes on 0.24: Both the proposed action and BCT alternative include disturbed areas of mixed conifer
where slopes are greater than 25 percent. Section 2.6 of the DEIS and Appendix B include design
criteria and mitigation measures for rehabilitating all disturbed areas.
0.27 All species listed as candidates for the federal threatened or endangered Y
species list, all species listed as protected rare, endangered, and critically
endangered by the State of Nevada, and all Forest Service sensitive species
will be considered 'species of concern' and treated as if they were on the
Forest Service sensitive species list. (Standard)
0.29 Limit negative impacts to all species of concern due to management Y
activities. Enclosed species list is the current (9/96) list of species of concern.
(Guideline)
Notes on 0.29: Section 2.6 and Appendix B include design criteria and mitigation measures intended to
limit negative impacts on species of concern. The biological assessment prepared for this project
discusses planning-phase design changes that were made in order to limit negative impacts and
promote beneficial impacts on the MCBB.
195
Table A-1 (cont’d). Relevant standards and guidelines from HTNF Forest Plan Amendment 5,
General Management Plan for the SMNRA.
In
(Y, N)
0.31 New roads, administrative facilities, and developed recreation sites other than N
low impact facilities (trails, trailhead parking, signs, restrooms, etc.) will be
outside a 100-yard buffer zone around known Clokey’s eggvetch and rough
angelica populations or potential habitat, and outside biodiversity hotspots
(defined as areas of particular diversity or sensitivity) (see Map 4 and Map
5). (Standard)
Notes on 0.31: As discussed in sections 1.6 and 3.5.6 of the DEIS, the entire ski area is within a
biodiversity hotspot, and elements of the proposed action and BCT alternative would be within the
100-yard buffer for Clokey’s eggvetch. Bringing the proposed action or BCT alternative into
compliance with this standard would require a project-specific Forest Plan amendment, as discussed in
sections 1.3, 1.4, and 1.6.
0.36 Retain all snags that do not pose a threat to public safety or extreme fire Y
danger. Snags are retained to provide habitat for cavity nesting animals and
animals that feed upon the insects living within dead trees. Retain a minimum
of 5 snags per acre in late seral stages of the Pinyon/Juniper, Mixed Conifer,
and Bristlecone Pine Land Type Associations in all cases. (Standard)
0.68 Educate the public to the sensitivity of endemic species of the Spring Y
Mountains, the importance of diversity, the significance of the Spring
Mountains' biodiversity, and how to recreate without impacting these
resources. (Guideline)
Notes on 0.68: Mitigation measures in section 3.5.5 of the DEIS address public education programs
that will be instituted at the ski area.
11.7 Where possible, control access to, and revegetate areas that are adjacent to Y
recreation developments and have slopes greater than 25 percent. (Guideline)
Notes on 11.7: Section 2.6 of the DEIS and Appendix B include design criteria and mitigation
measures for rehabilitating all disturbed areas.
11.8 Close and rehabilitate trail to and "Gary Abbot Campground" site. Close area Y
to overnight use. (Standard)
11.9 Revegetate and restore understory at appropriate locations within developed Y
recreation areas and new administrative sites consistent with defensible space
(i.e., fire safety) guidelines. Where possible, control access using temporary
barriers at locations where revegetation efforts are occurring. (Guideline)
Notes on 11.9: Section 2.6 of the DEIS and Appendix B include design criteria and mitigation
measures for rehabilitating all disturbed areas.
11.12 Designate ski area sub-basin visual quality objective as partial retention. Y
(Guideline)
196
Table A-1 (cont’d). Relevant standards and guidelines from HTNF Forest Plan Amendment 5,
General Management Plan for the SMNRA.
In
(Y,N)
11.13 Work cooperatively with federal, state and local agencies to designate State Y
Highways 156, 157, 158 as state and/or federal scenic byways. Protect the
scenic viewshed of State Highway 156, 157, and 158 to maintain naturally
appearing scenery. (Guideline)
11.28 Discourage snow play, where possible, in unsafe and unmanaged areas. Y
(Guideline)
11.35 Address user conflicts on Bristlecone Trail through a site specific planning Y
involving US Fish and Wildlife Service, trail users, and interested groups.
(Guideline)
Notes on 11.35: Section 3.10 of the DEIS addresses user conflicts on the BCT.
11.43 Maintain at least 10 parking spaces at the Bristlecone Trailhead available at Y
all times to trail users during summer operations at the ski area. (Standard)
11.57 Allow limited expansion of ski area in Lee Canyon and enhancement of N
skiing opportunities and facilities within the scope of an approved master
development plan and under the following constraints: (Standard)
1. Expansion occurs within the existing sub-basin.
2. Does not impact any threatened, endangered, or sensitive species or
species of concern, or its habitat.
3. Expansion is commensurate with development of additional parking
in the lower Lee Canyon area, and shuttle services.
4. Expansion incorporates defensible space design and fire safe
facilities.
5. Where consistent with other standards and guidelines.
Notes on 11.57: “Enhancement of skiing opportunities and facilities” would occur under both the
proposed action and BCT alternative. No expansion of the ski area would take place since all elements
of both the proposed action and BCT alternative would be within the existing permit area. As discussed
in sections 3.5 and 3.6 impacts on one endangered species and several species of concern would occur
under both the proposed action and BCT alternative. Section 1.6 states that the proposed action and
BCT alternative include a 500-vehicle parking lot at the ski area, precluding the need for down-canyon
parking and shuttle service. Based on these considerations, as discussed in sections 1.3, 1.4, and 1.6, a
project-specific Forest Plan amendment would be required to bring either the proposed action or BCT
alternative into compliance with this standard.
11.68 Provide additional mountain bike trail opportunities, within the constraints of Y
the biodiversity hotspots. (Guideline)
Notes on 11.68: The analyses in sections 3.5 and 3.6 indicate that the proposed action and particularly
the BCT alternative (with its lower level of impacts across all species) can be implemented within the
constraints of the biodiversity hotspots that encompass the ski area.
197
APPENDIX B: MITIGATION MEASURES

See section EIS 2.6 for design criteria pertaining to each resource.
SOIL, WATER, AND WATERSHED

Pre-Construction
1. Conduct appropriate soil and water studies, including modeling, to support design of runoff and
erosion control structures. Provide documentation to justify the design life.
2. Develop engineering drawings for each runoff and erosion control structure described in a project
plan. Include plan and profile views of structures as appropriate.
3. Comply with all federal, state and local codes related to construction disturbance and runoff from
construction sites. As required, develop and implement an erosion control and sediment plan that
covers all disturbed areas, including borrow, stockpile, skid trails, roads, or any areas disturbed by
development activities.
4. Design and locate parking, staging, and stockpiling areas of appropriate size and configuration to
accommodate expected vehicles and avoid or minimize adverse effects to adjacent soil, water
quality, and riparian resources.
5. Coordinate all phases of sanitation system management (planning, design, field surveys and testing,
installation, inspection, operation, and maintenance) with appropriate agencies to ensure
compliance with applicable regulations.
6. Locate ski area facilities (including buildings, runs, and lifts) on stable geology and soils to
minimize risk of slope failures.
7. Develop an erosion structure maintenance schedule showing structures needing annual
maintenance and those where non-recurring maintenance is expected. Display hand-crew or
machine maintenance if appropriate.
8. Plan projects to minimize re-entry after the site is stabilized.
Construction
9. Limit the amount of exposed or disturbed soil at any one time to the minimum necessary. Define
outer boundaries of disturbance with markers. Install sediment and stormwater controls prior to
disturbance where practicable.
10. When topsoil is present or can be salvaged, remove and stockpile with appropriate cover and
erosion control methods. Consult Forest Service soil scientist for determination of presence of
viable topsoil. Revegetation specifications and seed mixes must be approved by the Forest Service.
11. Limit operation of equipment when ground conditions could result in excessive rutting, soil
puddling, or runoff of sediments.
12. Confine all light vehicle traffic, parking, staging, and stockpiling materials to designated areas to
minimize ground disturbance. Heavy equipment (e.g. feller buncher, dozer, etc.) will be used but
also rely on helicopters to deliver lift towers and place equipment.
13. Consider over the snow removal of large trees when conditions allow. Small trees, branches and
other small residue created during clearing or glading activity will be chipped, mulched, burned, or
moved off site. Avoid damage to remaining trees and root systems adjacent to cut slopes and
cleared areas.
198
14. Prevent water from running down ski run prism particularly on steep grades (20 to 40 percent) and
from accumulating on gentle slopes (0 to 30 percent). Water bar spacing will account for slope as
follows:
Slope (%) Spacing (feet)
2% 250
5% 150
10–30% 100
>30% 75
15. Prevent water from running down roads and trails using water bars and rolling dips with a cross-
slope of 2 to 5 percent. Minimize cross slopes in areas where infiltration is a possible method to
reduce runoff. Water bars, rolling dips and culverts will be inspected and repaired on a weekly basis
during construction. Ruts will be repaired immediately.
16. Infiltration trenches shall be installed to intercept runoff from loading and unloading areas for ski
lifts, zip lines, mountain coasters and any outdoor locations where people will gather. Where soil
conditions permit (i.e. areas where soils are not cobbly or rocky) use erosion control mat to protect
any cut and fill areas associated with these locations.
17. Construct modified water bars across existing ski slopes to prevent the concentration of water flow,
act as micro-infiltration ditches and divert runoff to undisturbed terrain. Where feasible, use a
horseshoe design concept for waterbars and ditches with the tailing off ends of the structures at a 5
to 7 percent slope into the naturally vegetated areas.
18. Whenever possible, place excavated material on the uphill side of trenches and water bars. Manage
material placement to avoid trapping or concentrating water flow during construction. Fill trenches
with a 2-inch surcharge / berm to allow for settlement. Construct water bars over trenched areas as
in ski runs.
19. Use correctly installed silt fence or straw wattle to prevent sediment from entering existing drainage
channels, for projects within 50 feet of existing channels.
20. Use a lined ditch to transport water away from structures or areas where standard mitigation
strategies are not possible due to slope.
21. Use diversions ditches as needed to divert water away from ski run segments where both sides of
the run slope inward and prevent discharge from modified water bars. A mid-slope diversion ditch
may also be necessary to move runoff away from the ski run.
22. Protect any point of water discharge (e.g. trenches, ditches, water bars) with riprap or other methods
to slow water velocity and disperse runoff.
Post Construction Restoration/Maintenance
23. Fill material for storm damage repair will be sourced from areas that collect sediment after storms.
Essentially, material eroded off slopes will be collected and replaced.
24. Ensure that permit holder-owned and other authorized drinking water systems on NFS lands are
operated and maintained according to direction in FSM 7423.
25. Consider amending soil with mulch (e.g. wood chips), compost, mycorrhizal fungi inoculants and
other products to provide added nutrients, promote revegetation success, and to increase infiltration.
Utilize irrigation where appropriate.
199
26. Use and maintain surfacing materials suitable to the trail site and use to withstand traffic and
minimize runoff and erosion. Pay attention to areas where high wheel slip (curves, acceleration,
and braking) during motorized use generates loose soil material.
27. Install suitable stormwater and erosion control measures to stabilize disturbed areas and waterways
before seasonal shutdown of project operations or when severe or successive storms are expected.
28. Maintain the natural drainage pattern of the area wherever practicable.
29. Use and maintain suitable measures to collect and contain oil and grease in larger parking lots with
high use and where drainage discharges directly to channels.
VEGETATION
1. Install interpretive signs in prominent locations with information about special-status plant and
wildlife species and their habitat, including reminders to stay on designated trails.
2. Include text on summer trail maps reminding visitors to stay on designated trails in order to protect
special-status plant and wildlife species and their habitat.
3. Verbally remind visitors renting equipment, purchasing lift tickets, or asking for trail information
to stay on designated trails in order to protect special-status plant and wildlife species and their
habitat.
4. Install rope lines or signs to minimize entry into suitable special-status plant and wildlife species
habitat near high traffic areas.
5. Employ preventative management measures for the proposed projects to reduce the risk of
introduction or spread of undesirable plants into the area. Monitor the area for at least 3 consecutive
years and provide for control of new infestations.
WILDLIFE
1. In order to ensure that these design criteria and mitigation measures are understood and followed,
assign a qualified biologist (see BA Appendix B for “qualified biologist” definition) to be on site
when construction begins to educate contractor and construction crews, and periodically to ensure
that mitigation measures are being followed throughout project implementation. These mitigation
measures have been compiled into an implementation table for use by managers and biologists to
assure compliance during implementation (BA Appendix C). The project will be monitored as
required by the Humboldt-Toiyabe National Forest Land and Resource Management Plan and
supplemental General Management Plan for the SMNRA, and as outlined in BA Appendix B.
2. Establish and mark suitable habitat, as described in BA Appendix B, prior to implementation of
construction activities in an area.
3. Wherever practical, avoid impacting marked suitable MCBB habitat within the construction
disturbance area. If areas of marked habitat must be disturbed, delineate the disturbed habitat and
subtract the acreage from the incidental take allowance described in the determination section of
the BA.
4. Do not stage equipment or materials within suitable MCBB habitat.
5. Do not store or chip slash (i.e., small woody debris) within suitable MCBB habitat.
6. To maximize the potential for colonization of host and larval plants in disturbed areas, spread
chipped slash with a depth of no more than 2 inches above the soil surface at any point
(NalleliCarvajal-Acosta et al. 2015). Do not spread chipped slash in areas of suitable MCBB
habitat.
200
7. Do not burn slash piles within 5 meters of suitable MCBB habitat.

8. When broadcast burning for slash cleanup, remove slash or other fuels from a 5-meter buffer around
suitable MCBB habitat, if suitable habitat is adjacent to the area to be burned.
9. If possible, use access routes that do not cross suitable habitat. If not possible, see measure 16.
10. Complete final layout of hiking and mountain biking trails after suitable MCBB habitat has been
marked. No mountain biking or hiking trails will be placed within suitable MCBB habitat.
11. Do not deposit excavated material within suitable habitat or directly upslope of suitable habitat
unless controls are put in place to ensure material does not erode into suitable habitat.
12. Conduct activities around suitable habitat outside the adult MCBB flight period (mid-June through
mid-September) when possible.
13. Maintain snow cover in areas where suitable habitat exists while the ski area is open for skiing. If
insufficient snow cover exists in an area of suitable habitat (i.e., rocks and vegetation are visible),
mark the area as a hazard so skiers will avoid damaging habitat or individual MCBB with their
skis.
14. Maintain snow cover in areas where suitable MCBB habitat exists while the ski area is open for
skiing. If insufficient snow cover exists in an area of suitable habitat, mark the area as a hazard and
ensure that no grooming takes place in areas where the tiller could hit the ground.
15. Do not plow/blow snow from roads or parking lots into areas of suitable habitat.
16. When access across suitable habitat without snow cover is necessary, designate construction
travel routes that minimize the amount of habitat impacted in coordination with the SMNRA
Wildlife Biologist prior to implementation. Install rope lines on the boundaries of travel routes to
constrain ground disturbance. When working in or passing through suitable habitat, minimize
impacts on adults and habitat to the extent possible by:
• Avoiding disturbance on host and nectar plants by stepping in the spaces between plants.
• Minimizing solid and rock disturbance.
• Avoiding unnecessary disturbance to adults.
• Inspecting and clearing equipment and clothing to prevent the introduction of invasive
organisms.
17. All equipment must be fueled and lubricated outside of the suitable habitat area to minimize the
potential for chemical spills and exposure of MCBB to chemicals.
18. Felling of trees in or adjacent to suitable habitat must be done such that trees are felled in the
direction that the impact of the tree on the ground will affect the smallest possible amount of
MCBB suitable habitat.
19. If glading of trees (as described in section 2.2.1.4) would result in habitat removal, do not conduct
glading operations in the areas where habitat removal could occur.
20. Conduct any revegetation according to guidelines and specifications established between the
Forest Service and FWS at the time such revegetation is proposed. Seed mixes must be approved
by the Forest Service and FWS.
201
CULTURAL RESOURCES
Elements of the proposed action and BCT alternative were relocated to avoid direct impacts on the NRHP-
eligible site. To address ongoing impacts and potential indirect impacts on the site, mitigation measures
described in the Cultural Resources Narrative Report are necessary (see section 11 in Santarone et al.
2017). Design criteria listed in section 2.6 will serve to protect any undiscovered cultural resources.
The following mitigation measures were identified for cultural resources:
1. Invite tribal knowledge holders to conduct a cultural assessment.
2. Develop interpretive signs, panels, and brochures to make the public aware of Nuwuvi culture and
the importance of the Spring Mountains, in consultation with the affected Tribes.
3. Invite tribal representative to conduct blessings on the land prior to construction projects.
4. Invite tribal knowledge holders to conduct monitoring of glading and clearing.
5. Give tribal leaders access to wood from felled trees, that can be used for religious ceremonies or
other culturally appropriate practices.
6. In addition to the current support provided for the Gathering for Our Mountains, financial, building
use, and shuttles could be provided. This would be proponent-provided mitigation.
7. Notify Nuwuvi leaders of ski area job openings as they become available. This would be proponent-
provided mitigation.
SCENIC RESOURCES
No additional mitigation measures identified.
RECREATION
No additional mitigation measures identified.
SAFETY
1. Use at least four signs to notify riders of each intersection with the BCT. Signs will be spaced
approximately 100, 50, 25, and 0 feet from the intersection. Additional signs may be used if deemed
necessary.
2. For each intersection of mountain bike trails with the BCT, use two signs on the BCT, one facing
each direction, to notify BCT users of the intersection.
3. Where appropriate, use slowing features to reduce the speed of mountain bike trail users at
intersections with the BCT.
4. When determining the final layout of mountain bike trails, ensure that users of the trail can see at
least 20 feet up and down the BCT from a distance of 30 feet away from the intersection.
TRAFFIC
1. The Forest Service will continue to participate in and support MCWA efforts to address traffic and
parking issues in the SMNRA.
202
LAND USE
1. Construct a fence and signs along the northeast permit boundary between the ski area and Camp
Lee Canyon. This fence will be approximately 500 feet long and span the drainage below the new
parking lot. The fence does not need to be a permanent installation and may be removed during the
winter to prevent snow damage. The fence will inform ski area visitors about the boundary and
deter casual access to Camp Lee Canyon; therefore, it does not need to be a substantial barrier.
2. Erect snow fencing along the north edge of the Chair 5 pod ski runs. Signage will indicate that the
area beyond the fence is outside the ski area boundary.
203
APPENDIX C: RESPONSE TO COMMENTS ON

THE DRAFT EIS
THE COMMENT PROCESS
The Spring Mountains National Recreation Area, Humboldt-Toiyabe National Forest (HTNF) prepared a
Draft Environmental Impact Statement (DEIS) addressing proposed implementation of Lee Canyon Ski
Area Master Development Plan Phase I, in accordance with agency’s National Environmental Policy Act
(NEPA) procedures (36 CFR 220).
On August 17, 2018, an email bulletin was sent to 466 individuals, organizations, agencies, and others on
the project mailing list notifying them of the document’s availability on the Forest Service website and
providing instructions on submitting comments. Hard copies of the document were made available by the
Forest Service to those requesting a copy. The Notice of Availability of the DEIS was also published in the
Federal Register on August 17, 2018, initiating a 45-day comment period, as stipulated in the agency’s
notice and comment regulations (36 CFR 215). A Legal Notice of Proposed Action was published in the
Las Vegas Review-Journal on September 19, 2018. Comments were received from 9 agencies, 8
organizations, and 344 individuals.
This report identifies commenters, lists the comments received, and provides HTNF responses to
substantive comments, in accordance with agency regulations at 36 CFR 215.6.
RESULTS
Table 1 lists each comment letter (including emails and other forms of communication), identifying the
code number assigned to it, the name and address of the commenter, and the topics or resource areas
addressed by the commenter. In the results section that follows the table, each quoted comment is followed
by a comment code made up of the letter code (A = agency, O = organization, I = individual), and the
number of that individual comment within the letter (e.g. A1-2 is the second comment in letter A1). All
original comment letters are included in the project record.
Table 1. Comment log.

ID Name Address Topic(s) Raised
Brenda Whitfield, Air Quality
Specialist Process/Other Permits and
A1
Approvals; Air Quality
Clark County Dept. of Air Quality
Process/Other Permits and
Nancy A. Amundsen, Director Approvals; Soil, Water, and
A2 Clark County Dept. of Comprehensive Watershed Resources;
Planning Recreation; Safety; Traffic
and Parking
Jorge Gonzalez, Fire Chief
A3 Safety; Traffic and Parking
Mt. Charleston Fire District
Mary A. Martini, District 1 Engineer
A4 State of Nevada, Dept. of Safety; Traffic and Parking
Transportation
204

Lisa Kremer, Chief Process/ Other Permits and
A5
Nevada Div. of Env. Protection Approvals
Skip Canfield,
A6 Scenery Resources
Nevada Division of State Lands
Sue Gilbert Soil, Water, and Watershed
A7
Division of Water Resources Resources
Rebecca Lynn Palmer
A8 State Historic Preservation Officer Cultural Resources
State Historic Preservation Office
Process/Notice and
Comment; Process/Other
Kathleen Martyn Goforth, Manager Permits and Approvals; Soil,
A9 Water, and Watershed
US EPA Resources; Wildlife; Traffic
and Parking;
Opinion/General
Mark Zellmer, President
O1 Opinion/In Favor
Alpine Ski & Snowboard Club, Inc.
Process/Purpose and Need;
Patrick Donnelly, Nevada State Process/Proposed Action;
Director Process/Alternatives;
O2
Process/Implementation
Center for Biological Diversity Schedule; Vegetation;
Wildlife; Recreation
Jose Witt, Southern Nevada Director Recreation; Safety; Traffic
O3
Friends of Nevada Wilderness and Parking
Dan Hooper, Process/Mitigation;
O4
Lee Canyon Wildlife; Traffic and
Parking; Opinion/In Favor
Process/Scope of the
Analysis;
John E. Hiatt, Conservation Chair Process/Alternatives;
O5 Process/Mitigation; Soils,
Red Rock Audubon Society Water, and Watershed
Resources; Vegetation;
Wildlife; Recreation
Jennifer Hanks, SNMBA Treasurer
O6 Southern Nevada Mountain Bike Opinion/In Favor
Association (SNMBA)
Process/Collaborative
Tom Padden, Executive Director Planning; Process/Purpose
O7 Spring Mountains Conservation and Need; Process/Notice
Alliance and Comment; Wildlife;
Safety
205

Candace Fallon, Senior Conservation
Biologist and Sarina Jepsen, Director of
Endangered Species and Aquatic
O8 Conservation Process/Mitigation; Wildlife
The Xerces Society for Invertebrate
Conservation
I1 Agrawal, Pawan Opinion/In Favor
I2 Alder, Mike Opinion/In Favor
Wildlife; Scenery
I3 Alderson, Jimmy and Katy Johnson
Resources; Recreation
I4 Allaire, Margot Opinion/In Favor
I5 Amico, Jeff Opinion/In Favor
I6 Arnold, Daniel Wildlife; Opinion/In Favor

I7 Austin, Jeffrey Opinion/In Favor
Process/Purpose and Need:
I8 B, Jeff
Wildlife; Opinion/Opposed
Process/Alternatives;
I9 Baird, Jane
Opinion/In Favor
I10 Benton, Lauren Opinion/In Favor
I11 Bernhard, Alan Opinion/Opposed
I12 Birkin, Brent B. Opinion/In Favor
I13 Bobryk, Tom Opinion/In Favor
I14 Boekankamp, Tricia Opinion/In Favor
I15 Boffeli, Shannon
Opinion/In Favor
I16 Bowers, Joshua Opinion/Opposed
I17 Brian, Kam and Katherine and family Opinion/In Favor
Soil, Water, and Watershed
I18 Brittingham, Steve Resources; Wildlife;
Opinion/Opposed
I19 Brogan, Victoria Process/ Proposed Action
I20 Caples, Craig F. Safety; Opinion/In Favor
I21 Carman, Stephanie Process/ Proposed Action
I22 Colety, Michael Opinion/In Favor
I23 Cummings, Michael Opinion/In Favor
I24 Darlene Opinion/Opposed
206

Traffic and Parking;
I25 Davis, R
Opinion/In Favor
I26 Dodd, Joe Opinion/In Favor
I27 Dorsey, Brandon Opinion/In Favor

I28 Doucette, Justin
Opinion/In Favor
I29 Downey, J. Opinion/In Favor
I30 Dyrland, Darion Opinion/In Favor
I31 Edwards, Kevin Opinion/In Favor
Process/Proposed Action;
Recreation; Safety; Traffic
I32 Emord, Nicole
and Parking;
Opinion/Opposed
I33 Filas, Mike Opinion/In Favor
I34 Fleming, Stephen Nevada Opinion/Opposed
I35 Fleming, Stephen Nevada Soils, Water, and Watershed
Resources
I36 Fleming, Scott Opinion/In Favor
I37 Floyd, Christopher Opinion/In Favor
Opinion/In Favor;
I38 Fox, Jerry
Opinion/Opposed
I39 Freeman, Elizabeth Opinion/In Favor
I40 Guerrero, Aaron Opinion/In Favor
I41 Guerrero, Ashley Opinion/In Favor
I42 Gutierrez, Maria Opinion/Opposed
I43 Halverson, Philip Opinion/In Favor
I44 Hanks, Jen
Opinion/In Favor
Vegetation; Opinion/In
I45 Hiatt, Hermi
Favor; Opinion/Opposed
Wildlife; Access; Opinion/In
I46 Hotchkiss, Carol
Favor
I47 Hyde, Kurtis Opinion/In Favor
I48 ID, Luci
Opinion/Opposed
Process/Notice and
I49 Isaacs, K. Comment; Soil, Water, and
Watershed Resources;
207

Wildlife; Traffic and
Parking; Air Quality;
Opinion/In Favor
Analysis; Soils, Water, and
I50 Jenson, Caroline Watershed Resources;
Wildlife; Safety; Traffic;
Opinion/In Favor
I51 Jolley, Andrew Opinion/In Favor
I52 Kadlub, Craig Traffic and Parking;
Opinion/In Favor
Soil, Water, and Watershed
I53 Kantor, Lynn
Resources; Traffic and
Parking
I54 Kennedy, Thomas Opinion/In Favor
I55 King, Stanley Opinion/In Favor
I56 Kling, Joel Opinion/In Favor
I57 Lambson, Lyman
Opinion/In Favor
I58 Lane, Chris Opinion/In Favor
I59 LaRose, James Opinion/In Favor
I60 Leaver, Scott and Andrea and family Opinion/In Favor
I61 Liberti, Dawn Process/Alternative
I62 Lowey, Cindy Safety; Opinion/In Favor
I63 Macias, Cesar Opinion/In Favor
Process/Mitigation; Traffic
I64 Mafi, Michael A.
and Parking; Access;
Opinion/General
I65 Manning, Justin Opinion/In Favor
I66 Mabry, Jack Process/Alternatives;
Wildlife
I67 Martin, Dean T. Opinion/In Favor;
Opinion/Opposed
I68 McDonald, Michael Opinion/In Favor
I69 McGinnis, Danny Opinion/In Favor
I70 McGonigle, Jim Opinion/In Favor
208

I71 McGonigle, Kathleen Opinion/In Favor
I72 Means, Stephen Opinion/In Favor
I73 Mick, Rick Wildlife; Opinion/Opposed
I74 Morris, Benjamin Opinion/In Favor
I75 Morrow, Robert Traffic and Parking
I76 Mullen, Leah Opinion/In Favor

I77 Munoz, Angelica Opinion/Opposed
I78 Murphy, Cindy Opinion/Opposed
Traffic and Parking;
I79 Murphy, Susan
Opinion/Opposed
I80 Murray, Nicholas Opinion/In Favor
I81 Murray, Nicholas Opinion/In Favor1
I82 Myers, Stephanie
Process/Mitigation
Recreation; Traffic and
I83 Ofenloch, Kevin & Jaci
Parking
I84 Okerlund, Thomas Opinion/In Favor
I85 Osgood, Pamela
Opinion/Opposed
I86 Page, Scott Wildlife
Recreation;
I87 Perry-Jones, Jean
Opinion/Opposed
Recreation;
I88 Perry-Jones, Jean
Opinion/Opposed1
I89 Petricka, Ariell Opinion/In Favor
I90 Plana, Eduardo Opinion/In Favor
I91 Public, Jean Opinion/Opposed
I92 Pudelwitts, Nancy Opinion/In Favor
I93 Reese, James Opinion/In Favor
I94 Reese, Susanne Opinion/Opposed
I95 Robb, Evelyn Opinion/In Favor

I96 Rodarmel, Jody Access
I97 Schelin, Dustin Opinion/In Favor
I98 Schelling, Edward Opinion/Opposed
209

I99 Schreiber, Deborah Opinion/Opposed
I100 Shanahan, Seth Opinion/In Favor
I101 Siverlyguido, Abraham Opinion/In Favor
I102 Speckery, Barb Opinion/Opposed
I103 Spotts, Richard
Wildlife
I104 Tancredi, Loretta
Opinion/Opposed
I105 Taylor, Lisa Opinion/In Favor
I106 Tecson, Mark Opinion/In Favor
Analysis; Process/Proposed
I107 Thompson, Donna
Action; Safety;
Opinion/Opposed
I108 Trapp, Paul Opinion/In Favor
I109 Trent Process/Alternatives;
Opinion/In Favor
I110 Urioste, George and Joanne Opinion/Opposed
I111 Virella, Francisco Opinion/In Favor
I112 Ward, John Opinion/Opposed
I113 Wilson, Kim Opinion/In Favor
I114 Winter, Quinn Opinion/In Favor
Opinion/In Favor;
I115 Wixom, Josh
Opinion/Opposed
I116 Wixom, Stein Opinion/In Favor
Form letters
Opinion, opposed to
I117 Abbruzzese, Mary
summer use
Opinion, opposed to
I118 Adkison, Toni
summer use
Opinion, opposed to
I119 Alcala, Laura
summer use
I120 Opinion, opposed to

Alvarado, Myrna
summer use

Alwardt, Linda
summer use

Ary, Scott
summer use
210

B., Veronica
summer use

Babb, Stephen
summer use

Bailley, Patti
summer use

Baisinger-Criddle, Carol
summer use

Baker, Staci
summer use

Baker, Vickey
summer use

Bechmann, Elisabeth
summer use

Becker, Barbara
summer use

Becker, Kathy
summer use

Bellamy, David
summer use

Bittler, Alan
summer use

Bjorkman, Inge
summer use

Borg, Carolyn
summer use

Borg, Carolyn
summer use1

Bouchard, Lois
summer use

Boylston, Sandra
summer use

Brace, Morgan
summer use

Brant, Ann
summer use

Brauer, Ann
summer use

Breuer, Ann
summer use

Brown, Jeanne
summer use
211

Bubb, Donna
summer use

Buot, Carolynne
summer use

Burton, Lisa
summer use

Butler, James
summer use

Casarez, Lilia
summer use

Chaplin, Kent
summer use

Chi, Animae
summer use

Clarke, Cher
summer use

Cole, Paul
summer use

Conway, Maurene
summer use

Cooper, Ross
summer use

Coutts, Sara
summer use

Cox, Joseph
summer use

Cox, Linda
summer use

Cross, Heather
summer use

Curdie, David
summer use

Day, Patricia
summer use

Delagarza, Angela
summer use

Dunn, Micah
summer use

Ecker, Jennifer
summer use

Elgut, Malcolm
summer use
212

Elliott, Naomi
summer use

Emmerich, Kevin
summer use

Erickson, Rebecca
summer use

Erwin, Jeffrey
summer use

Eskew, Jerry
summer use

Faith-Smith, Bonnie
summer use

Faso, Linda
summer use

Fichtel, Chris
summer use

Fraga, Naomi
summer use

Gaffney, Jennifer
summer use

Gagliano, Debra
summer use

Gelbart, Susanna
summer use

Gelbart, Susannah
summer use

Gendvil, Derek
summer use

Gerlach, Christian
summer use

Gerlach, Christian
summer use

Gibb, Ken
summer use

Goade, Jennifer
summer use

Goettling, Sandra
summer use

Gold, Stacy
summer use

Gonzales, Shaun
summer use
213

Greenman, Amber
summer use

Groeber, Kim
summer use

Hanbury, Pat
summer use

Harry, Beverly
summer use

Hasbach, Corinna
summer use

Hastings, Susan
summer use

Hausler, Leticia
summer use

Heald, James
summer use

Heelan, Roberta
summer use

Hegland, Patricia
summer use

Hendricks, Sarah
summer use

Henriquez, Leticia
summer use

Henriquez, Leticia
summer use1

Henry, Jennifer
summer use

Herman, Jeff
summer use

Herrington, Beverly
summer use

Hieber, Richard
summer use

Houck, Megan
summer use

Idol, Kim
summer use

Ingram, Sj
summer use

Irons, Bridget
summer use
214

Ivaldi, Miriam
summer use

Johns, Marie
summer use

Johnson, Ronald
summer use

Johnston, Judith
summer use

Jones, Linda
summer use

K., Miriam
summer use

Keil, Kirk
summer use

Kelley, Dorinda
summer use

Kester, Kathleen
summer use

Kezar, Tara
summer use

Kita, Karen
summer use

Knoll, Kris
summer use

Knowles, Cybele
summer use

Koff, Marilyn
summer use

Koritz, Raleigh
summer use

Koulavongsa, Joanne
summer use

Kratz, Lauren
summer use

Kurland, Michele
summer use

Kyes, Karin
summer use

La Fountain, DJ
summer use

Lamb, John
summer use
215

Lambert, Corey
summer use

Lara, Rebecca
summer use

Little, Heather
summer use

Lobel, Colleen
summer use

Lohli, Arline
summer use

Lukachy, Tamara
summer use

Lurtz, Jamie
summer use

Lynn MacKinnon, Bonnie
summer use

M. Reed, Robert
summer use

Marriott, Laurie
summer use

Martin, Julie
summer use

Martinez, Jennifer
summer use

Mascarich, Morgan
summer use

Matlin, Thelma
summer use

Mazzola, Lisa
summer use

McMullen, Gail
summer use

Meier, Rich
summer use

Mell, Richard
summer use

Mendez, Joe
summer use

Milic, Ljiljana
summer use

Miller, Betty
summer use
216

Miller, Elizabeth
summer use

Miller, Madeleine
summer use

Minic, Marija
summer use

Montarou, Anne
summer use

Moore, Lee
summer use

Mrowka, Rob
summer use

Mulcare, James
summer use

Murphy, Cindy
summer use

Nelson, Dennis
summer use

Nelson, Tracy
summer use

Neste, Lisa
summer use

Night, Talus
summer use

Nix, Zephan
summer use

Noffsinger, Sandra
summer use

Nunez, William
summer use

Odin, Danielle
summer use

Olson, Allen
summer use

Ortega, Karen
summer use

Ozkan, Dogan
summer use

P, Dr
summer use

Padar, Stephen
summer use
217

Palacky, Tami
summer use

Peace, Julia
summer use

Peart, Cindy
summer use

Peranio-Paz, Giana
summer use

Perkins, Guy
summer use

Petras, Christina
summer use

Peyser, Victoria
summer use

Porter, Chris
summer use

Portteus, Eric
summer use

R, S
summer use

Ramirez, Marilee
summer use

Ramirez, Marilee
summer use

Rappaport, Alex
summer use

Ratliff, Joe
summer use

Reckling, Debra
summer use

Reckling, John
summer use

Reeson, Paulo
summer use

Reeves, Lenore
summer use

Renee, Robyn
summer use

Ritter, Shirley
summer use

Rivera, Javier
summer use
218

Roberds, Nikki
summer use

Robertson, Barb
summer use

Robertson, Mike
summer use

Robinson, Jacquie
summer use

Rogers, Juliann
summer use

Roland, Jelica
summer use

Sanders, Robert
summer use

Sasaoka, Julie
summer use

Schneebeli, Christiane
summer use

Scott, David
summer use

Sexton, Sara
summer use

Sexton, Sara
summer use

Shapiro, Howard
summer use

Sickler, Cheryl
summer use

Sims, Nancy
summer use

Smith, Barry
summer use

Spotts, Richard
summer use

Steadmon, Jason
summer use

Steele, Dee
summer use

Stidham, Jean
summer use

Stillman, Jonathan
summer use
219

Stuehler, Helen
summer use

Sullivan, Theodora
summer use

Taylor, Michelle
summer use

Tefertiller, Staci
summer use

Terrell, Scott
summer use

Thomas, Debbie
summer use

Thompson, Robin
summer use

Timothy, Dawn
summer use

Toce, Jeannette
summer use

Trufan, Hal
summer use

Vandal, Lise
summer use

Vazquez, Patricia
summer use

Venezio, Glen
summer use

Vergilia, Nadine
summer use

Vitavec, Rosemary
summer use

Wakefield, Marie
summer use

Watola, Danuta
summer use

Webb, Kathy
summer use

Wei, Annie
summer use

Weir, Vernon
summer use

Welch, Kathleen
summer use
220

Wiley, Kimberly
summer use

Williams, Freddie
summer use

Williams, Virginia
summer use

Wilson, Tina
summer use

Wolfenbarger, Anne
summer use

Wong-Kone, Diane
summer use

Worley, David
summer use

Wright, Georgina
summer use

Youngelson, Noah
summer use

Youtie, Lisa
summer use

Yovella, Debra
summer use

Zaber, David
summer use

Overbey, Linda
summer use
1
Indicates that the comment is a duplicate of the prior comment.
PROCESSING OF COMMENTS
In accordance with the following Forest Service NEPA procedures, the agency must review, analyze,
evaluate, and respond to substantive comments on the DEIS (FSH 1909.15 [ 25.1]):
(a) An agency preparing a final environmental impact statement shall assess and consider
comments both individually and collectively, and shall respond by one or more of the
means listed below, stating its response in the final statement. Possible responses are to:
(1) Modify alternatives including the proposed action.
(2) Develop and evaluate alternatives not previously given serious consideration
by the agency.
(3) Supplement, improve, or modify its analyses.
(4) Make factual corrections.
221
(5) Explain why the comments do not warrant further agency response, citing the
sources, authorities, or reasons which support the agency's position and, if
appropriate, indicate those circumstances which would trigger agency reappraisal
or further response.
Substantive comments and responses to them are provided below.
COMMENTS AND RESPONSES

The following sections list the quoted comments in italics with the comment code (i.e., the comment letter
and specific comment within that letter, corresponding to the preceding table) followed by a Forest Service
response. Where applicable, similar comments are listed together followed by a single response.
Throughout this document the “proposed action” is often used as shorthand for the “proposed action and
BCT alternative” for the sake of brevity.
PROCESS
Scope of the Analysis
We need to look at the bigger picture, please. The entire Spring Mountains need a Master
Plan. We need researchers (UNLV?), sensible development, and some areas with
controlled access. (I50-6)
Response: The master plan for the SMNRA is the General Management Plan for the Spring Mountains
National Recreation Area (GMP), an amendment to the Toiyabe National Forest Land and Resource
Management Plan (Forest Plan). The master plan for the ski area is the Las Vegas Ski and Snowboard
Resort Master Development Plan, which was accepted by the HTNF following a review confirming that it
was consistent with the Forest Plan, as amended. The proposed action that is the focus of this EIS is
consistent with both the Forest Plan, as amended, and the ski area’s master plan.
The proposed action is site specific and is drawn from Lee Canyon’s master development plan Management
of the Spring Mountain National Recreation Area (SMNRA) is under the direction of the Forest Plan, which
includes the General Management Plan for the Spring Mountains National Recreation Area. That plan
addresses the concerns raised by this commenter. Beyond that, planning for the entire SMNRA is outside
the scope of this analysis.
It is my opinion, however, that the analysis of the proposed action should include the
watershed (or sub-watershed) of upper Lee Canyon. If the entire upper part of the
watershed is included in the analysis then it would allow one to see how the disturbance of
the proposed action fits into the bigger picture of disturbance in the larger watershed and
how we can achieve a reasonable semblance of the natural disturbance regime which
allowed species such as the Mt. Charleston Blue Butterfly to thrive in that area. (O5-12)
Response: See DEIS section 3.4. It identifies the analysis area for disturbances within the Lee Canyon
watershed, which includes the three subwatersheds comprised by upper Lee Canyon (see Figure 3-2). The
cumulative effects analysis also includes cumulative actions within those subwatersheds and beyond, as
appropriate to the resources in question. This is consistent with the requirements of NEPA, the Council on
Environmental Quality (CEQ), and the Forest Service regarding cumulative effects analysis.
The USFS has completely abandoned it’s [sic] responsibility in managing the forest, from
dead tree removal along the highways to trail maintenance. The frequent cry is that there
is no funds for the necessary enforcement and maintenance of this completely unique area.
(I107-4)
222
Even in a relatively quieter summer season, the USFS is without resources to address
illegal campfires which occur everywhere… Graffiti on rock faces is rampant and
unaddressed… Absence of enforcement of the laws and control of the visitor volume creates
a free-for-all mentality, and a danger to the sensitive environment, visitors, and residents.
(I107-5)
Response: This EIS analyzes the effects of the proposed action, which is focused on management of the ski
area. Enforcement of SMNRA fire closure orders and vandalism prevention are not part of the proposed
action but are an ongoing effort conducted by Forest Service personnel on a daily basis.
Collaborative Planning
It is examples like these [past fuel reduction projects and policy and implementation
failures] that cause those of us who have experienced these failings over the years to be
skeptical and cautious toward these kinds of planning processes, and try to appeal for
better oversight of implementation. The solution is clearly a more open, participatory
process, including collaboration in obtaining more and better resources for conservation
needs and goals, by developing more and better cooperation throughout the whole chain
of entities, from local concerned citizens, businesses, scientists and conservation groups,
to regional administration, to willing members of our Congressional delegation.
How unforgivable it would be if we would miss this opportunity for a genuine collaboration
and, therefore, success through continuing improvement of how we achieve stewardship.
(O7-6)
Response: Our planning process is collaborative, as evidenced by the extensive interchange with the public
and other agencies and organizations when our Forest Plan and GMP were being developed. At this point,
we are involved in the NEPA review phase, addressing a project-specific proposed action. While public
involvement is solicited at key points in the NEPA process (see DEIS Chapter 5), we are beyond the
collaborative planning stage.
Purpose and Need

Lee Canyon agrees with and is supportive of the overall purpose and need. The purpose
and need discusses “growing recreational demand from Las Vegas and the surrounding
area” The last significant expansion of facilities at the ski area occurred in the late 1960’s
to early 1970’s. Since that time, the Las Vegas population has multiplied over five times
and continues to grow. This population growth along with increased numbers of people
participating in outdoor recreation activities has resulted in significant growth in visitors
to Lee Canyon who would be better served with additional facilities. (O4-1)
The purpose and need also discusses “Develop year-round recreational opportunities to
meet increasing demand by recreationists of various types and skill levels.” There has been
tremendous growth nationally and locally in activities such as mountain biking with now
approximately 40 million mountain bikers nationally. Adding summer recreational
opportunities will allow other user groups to be able to utilize and enjoy Lee Canyon. (O4-
2)
The reality is that the area already allocated for development has never been fully
developed into a 1st Class small facility. Its environmental impact has not been good.
Require it to be developed into a "model environmentally friendly" facility and solve the
traffic problems and you will "enhance everyone's recreation experience". (I35-3)
Response: See DEIS section 1.4. The statement of purpose and need for the proposed action was developed
to reflect aspects of the ski area that require improvement in order to provide the range and quality of
223
recreational opportunities desired by SMNRA users. This includes year-round opportunities in response to
both growing public demand and climate change. See also the following response and our response below
under Alternatives/Winter-only Alternative.
Further, and sadly, environmental changes have reduced the number of ski-able days over
the past few years, barring the one large snow year we had couple years ago. Expansion
of the skiable terrain under this changing climate is financially foolish. (I8-3)
Given climate change alone it doesn’t make sense to build a new ski resort. The ones we
have are not doing well financially because of weather. (I85-1)
Response: In response to concerns such as this, the Forest Service has completed in-depth studies of
projected effects of climate change on snowpack and winter recreation on the HTNF and the Intermountain
Region as a whole (Tausch 2011 and Halofsky et al 2018, respectively). These studies are cited frequently
in the DEIS. In regard to this comment, DEIS sections 3.9.2.2 and 3.9.3.2.2 are most relevant. In short,
these studies identify snowmaking and year-round recreational opportunities as key strategies for
Intermountain Region ski areas faced with the prospect of global warming. This proposed action embodies
both of those strategies.
For at least the past 20 years, USFS policy in the SMNRA has clearly emphasized
facilitating recreational use and “visitor experience” over conservation needs and
responsibilities... Conservation goals have also been frustrated by lack of resources, or
misallocation of priorities when resources have been available.
Brief reference is made of the CA in this DEIS, but little is evident of its being able to be
applied in the broad sense that it was intended. In actual practice, readily visible
throughout the landscape of the SMNRA, there is little to no evidence that the vision and
provisions of the CA are known or have been taken seriously. (O7-2)
Response: See DEIS sections 1.4 and 1.6, both of which describe the proposed action in the context of the
overall management direction for the SMNRA. The ski area permit boundary comprises less than 0.01
percent of the SMNRA, and potential impacts on the Spring Mountains Conservation Agreement (CA)
species of concern (plants and animals) were fully analyzed in the DEIS for each alternative. The CA was
considered appropriately as it related to the project area.
Proposed Action
General
The bike trails, zip lines, coaster, (which most people will ride maximum once), the hiking
trails, archery targets, going on triple ski lift rides, renting one wheel self balancing skate
boards, and of coarse [sic] eating and drinking at the tent cafes. What a zoo already! I
realize Powdr Corporation has recently purchased Lee Canyon, along with at least eight
other ski resorts, of coarse [sic] for a profit. It is very hard for me to believe they will have
any concerns preserving the delicate environment, ie butterfly habitat and Bristlecone
trails. (I53-2)
Response: DEIS section 2.2 describes the proposed action in detail. Section 1.6 addresses this proposed
action’s consistency with the Forest Plan, which guides our management of the ski area. Through our
administration of their permit, we will ensure compliance with that management direction, in terms of both
provision of recreational opportunities and resource protection.
Additionally, PL 112-46 requires that, to the extent practicable, new summer recreation
infrastructure and activities “be located within the developed portions of the ski area.”6
Neither the proposed action nor the BCT alternative locate new infrastructure or activities
224
within the developed portions of the ski area, and indeed will require an extensive
expansion of the developed area within the ski area. (O2-5)
Response: The comment accurately quotes sec. 3(B)(ii) of the Ski Area Recreation Opportunity
Enhancement Act (SAROEA), but as stated in the introduction to that section, this direction applies to
“…other seasonal or year-round natural resource-based recreational activities and associated facilities (in
addition to skiing and other snow-sports).” It does not limit where new snow-sports infrastructure may be
developed. In this case, all proposed infrastructure and activities would occur within the special use permit
boundary. Pods 5 and pod 8 would be developed for skiing, becoming part of the “developed portion of the
ski area.” All proposed summer recreational infrastructure would be within or adjoining This new
developed area, in accordance with the cited terms of the SAROEA.
I would appreciate it if a proper map [mountain coaster] with the potential projects
outlined was sent or put online so I could understand exactly what goes where. (I19-1)
Response: Maps of the proposed action were included in the scoping notice, and maps of the proposed
action and BCT alternative are included in the DEIS (Figures 2-1 through 2-4). Both documents were posted
on the Forest website, where other project mapping is also available. In particular, the location of the
mountain coaster was shown on DEIS Figure 2-2 for the proposed action and Figure 2-4 for the BCT
alternative. This mapping appears to reflect the location of each proposed element with sufficient accuracy
and detail.
You continue to fail to show the Upper Bristlecone Trail on all your maps. Is that an
unlawful attempt to reduce negative comments from hikers? (I66-3)
Response: The BCT was included in DEIS Figures 2-1, 2-2, 2-4, 3-3, 3-5, 3-7, and 3-9. The trail was
inadvertently left off Figure 2-3. The FEIS will correct this oversight. We apologize for the inconvenience.
I request you don't have a disc golf course way up on the side of the mountain with
treacherous rocks and brush- terrible location to chase a disc around and try to find. Why
not have it in the flatter area alongside the Bristlecone trail. (I109-2)
Response: The proposed action does not include any change in the ski area’s permitted disc golf course.
Note also that the preferred, BCT alternative was developed to move ski area infrastructure away from the
BCT. A disc golf course in that area would be inconsistent with that objective.
Will there be additional trash receptacles and pick up schedules to accommodate the
increase in trash and debris? (I32-4)
Response: To comply with their special use permit, Lee Canyon is required to provide adequate services
and utilities, including trash collection. This requirement is in place currently and would remain under the
proposed action. See also DEIS section 1.7.2.6 dealing with the issue of litter.
On Monday mornings throughout the winter, the volume of scattered trash left behind, and
overflowing dumpsters, are obvious testaments to just how overwhelmed and dangerous
this stretch of the highway has become. [referring to the Foxtail Winter Snowplay Area]
(I52-3)
Response: While conditions at the Foxtail Winter Snowplay Area are outside the scope of this analysis, the
DEIS does address potential impacts on traffic on SR 156 (DEIS section 3.11).
Projected User Numbers
In a significant deficiency in the DEIS, there is no concrete information provided by the
Forest Service on the anticipated usage of the proposed developments, and the associated
impacts of increased visitor traffic on the forest. (O2-8)
225
There are various different references to an increase in visitation in the DEIS but none of
these references gives the reader a complete picture of anticipated usage levels.
• Under the “emergency services” section (DEIS at 163), there is a reference to
“approximately 10,000 biker visits the first year of operation and gradually
increase to a maximum of 25,000 biker visits in 5 to 10 years,” which is then cited
as referencing “(Kelly, 2017)”. There is no entry in the list of references for
“Kelly, 2017,” so the reader is left to guess as to where the 10,000 and 25,000
numbers came from and what their relation are to anticipated overall usage of the
facilities.
• Under the “recreation” section (DEIS at 157), there are some numbers given:
“The ski area provided the following projections of summer visitors using the
proposed facilities on a peak day: mountain bike trails, 650; mountain coaster,
1,500; and zip line, 300 (Hooper 2017). Average use is projected to be 70 percent
of those figures.” However these numbers are presented without any context. How
many days long is the season? How many peak days are there in the season? Are
these numbers based on market analyses? Where does the 70% average use
number come from?
• Under the “traffic” section (DEIS at 166), it states that “skier numbers are
projected to increase from 1,880 to 2,850 on peak days.” The same questions from
above related to “peak days” apply here. (O2-9)
The Forest Service needs to revise the proposed action in the DEIS to include concrete
projections for the numbers of anticipated users for the various new amenities on an annual
basis. (O2-10)
Response: Projecting visitation, particularly for individual improvements at the ski area, is an inexact
science. The DEIS, as these commenters note, provides the best, conservative projections available based
on experience at other mountain resorts and the opinions of the cited people, who are knowledgeable in this
area. These projections are necessary to assess specific issues such as emergency services, recreational
impacts on BCT users, and traffic effects to determine the potential for significant effects. Other issues do
not require use projections to make this determination. These projections are an analytical tool, not part of
the proposed action, so no revision of the proposed action is required. Consistent with NEPA, CEQ, and
Forest Service direction to keep analysis concise and focused, we do not feel other use projections are
warranted. The FEIS will include the Kelly 2017 citation.
Mountain Biking
Adding mountain biking trails to the ski area is a common use by many resorts and a great
way to expand business year-round. Based on previous experience, I would caution that
any added trails for this purpose must switchback across the area and not simply down the
existing ski runs. (I67-5)
Response: We agree. As indicated in Figure 2-2 of the EIS showing the approximate location of the
proposed mountain bike trails, most are not on ski runs, and most zig zag down the slopes. This makes for
more entertaining cycling as well as reducing erosion hazard.
Skier Services Infrastructure
…one improvement I would suggest is to give us a baby changing table somewhere, lots of
people bring babies and have to tread all the way back to their vehicle to change them.
(I21-1)
Restrooms are inadequate. (I64-3)
226
The restaurant and restroom facilities are extremely outdated and insufficient to meet the
current and future needs of guests. Updating these amenities should be considered basic
and essential. (I67-2)
…the infrastructure itself cannot handle the current volume of winter visitors… The
infrastructure in place is tremendously overwhelmed and cannot accommodate more.
(I107-2)
Response: The need for additional restrooms was an important factor in our decision to pull the skier
services building that was scoped as part of the proposed action out of this analysis and categorically
exclude it from additional review. Authorization to construct that building at the mid-mountain base area
was issued in 2018, and construction is planned for summer of 2019. This structure will provide
approximately 5,000 square feet of restrooms and other skier services. Beyond that, the proposed action
includes the equipment rental/food & beverage building, which would provide additional restroom space
and food and beverage service, and the vault toilet facility at overflow parking lot, which would add more
restroom capacity at the ski area. Collectively, these additions would eliminate existing deficits in skier
service infrastructure.
Forest Plan Amendment
…PL 112-46 requires that new summer recreation infrastructure and activities, “be
authorized in accordance with the applicable land and resource management plan.”7 Both
the proposed action and the BCT alternative require a significant amendment to the Forest
Plan, meaning that they are not in accordance with the current plan. (O2-6)
A Forest Plan amendment is required for the proposed action and BCT alternative because
they would violate prohibitions on new recreational developments within biodiversity
hotspots and on expansion of the ski area which would impact endangered species. (O2-
21)
These provisions of the Forest Plan were put into place for a reason- to recognize and
protect the irreplaceable biodiversity of the Spring Mountains National Recreation Area.
It is important to note that the 1st goal of the SMNRA GMP is to “conserve the health,
diversity, integrity, and beauty of the ecosystem,” while the 4th goal is “where consistent
with the above, provide additional opportunities for recreation.”12 The provisions of the
Forest Plan in question here, 0.31 and 11.57, were put in place precisely to achieve the 1st
goal. The need to change them to accommodate the proposed action is clear evidence that
the proposed action is not consistent with the 1st goal. (O2-22)
Response: Project-specific Forest Plan amendments are made fairly frequently; Forest Plans by necessity
address larger-scale landscapes and cannot always effectively incorporate localized management
considerations. As explained in DEIS section 1.4, the proposed action could not be revised, or an alternative
developed, in a way that complied with the two standards in question and still met the stated purpose and
need for action. Section 1.6 goes on to state that the proposed amendment is necessary in order for any
development to occur at the ski area. The DEIS addresses in detail the potential site-specific impacts on the
unique, special-status species that these standards are in place to protect (see sections 3.5 and 3.6), based
on this analysis the Responsible Official will decide whether or not to amend the Forest Plan (section 1.5).
Alternatives
Winter-only Alternative
The Forest Service has defined the purpose and need in an unreasonably narrow fashion,
removing its own discretion in deciding whether to permit summer recreation
infrastructure development at the ski resort.
227
Instead, as it is currently laid out in the DEIS, the “purpose and need” statement for the
Lee Canyon ski resort expansion is arbitrarily constrained. The Forest Service cannot
define the purpose and need so narrowly such that only the proposed action, or a very
closely related alternative, meets the goals and objectives of the project; doing so skirts
the entire purpose of performing a NEPA analysis.
…As a result, the Forest Service has failed to put forward a reasonable range of
alternatives, including one which evaluates only the winter components of the proposed
action. (O2-1)
During scoping, the public clearly identified a desire for a winter-only alternative and a
conservation-based alternative in the DEIS.2 The Forest Service has ignored such requests.
(O2-2)
In part, the Forest Service appears to rely on a perceived mandate for expansion of summer
recreation from the Ski Area Recreation Opportunity Enhancement Act of 2011 (PL 112-
46) (DEIS at 5), and then uses that perceived mandate to eliminate from consideration an
alternative which would not allow for the zip line and mountain coaster (DEIS at 12). And
further in the scoping report, the Forest Service uses the same justification to deny the
public’s request for a winter-only alternative (DEIS scoping report at 7).
However the Forest Service is misapplying PL 112-46 in several ways. (O2-3)
In addition to erroneously interpreting PL 112-46 as a mandate for developing summer
recreation infrastructure and activities, the DEIS invokes language in the Forest Plan,
stating, “desired future condition (p. 30) ‘The ski area is providing additional winter
recreation opportunities.’” (DEIS at 6). While the Forest Plan is very specific about a
desired future condition of enhanced winter recreation at the ski resort, it says nothing
about summer recreation there. At the very least, in order to comply with the intent of the
Forest Plan, a winter-only alternative should have been developed. Thus we urge the
Forest Service to revise the DEIS to include a winter-only alternative. (O2-7)
I do not believe that this EIS evaluates a "reasonable range of alternatives" as required by
the relevant NEPA CEQ regulation. The EIS action alternatives provide for the expansion
of summer commercial recreational uses. This is too limiting and prejudicial of an analysis.
The Forest Service should have developed and included an EIS alternative which allows
expansion of winter activities while not permitting summer recreation expansion. This
alternative would maintain the relatively undisturbed conditions on the mountain during
the summer. (I103-1)
These potential pros and cons are precisely why another EIS alternative is reasonable and
necessary so that an objective analysis may occur, including a fair comparison of a
reasonable range of alternatives. Therefore, a supplemental EIS is needed with the
additional alternative. (I103-3)
Response: These comments must be addressed at several levels: First, Lee Canyon’s accepted MDP, from
which the proposed action was drawn, includes the stated objective to “Offer ‘year round’ operations with
a wide variety of unparalleled recreational activities in a natural, wilderness environment.”
Second, alternatives other than the required no-action alternative that are analyzed in detail in an EIS must
be reasonable as well as avoiding or minimizing adverse environmental impacts of a proposed action (40
CFR 1500.2c). As discussed below, a winter-only alternative would not meet the stated purpose and need
for action and thus would not be reasonable. Beyond that, the DEIS did not identify sufficient adverse
effects due to the proposed summer activities to warrant a winter-only alternative. For example, only 1.5
228
acres of the 17.4 acres of MCBB habitat disturbance associated with the BCT alternative is due to summer
activities (see FEIS section 3.6.3.3.1).
Third, scoping commenters did not request analysis of a winter-only alternative (see Scoping Report pp. 8–
10), and neither the scoping report nor the DEIS discusses such an alternative in any manner. One scoping
commenter did express the opinion that the DEIS’s purpose and need statement only supported winter
recreation improvements, so that is all the proposed action should include. The response to that comment
in the scoping report cited the SAROEA discussion under purpose and need in the DEIS, identifying the
need to “Develop year-round recreational opportunities to meet increasing demand by recreationists of
various types and skill levels.”
Fourth, the DEIS purpose and need statement also cites the Forest Service’s Framework for Sustainable
Recreation regarding diverse recreational opportunities, and DEIS section 1.6 includes several points of
Forest Plan and GNP direction supporting the proposed summer recreation development. The DEIS does
identify substantial positive effects of the proposed action in meeting this central component of purpose
and need.
Fifth, based on these comments, the FEIS will address a winter-only alternative for consideration by the
public and the responsible official. It may or may not be carried into in-depth analysis for the reasons
outlined here (40 CFR 1502.14a).
Sixth, DEIS section 1.5, Decisions to be Made, states that any of the alternatives addressed could be selected
“all or in part.” Based on the analysis provided in the EIS, which describes the effects of individual project
elements, the responsible official could choose to authorize winter recreational developments only.
Alternative Eliminating Pod 8
The original developers of the Lee Canyon ski area recognized that the best area for snow
sports is located on the north facing slopes located on the south wall of the canyon. These
slopes receive the least sun and hence the snow on these slopes stays in the best condition
for the longest time. The area being proposed for chair 8 lies further north and receives a
lot more sun exposure. In view of the rapidity with which climate change is affecting
precipitation patterns in this area it doesn’t make sense to build a major new skiing area
at this location. The BCT alternative is an improvement on the proposed action but doesn’t
go far enough. Chair 8 and its associated infrastructure should be deleted from the plan.
(O5-5)
...the Bristlecone Trail alternative is preferable to the proposed action, but the BCT
alternative plus the elimination of chair 8 would be even better and would still allow the
ski area to expand. (O5-14)
I am glad to see that major changes include moving recreation away from the Bristlecone
Trail… However, more is needed…
The Bristlecone Trail was here long before a ski area even existed, starting in 1964. It has
been a haven of tranquility for recreation lovers and it deserves to continue that way. Not
just some but ALL ski area activities need to be COMPLETELY diverted away from the
Bristlecone Trail. Strict boundaries must be installed and enforced… However, additional
ski runs for skiers and use by mountain bikers should be STRICTLY PROHIBITED from
entering the present Bristlecone Trial boundaries. There should even be a wide
CORRIDOR between the ski area and the Bristlecone Trail where NO ACTIVITY is
permitted. The majority of people who use the Bristlecone Trail seek tranquility and a
meditative experience. (I82-1)
Response: Pod 8 exposures range from north to northwest, not significantly different from those in the
existing pods, and its higher elevation would keep snow longer. The DEIS addresses the implications of
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climate change (DEIS section 3.9). As discussed in DEIS section 2.2.1.3, pod 8 is an important element of
the proposed action, providing a logical step up in terrain difficulty as well as accommodating the needs of
a growing recreational market with a diversity of terrain.
The BCT alternative was developed to reduce impacts on BCT users. It includes a buffer between the trail
and pod 8 development and moves the more intrusive summer elements to other parts of the ski area. Neither
the mountain coaster nor the zip line would cross the BCT. The analysis indicates that this would
substantially reduce impacts on trail users (DEIS section 3.9.3.3.1), but some impact is unavoidable because
the trail passes through the permit area of an existing developed ski area.
We should also point out that the Forest Plan assigns the project area to Management Area 11 – Developed
Canyons, which provides for this type of developed recreation (section 1.6).
Alternative Eliminating Development East of Lift 2
I believe that any projects east of Chair 2 should be eliminated. This is prime hiking
territory… (I66-1)
Response: Most of the current ski area infrastructure is east of Chair 2, and most hiking in the area involves
the BCT, which is west of Chair 2. Under the BCT alternative, many of the proposed improvements are
moved east of Chair 2 to reduce impacts on BCT users.
Alternative Location for Vault Toilet
The proposed location for a new vault toilet doesn’t make sense. The overflow parking lot
only gets used a few days a year while there is a real need for a vault toilet for users of the
Bristlecone Trail. A much more useful location would be near the east end of the main
parking lot near the beginning of the Bristlecone Trail. (O5-10)
Response: The vault toilet is proposed to provide facilities for ski area visitors as well as visiting guests. Its
location was determined to assist those needing facilities away from the mid-mountain base area. The
facility is not intended to meet the needs of Bristlecone Trail (BCT) users.
Cross-country Mountain Bike Trail Alternative
In addition to the proposed [mountain bike] trails, I would like to see:
-a cross-country mountain bike directional perimeter loop
-multiple uphill mountain bike options
Having both XC and DH mountain bike trails will keep Lee Canyon's mountain bike terrain
competitive with other ski resorts throughout the country. (I15-2)
In addition to the Downhill mountain bike trails proposed, I would like to propose the
following:
-a Cross Country (XC) perimeter loop with two uphill options
-limiting the multiuse trails to uphill MTB traffic. (I44-2)
Response: Cross-country bike trails pose a number of management issues at ski areas (e.g., difficulty
segregating uses, limiting use to paying customers, and overall congestion when combined with other trail
types, with associated impact on MCBB habitat). As a result, Lee Canyon has not proposed cross-country
trails.
Alternative Zip Line
I would rather see a zip line park like this https://www.tahoetreetop.com. (I57-2)
Please give us something comparable to this one outside of Buffalo NY. (I61-1)
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Response: These examples are what are typically called ropes courses or aerial adventure courses, not zip
lines, which Lee Canyon has proposed. These comments will be provided to the ski area for their
consideration.
Shuttle Alternative
If you really want to cover parking needs at the ski resort during the ski season, you should
strongly consider a shuttle bus system from the parking area at 95 and Lee Canyon Road
up to the ski resort. (I66-5)
Response: The parking area proposed along with the existing parking and overflow lot is expected to meet
the projected comfortable carrying capacity of the resort with some excess parking space. As discussed in
the DEIS (section 3.11), the additional 500-car parking lot would bring the ski area total to 1,228 spaces.
The additional lot may reduce the number of illegally parked cars by providing non-skiing visitors with
more legal options.
A shuttle system has been attempted in the past, but that experience and similar experiences at other ski
areas suggest that shuttle systems are generally not highly used and thus do little to reduce traffic.
Miscellaneous Alternatives
And if they need one [mountain coaster], it should be a noiseless one far away from the
Bristlecone trail. The zip line should also be far away from the Bristlecone trail. (I104-2)
…would hope that the coaster would not pass overhead of any established hiking trails,
such as the Bristlecone Pine Trail. While proper placement of posts or other support items
may not impede hikers, cars and bridges overhead would ruin the hiking experience. (I28-
2)
Response: The BCT alternative was developed to reduce potential impacts on the BCT. In particular, the
mountain coaster and zip line were moved to the east side of the ski area, away from the trail.
For hiking, I think it would be nice to have a backcountry primitive trail connecting
Bristlecone trail to North Loop trail to the west of Lee Peak also. I realize it's steep, but
would be nice to give advanced hikers that option to summit Charleston Peak from that
direction. It would also be nice to have Bristlecone trail branch off and do other loops, as
it can be boring doing the same trail each time and is nice to have a few destination options
of different lengths. (I109-3)
Response: While opportunities to improve hiking are an important Forest Service consideration, expansion
of the SMNRA hiking trail system is beyond the scope of this analysis.
The ski lift U.S. to [sic] dangerous to take dogs up, so would be nice to upgrade that for
both summer n [sic] winter usage. (I9-2)
Response: The modification of a lift to transport dogs is beyond the scope of this analysis. This suggestion
will be provided to the ski area for their consideration.
Let the [sic] use any of the huge vacant properties to make a virtual canyon forest area.
There are at least a half a dozen vacant mega properties available in the county. (I48-2)
Response: The use of other properties outside the special use permit area is beyond the scope of this
analysis.
Mitigation
Lee Canyon would like to see additional clarification regarding mitigation measures in the
final EIS. Specifically line item 15 is somewhat vague with what would be defined as
“plow/blow”
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15. Do not plow/blow snow into areas of suitable habitat. (O4-5)

Response: The intent of this mitigation measure is to minimize potential impacts to suitable Mount
Charleston Blue Butterfly (MCBB) habitat near roads and parking areas. It does not apply to snowmaking.
The FEIS will reword this mitigation measure to make this clear.
On page 129 measure 9 says to see also measure 17, but there is no measure 17. (O5-4)
Response: An error occurred on page 129. Mitigation measure 9 should have referenced measure 16, not
17. This will be corrected in the FEIS. This will also be corrected in Appendix B.
Mitigation measures to avoid suitable habitat “wherever practical” do not seem sufficient
for a federally endangered species. (O8-2)
Response: Some incidental take would likely be unavoidable. Recognizing that the emphasis is to avoid
suitable MCBB habitat as much as possible and to create more suitable habitat over time, the ski area, in
accordance with the Fish and Wildlife Service (FWS) and Forest Service direction and approvals, would
work to limit any disturbance as much as practical. The specifics would be defined through consultation
between the two agencies in accordance with Section 7 of the Endangered Species Act (ESA).
The DEIS does not provide sufficient information to show that creation of new potential
habitat is enough to mitigate the degradation and loss of occupied or potentially occupied
habitat in other areas. We urge the agency to conduct additional surveys to determine
areas of occupancy within the proposed project area. (O8-11)
Response: As part of this analysis, extensive surveys were completed to identify areas where MCBB host
and nectar plants occur. These areas have been mapped and are known. Extensive efforts were taken during
project design and development of the BCT alternative to minimize potential impacts on them, under the
assumption that if sufficient host and nectar plants to meet the requirements of the MCBB exist, the butterfly
may occur during some years. The result is a sound, conservative estimate of occupied or potentially
occupied habitat for the MCBB on which to base the impact analysis. See the response to comment O8-8
below in the Wildlife section for a discussion of the creation of potential habitat.
For every tree cut an equivalent tree, or a number of trees with equal diameter or
circumference, should be planted. Example: A 12" circumference tree to be cut shall be
replaced by 4 - 3" circumference trees in a location specified by the SMNRA within its
jurisdiction. (I64-1)
Response: DEIS section 1.7.2.2 notes that the effect of tree removal on the ecology of Lee Canyon, a
concern identified during scoping, is not be carried into in-depth analysis. The stated reason is that “This
EIS addresses the direct, indirect, and cumulative impacts of the proposed action and alternatives. Aside
from effects in those categories, the ecology of Lee Canyon is outside the scope of this analysis.” Among
the direct, indirect, and cumulative resource effects of forest clearing and glading addressed in the DEIS
are soil, water, and watershed (section 3.4); wildlife (section 3.6); scenic resources (section 3.8); and
recreation (3.9).
Given that mountain biking will now be permitted at the ski area, it should be banned on
the Bristlecone Trail. (I82-2)
Response: Existing Forest Plan direction on the use of mountain bikes on the BCT will remain in force.
The proposed lift-served mountain biking is a very different type of recreation from the cross-country biking
that occurs on the BCT, and the DEIS (section 3.9) does not indicate the need for this mitigation measure.
Notice and Comment

When the Final EIS is released for public review, please send one hard copy and one CD
to the address above (mail code: ENF-4-2). (A9-6)
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Response: The requested copies will be submitted to the EPA when the FEIS is released.
1. Incorrect address of contact has been listed for both 2017 and 2018 comment times in
the Federal Register and publications using this [as] their reference. – 701 N. Torrey Pines
Dr., Las Vegas, NV 89103. (I49-1)
Response: We will make that correction in future notifications. We appreciate you pointing out our error.
…a mere 45 day comment period does not allow time to adequately digest, respond and
ensure guarantees for successful determination and implementation of Best Practices.
Though a 45 day period is somewhat typical, a 90-day period would be better; a 6-month
period, with workshops among qualified stakeholder participants, would be ideal. (O7-1)
Response: The comment period on the DEIS was 45 days as stipulated in the agency’s notice and appeal
regulations (36 CFR 218.25[a][ii]). We received no requests for additional time during that period.
Implementation Schedule
…elements of the proposed action which might benefit the butterfly, such as the expansion
of ski runs and glading, should be undertaken with a conservative, phased approach. Begin
with a single element, like the Chair 5 pod, and see how the ecosystem responds before
taking further action. (O2-23)
Response: If either this analysis or ongoing consultation with the FWS under ESA Section 7 suggests the
need for the Forest Service to manage the implementation schedule for any authorized projects, the
Responsible Official will identify that requirement in the Record of Decision (ROD).
Other Permits and Approvals

... in Section 1.9 of the EIS, there is no notation that the project will be required to obtain
land use approval by the Clark County Board of County Commissioners through the land
use entitlement process.
In this case, the proposed facility expansion does not fall under the guise of a governmental
use. Instead, the applicant is engaged in a commercial, nongovernmental use. Using the
land as private recreation area on leased federal land would be considered a proprietary
use, and thus, zoning regulations would apply. The facility has, in the past, received County
land use approval for a number of uses and events. (A2-1)
Response: The ski area operates on National Forest System land under a special use permit that authorizes
the permittee to provide recreational opportunities that require specialized infrastructure and cannot be
provided on non-public land. Issuance of such permits allow us to meet our recreational mandates. The
special use permit is not a lease – the permittee neither owns nor has exclusive use rights to the land.
Accordingly, the Forest Service is responsible for land-use management at the ski area. Our Forest Plan, as
amended, the ski area’s special use permit that we issued, and the MDP prepared by the ski area and
accepted by the Forest Service as a condition of the special use permit provide our management direction.
Our special use permit administrator is responsible for implementation of these plans and enforcement of
their terms and conditions. Based on these considerations, Clark County’s land use entitlement process does
not apply to this proposed action.
That said, Lee Canyon does own the buildings at the ski area, and that may bring the county and other
government entities into play. For example, Clark County issues the business license and receives sales tax
revenues. The Southern Nevada Health District regulates food safety and drinking water quality. The
Nevada Department of Environmental Protection regulates septic systems at the ski area.
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Other roles the county may fill, at the county’s discretion, are issuance of building permits, performance of
construction inspections, and provision of final inspection and occupancy certifications. These roles come
into play following NEPA review of proposed buildings, authorization of the buildings by the Responsible
Official, and Forest Service design and engineering review and approval, which includes compliance with
county codes among other standards (e.g., access regulations and design review for conformance with our
Built Environmental Image Guide).
Section 94 of the AQRs requires that a dust control permit be obtained prior to: (i) soil
disturbing or construction activities impacting 0.25 acres or more in overall area, (ii)
mechanized trenching of 100 feet or more in length, or (iii) mechanical demolition of any
structure 1,000 square feet or more in area. When construction activities exist, Best
Available Control Measures (BACM) must be employed. (A1-2)
Section 94 also requires that a construction project of ten (10) acres or more in area,
trenching activities of one (1) mile or greater in length, or structure demolition using
implosive or explosive blasting techniques, shall require a detailed supplement to a Dust
Mitigation Plan. (A1-3)
The following regulations shall apply to areas located in a PM10 nonattainment area, an
area subject to a PM10 maintenance plan defined under 42 U.S. Code 7505a and areas
not regulated by Section 94:
• Section 90 of the AQRs requires owners/operators of vacant lots that are 5,000
square feet or larger and are disturbed by any means to implement applicable
control measures.
• Section 91 of the AQRs requires owners and/or operators of existing unpaved
roads constructed prior to April 1, 2002 to implement applicable control measures.
• Section 92 of the AQRs requires owners/ operators of an existing unpaved parking
lots or storage areas to apply and maintain applicable control measures. (A1-4)
Section 12 of the AQRs requires issuance of a stationary source permit for any applicable
source located in Clark County that has a potential to emit a regulated air pollutant that
is equal to or greater than the thresholds listed in that section. (A1-5)
…contact Clark County Department of Air Quality regarding this proposed project. (A5-
1)
Response: Lee Canyon Ski Area will comply with the cited regulations regarding dust control and acquire
the required permits and approvals for implementation of all activities approved. Table 1-1 of the EIS,
which lists other permits and authorizations that may be required, includes DAQ dust permits. The ski area
lies in HA 211, which is outside the Clark County PM10 maintenance area, so the cited regulations for
nonattainment areas do not apply.
We suggest that the Final EIS include a discussion of how the proposed project would
comply with Endangered Species Act (ESA) requirements, including any necessary ESA
Section 7 consultation with the U.S. Fish and Wildlife Service regarding potential impacts
to the Mount Charleston blue butterfly, or its designated critical habitat. (A9-4)
Response: The Forest Service is consulting with the FWS on potential effects on the MCBB, in accordance
with ESA Section 7. Results of this consultation will be included in the FEIS or ROD as appropriate.
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RESOURCE DISCIPLINES
Soil, Water, and Watershed Resources
…concern related to the potential impacts to Camp Lee Canyon and the existing County
facilities on that site. A detailed drainage study was not submitted that verifies that soil
erosion or drainage issues can be mitigated on-site to not increase any off-site flows. (A2-
2)
Response: Results of a detailed runoff study, including five drainages that generate runoff in the permit
area, are included in DEIS section 3.4.3.2.1 for the proposed action and in section 3.4.3.3.1 for the BCT
alternative. The results include runoff from storm events with a 2-year, 25-year, and 100-year frequency.
These results include peak runoff estimates that would occur from drainages affected by each alternative if
the proposed activities were approved. Results are summarized for current conditions and also for each
alternative with and without a detention basin under three scenarios including no BMPs, physical BMPs
only (i.e. no revegetation), and full rehabilitation (including physical BMPs and full vegetation regrowth
on disturbed areas).
As described in section 3.4.1.1.1, the proposed parking lot would be designed to function as a detention
basin to manage peak runoff following intense rain events. The peak runoff estimates in Table 3-11 are
made at the discharge outfall from the parking lot/detention basin just above Camp Lee Canyon. Based on
modeled estimates, peak runoff under the proposed action would decrease by roughly 1 to 65 percent
compared to current peak flows after all mitigation measures were implemented. These results indicate that
runoff and erosion issues can be mitigated on-site without a corresponding increase in flows leaving the
permit area.
Conservative assumptions were used as part of the runoff study, and actual runoff from storm events could
yield less runoff. Section 3.4.1.1.1 states “…additional project-specific modeling after projects are
approved could be done to improve accuracy of estimates and possibly require less extensive mitigation,
such as a smaller detention basin.”
Ensure that the water use does not exceed the permitted withdrawal/diversion limits. Any
water used for construction related activities such as dust suppression must be from a
permitted right with a manner and place of use that is applicable for construction activities.
(A7-1)
…my major concern was/is the amount of additional water draw for the additional snow
making while increasing the year round use of the area. Despite questioning the impact of
drawing ever more water while less snow is falling for fewer months resulting in less water
available to the biological systems and the springs, most of which have not surface [sic]
for the past two spring/summers, I see absolutely no mention of this in the EIS. (I18-1)
…the southwest is experiencing an increasing and long term drought that the additional
snow making and increasing the year round use completely ignores.
There should be an addendum to the EIS addressing the increased draw down of water for
additional snow making over a larger area for a longer part of the winter ski season. (I18-
4)
I have concerns regarding the use of two snowmaking lines, using “available water”…
Where is the water coming from and what do we do when it is gone. (I53-1)
I have some concerns about the saucers zooming through butterfly habitat and artificial
snow making. (Where is the water coming from? How is the melt controlled? Are there
chemicals or additives that will seep into our aquifers or runoff? How much energy is used
in the process? (I50-1, see also Wildlife)
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Response: The proposed action does not include increased water use to support the proposed additional
snowmaking. DEIS section 1.7.2.1 states:
The proposed action does not include increased water use for snowmaking. The ski area
employs snowmaking to supplement natural snow and maintain coverage for a safe and
enjoyable skiing experience, not to extend the ski season. The snowmaking system draws
from the existing reservoir, which is filled with water from the Three Springs complex
above the reservoir within the ski area boundary. Three wells are also pumped as needed
to fill the snowmaking reservoir. Water use is determined primarily by climatic conditions
– i.e., the adequacy of natural snow coverage and whether temperatures allow snowmaking
when additional coverage is needed. The proposed snowmaking system expansion is
intended to provide the ski area the flexibility to use available water to make snow where
it is most needed at any given time.
The water rights associated with the ski area are held by the Forest Service, and those rights
are for significantly more water than the ski area has ever used. Phase 2 of the MDP
includes a second snowmaking reservoir that would bring more water rights into active
use. However, the second reservoir has not been proposed. The ski area has been actively
investigating alternative sources for snowmaking water, beyond Three Springs and the
three existing wells, but none have been identified. As a result, no additional water sources
have been proposed, and increased water use is outside the scope of this analysis.”
The existing snowmaking system does not use chemicals or any additives to make snow. This would not
change if the snowmaking expansion were approved.
EPA also suggests that the U.S. Forest Service consider other options to address
stormwater runoff, including using permeable pavement. (A9-3)
Response: We will consider requiring permeable pavement in the proposed parking lot. However, this may
not be a feasible option to reduce stormwater runoff. As discussed in 3.4.1.1.1, the parking lot would
function as a stormwater detention basin during the summer season when high-intensity rain storms
generate surface runoff. The basin would collect and temporarily detain surface runoff from the resort as
well as sediment and other suspended material transported by runoff. Suspended material in runoff would
settle into pores of permeable pavement and likely reduce function and operational lifetime of permeable
pavement. Although sediment would be cleaned from the detention basin each year (or more often if
needed), cleaning would not restore permeability.
With over 100 acres of new disturbance proposed soil erosion is obviously a major
concern. Significant space in the document is devoted to this topic. However, other than
many references to “best management practices” (BMP) there is not much in the way of
specifics on how the problem will be addressed. Soil erosion is a significant issue on the
existing ski runs, even though the managers have had decades to solve the problem. (O5-
7)
Mountain bike trails are notorious for erosion problems as well as user modifications to
increase downhill speed. Mountain bike trails on slopes with erosive soils have to be
hardened if they are going to be sustainable, or be very carefully constructed so that all
the sand and fines aren’t washed away to just leave a rock pile. (O5-9)
Response: DEIS section 3.4.3.2.2 and section 3.4.3.3.2 include a detailed description of potential soil
erosion impacts for individual projects. The method used to address soil erosion (i.e. the CDA approach) is
clearly described in section 3.4.1.1.2. These methods recommend BMPs that address site-specific
conditions at each project location known to influence soil erosion. As stated in section 3.4.1.1.2, some of
these conditions include erosion hazard, disturbance size and intensity, slope, and distance to the nearest
runoff pathway. Numerous BMPs are recommended in Tables 3-10 and 3-13 that account for these
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conditions and other factors observed at individual project locations. Footnote 3 in each table indicates that
additional detail is provided in Appendix B for each BMP. Additional BMPs not listed in Tables 3-10 and
3-13 are described in specific detail in section 3.4.5.
The primary source of BMPs in Tables 3-10 and 3-13 is a nationally recognized and Forest Service
approved document. Most practices in section 3.4.5 are from Lee Canyon’s Erosion Control Plan, as well
as handbooks specific to the ski industry and construction trades in the state of Nevada. Prior to beginning
construction, state and county law requires review and approval of a Storm Water Pollution Prevention Plan
(SWPPP, Section 2.6). The SWPPP requires additional BMPs based on site drawings and construction
details. The level of detail included in a SWPPP is typically not prepared until after individual projects are
approved as part of the NEPA process. The information referenced here in Chapter 3 and Appendix B
addresses soil erosion concerns at a level of detail required for environmental analysis.
Soil erosion is an ongoing concern at Lee Canyon, most of which is due to a lack of established ground
cover. The Forest Service is continuing to evaluate a seed mix that will both support desired natural
conditions and provide habitat for wildlife species. In the meantime, structural controls (e.g., berms, ditches,
and maintenance activities) are being used to minimize erosion impacts and restore damaged areas.
Finally, note the ski area has engaged Gravity Logic, a world leader in the design of safe, sustainable
progressive mountain bike trails for summer resort operations. At this point, only initial trail layout has
been completed. Final design will reflect design criteria, construction practices, and BMPs that will
minimize erosion risk and other adverse environmental effects.
The subject of climate change with regard to intensity of summer thunderstorms is briefly
discussed on pages 46 and 47 with the conclusion that there will not be much impact. That
conclusion is based on the separate studies by Tausch and Halofsky that addressed the
issue for the entirety of the HTNF and intermountain region respectively. Based on my
own, admittedly anecdotal, observations in this area over the last 40 years I think that the
intensity of summer thunderstorms is increasing and will potentially have a significant
impact on erosive runoff at the Lee Canyon Ski Area. If in doubt on this point, one merely
needs to look at the erosion damage in Lee Meadow, just downhill from the ski area, that
has happened in the last few years. (O5-11)
Response: First, we should note that the cited studies do not just look at the HTNF and the Intermountain
Region as wholes. Both break their analysis down, addressing sub regional and localized effects.
Climate change and summer thunderstorm intensity is addressed several times in the EIS, including section
3.4.2.1. Results from Halofsky et.al are accurately summarized in that section and indicate that spring and
early summer precipitation events may be reduced somewhat over time (p. 61, Halofsky et al. 2018). In
regard to recent historical summer thunderstorm intensity, available data from a nearby SNOTEL
precipitation site in Lee Canyon was used to examine seasonal patterns and trends. Although this record
extends only 10 years, it does capture several storm events that are similar to the magnitude of 2-year and
25-year events. The magnitude of storm events used to estimate peak runoff for the Lee Canyon area were
determined from the updated NOAA Atlas 14 Volume 1 and follow approved hydrologic methods.
Section 3.4.3.2.1 describes impacts of intense summer thunderstorms on surface runoff during 2-, 25-, and
100-year storm events. These impacts account for changes in land cover that would occur under the
proposed action. The modeled results show that recommended BMPs, when fully implemented, reduce
peak runoff estimates slightly below existing levels.
As professionals you must know the fragile nature of this area. The annual snowfall has
never been predictably adequate even for the existing facility. Does someone think that is
going to improve? Well all you need to do is pump from an aquifer of unknown size with
limited recharge! (I35-1)
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Response: Processes that influence snowfall accumulation and coverage are described in DEIS section
3.4.2.3. As indicated above, current water use is determined by climatic conditions – i.e., the adequacy of
natural snow coverage and whether temperatures allow snowmaking when additional coverage is needed.
Beyond that, the proposed action does not include increased water use to support the proposed increase in
snowmaking system coverage.
There is little specific information on how the areas to be cleared under the proposed
action will be revegetated although it is stated that irrigation may be necessary. Irrigation
requires a lot of water, potentially much more than snow making. If irrigation is part of
the rehab plan then how this will impact the supply of water for snow making needs to be
spelled out. (O5-8)
2. Water table issues related to tree and understory plant removal
a. Trees remarkably slow the egress of rain and snow from the slopes to the
ground water table.
i. Note volume of water which caused significant damage to roads
crossing the ‘creeks’ path alongside highway 156 at the current
density of tree/understory shrubbery/grasses after rainfall August 16,
2018: https://www.youtube.com/watch?\=79SICzOAOM4 “Lee
Canyon flood August 16, 2018”
a. This rainfall also created 1-2’ drops below stone steps along Upper
Bristlecone trail where rainwaters followed the trail.
i. Personal observation on August 18, 2018.
b. Without the current tree cover, how much forage will be lost without requiring
irrigation. Where will the irrigation water come from as water retention will
be lost without the Tree/shrub cover slowing heavy rainfall runoff.
c. Seeding bare slopes is minimally effective at reducing heavy rainfall as
occurred 8/16/2018.
i. Most grass seeded clear cut ski slopes are eroded (personal
observations over decades of using ski slopes, summer and
winter). (I49-3)
Response: The cited mitigation measure that mentions irrigation is drawn from a standard measure in the
Forest Service National Core BMPs for ski lifts and runs. Irrigation is not a component of planned
revegetation efforts (see first response below under Vegetation), but it might be appropriate, on a limited
basis, after a seed mix is approved by the Forest Service. Disturbed slopes could then be seeded, and
temporary, localized irrigation could be used to improve germination and establishment of vegetation
during a dry spring. The amount of water used would be insignificant, and irrigation is a beneficial use
assigned to existing water rights. Beyond that, irrigation would take place during the opposite season. Based
on these considerations, no impact on water available for snowmaking is anticipated.
DEIS section 3.4.2.1 describes the precipitation regime, noting that surface runoff occurs only when
precipitation exceeds the rate of infiltration, and that intense summer storms account for the cited issues
with runoff and erosion. Compared to intense summer storms and runoff, snowmelt is a much slower
process that generates modest runoff and provides ample opportunity for infiltration and recharge.
Section 3.4.3 describes the effects of the proposed action, including clearing and glading, on runoff and
erosion. It is important to note that trees and shrubs protect soil from the impact of falling rain, but they can
also inhibit understory plant growth. In comparison, understory vegetation can reduce surface runoff by
creating a consistent surface cover and increased surface roughness. These two factors slow runoff and
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provide opportunities for infiltration and groundwater recharge. Ongoing erosion is minimal from ski runs
where understory species have naturally reestablished and provide a consistent surface cover.
In the absence of revegetation via reseeding, Tables 3-10 and 3-13 include physical BMPs that would slow
surface runoff, promote infiltration and groundwater recharge, and minimize soil erosion until revegetation
occurred either naturally or following reseeding. See also the first response in this section above.
Vegetation
The DEIS provides no information for how newly opened slopes or other graded areas will
be revegetated, and it makes revegetation seem optional in one instance (“Any revegetation
that does occur under the proposed action would use an approved seed mix.” DEIS at 63).
Revegetating graded areas is absolutely essential for the project to meet erosion standards
put forward in DEIS §3.4, and is a precursor for such graded areas becoming suitable
MCBB habitat, which the entire proposed action is contingent upon. And yet the Forest
Service appears to be punting on the whole topic of revegetation until such a time as a seed
mix can be approved, an issue which apparently has been unresolved for twelve years (“In
2006 the Forest Service suspended revegetation efforts, which had been successful at
reducing erosion in the past, with the objective of developing a revegetation seed mix that
included more native plants,” DEIS at 51). It is unacceptable for the Forest Service to
defer devising a revegetation plan until an appropriate seed mix can be approved,
particularly if the selection of the mix has been such a vexing problem that it has remained
up in the air for over a decade. (O2-11)
The Forest Service must revise the DEIS to disclose and analyze a substantial and detailed
revegetation plan particularly for the graded ski slopes. (O2-14)
Response: These comments raise two related issues, revegetation for erosion control and revegetation for
MCBB habitat restoration. The MCBB habitat question is addressed in the next response below. This
response focuses on the erosion-control aspects of revegetation. DEIS section 3.4.2.2 summarizes the
background leading up to the SMNRA suspending reseeding efforts in 2006 pending identification of a
suitable seed mix, and the resulting emphasis on physical erosion control measures at the ski area. The Las
Vegas Ski and Snowboard Resort Master Erosion and Sediment Control Plan produced by Stantec Inc. in
2008 and cited in DEIS section 3.4.2.2 reflected this approach, noting that revegetation efforts were
“stalled.” That plan was one of several sources of mitigation measures included in the DEIS (section 3.4.5
and Appendix B).
The 2008 plan guided rehabilitation of areas disturbed by the Chair 2 replacement in 2014 and the
snowmaking reservoir expansion in 2010. Both sites were successfully stabilized without reseeding.
However, as discussed in DEIS section 3.4.2.2, intense summer rainstorms have continued to cause serious
erosion on some ski runs. This is due in large part to the ski area’s inability to maintain erosion-control
structures in potential MCBB habitat. Maintenance activities are part of the ESA Section 7 consultation
being completed in association with this EIS, so the constraint on maintenance of erosion-control structures
will be removed if the proposed action or action alternative is approved.
In terms of projected impacts, the analysis documented in DEIS section 3.4.3.2.2 explains that erosion
hazard was rated based solely on physical mitigation and then rated again following revegetation. The text
notes that natural revegetation would take longer than reseeding, and in the interim erosion risk on proposed
ski runs would be moderate. Once revegetation occurred, either naturally or through reseeding, the risk
rating would fall to low.
It is important to note that most of the occupied and suitable MCBB habitat at the ski area occurs on
historically cleared and graded ski runs, indicating that natural revegetation has occurred and can occur
again, given the seed already present in the soil. With properly constructed and maintained erosion control
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structures to keep the soil in place, the low erosion risk assigned to proposed ski runs following revegetation
can be achieved, whether it is via seeding or natural revegetation.
Developing a suitable seed mix for Lee Canyon is taking a long time because it is complicated. Native seed
mixes are desired for several reasons (e.g., agency policy, and protection and maintenance of endemic plant
and animal species including MCBB). However, plant species native to the area may not be well suited to
artificial seeding (e.g., low germination rates) or have appropriate growth forms to offer timely erosion
control. In addition, seed or seedlings for many of these species are not commercially available.
As a result, until an approved seed mix was available, erosion would be controlled through the intensive
use and maintenance of the physical measures described in the DEIS (Tables 3-10 and 3-13, Section 3.4.5,
and Appendix B), and a revegetation plan per se is not appropriate. A weed control program (sections
3.5.3.2.2 and 3.5.3.3.2) would be employed to minimize infestation of disturbed areas. Together, the erosion
and weed-control measures would increase the likelihood of natural regeneration of desired, native species.
Dr. Thompson has been engaged in an effort of no fewer than eight years to understand
the complex ecology of the Mt. Charleston butterflies, including the blue, and he and Dr.
Abella brought that knowledge and experience to bear in crafting a lengthy and detailed
prescription for habitat restoration and enhancement for the MCBB in the SMNRA. (O2-
12)
Response: The research of Thompson, Abella, and other specialists, including and beyond the habitat-
enhancement prescription cited in this comment, was thoroughly reviewed in preparation of the DEIS. The
seeding/transplanting recommendations in the prescription are primarily to create habitat where there
previously was none. However, as noted in the preceding response, seeds of MCBB nectar and host plants
are present in the soil at the ski area, and surveys completed in 2016 for this analysis (DEIS section
3.6.2.1.1) show that these species are currently present on most of the areas that would be disturbed under
the proposed action. While densities are low in some areas, seed is clearly present.
As a result, our analysis drew more on aspects of Thompson and Abella’s recommendations other than
reseeding/transplanting nectar and host plants. In areas where appropriate plants are present, their main goal
for restoration efforts is to enhance habitat in areas with high probability of being colonized by MCBB
through efforts including reducing forest cover and increasing connectivity between occupied areas and
available habitat. As described in the DEIS section 2.2, enhancement of habitat for MCBB and other plants
and animals sharing its habitat through canopy removal and increased connectivity was a formative factor
in development of the proposed action.
Puzzlingly, while Thompson and Abella find that chipped slash must be kept to 3” or less
to prevent negative impacts on herbaceous understory (such as MCBB host and nectar
plants), the DEIS states that chipped slash will be no deeper than 4”. The DEIS should be
revised to be in accordance with the best available science, and keep chipped slash no
deeper than 3”. (O2-13)
Response: Based on published literature, the FEIS will be revised to limit the depth of chipped slash to 2
inches, and to note that no wood chips will be applied on suitable MCBB habitat.
Inaction is not an option. The proposed action and BCT alternative require grading 88.5
and 74.2 acres respectively. Leaving tens of acres of bare dirt unrevegetated is simply
asking for invasive species to spread. The exact methodology of determining the invasive
species risk assessment (DEIS at 94) is opaque, and the mass grading particularly of the
ski slopes is given a “moderate” rating, with impacts to be ameliorated by design criteria.
However there are no design criteria for preventing the on-site transmission of invasive
species, and certainly none that can prevent windborne invasives from taking hold on the
freshly graded slopes.
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… Allowing the proposed action or BCT alternative to proceed without a revegetation plan
is absolutely unacceptable and sets the stage for the project resulting in dozens of acres of
invasive species while resulting in the degradation of the overall condition of the MCBB’s
critical habitat. (O2-14)
Response: As described in section 3.5.2.2.4 of the DEIS, the method for determining invasive species risk
is based upon the likelihood of undesirable plants spreading to the project area, and the consequence of
undesirable plants becoming established in the project area (Table 3-17). The product of those two factors
is used to determine a risk rating (Table 3-18). The rating considers the adjacency of weed infestations as
a key component in that risk assessment. Section 3.5.2.2 describes the locations and extents of invasive
species in the project area, and sections 3.5.3.2.2 and 3.5.3.3.2 provide information on whether invasive
species are located within the proposed disturbance areas.
Projects with low, moderate, or high risk ratings require actions that involve treating any undesirable plant
species that may become established. Those actions would apply regardless of the method of transmission
or establishment, including windborne species. Design criteria 8 and 10 (section 2.6) described in the DEIS
have been included expressly for the control of invasive species until revegetation takes place. Revegetation
is addressed above.
There is also the entirely separate issue of off-trail mountain bike use. The DEIS gives
scarce mention to this possibility, and summarily dismisses it as an issue on page 90. The
DEIS primarily addresses this issue by providing a set of user-education focused mitigation
measures (signage, brochures, and verbal reminders) and the possibility of “rope lines to
minimize entry into suitable special-status species and wildlife species habitat” (DEIS at
101). (O2-19)
Response: As stated in DEIS sections 3.5.3.2.1 and 3.5.3.3.1, off-trail incidents such as falls and crashes
from developed bike trails could have the potential to impact species if they occur in occupied habitat.
While it is possible that mountain bikers could leave the trail, it is unlikely. Experience at other bike parks
shows that visitors who purchase or rent a specialized downhill mountain bike and pay for a lift ticket stay
on park trails designed specifically for their enjoyment. Beyond that, Lee Canyon would manage the use of
proposed trails through terms and conditions associated with ticket purchase. These terms and conditions
would be enforced by a bike patrol, similar to how ski patrol enforces winter rules. Those who bike or hike
off-trail would have their tickets revoked and would lose access to the trail system, similar to skiers and
snowboarders who enter closed areas. Managing trail use in this manner would improve mountain safety
and protect special-status plant and wildlife habitat.
Also Rough angelica, common in Kyle Canyon, is not known to occur in Lee Canyon,
although a similar species, King angelica, does occur. Table 3-14, p 76, even states that
Rough angelica is not known to occur on the site! (O5-3)
I am distressed to find statements in this document that contrast each other. For instance,
rough angelica (Angelica scabrida) does not occur in Lee Canyon (Glenne and Johnson
2002; Hiatt and Boone 2003) and the DEIS states as such on page S-5. However,
throughout the DEIS, statements were made that rough angelica would not be impacted as
if it occurs in Lee Canyon. How could it be impacted when it does not occur in Lee Canyon?
(I45-4)
Response: The statements regarding rough angelica are correct and do not conflict. This species is
intentionally included in the full list of potentially occurring special-status species, as an MIS associated
with the Mixed Conifer and Upper Wash land type associations, and as it relates to compliance with
SMNRA-wide Standard 0.31, which addresses not only individuals but potential habitat. Table 3-14 notes
that there is limited habitat at springs at the ski area. Section 3.5.2.1.3 indicates that this habitat is not in an
area that would be disturbed. After including this species in these established categories, the document
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clarifies that rough angelica is not present in the project area and is not carried into detailed analysis, where
appropriate. Since Standard 0.31 includes effects on potential habitat, and potential habitat occurs at the ski
area, it is appropriate to address the species in the analysis.
We also need to see a discussion of the nature of disturbance needed to ensure survival of
aspen groves, which have very high wildlife value. I’m sure the Forest Service will say that
these issues are beyond the scope of analysis, but I would argue that a bigger watershed
analysis would help put things into perspective and make sense from the perspective of
meaningful long term resource management. (O5-13)
Response: The effect of the proposed action on aspen is described in section 3.5.3.2.1, which notes that
there are 223 acres of aspen stands inside the ski area permit boundary. The proposed action would affect
95 acres, or 43 percent, and the BCT alternative would affect 88 acres or 41 percent. To address effects at
the SMNRA level, a coarser-scale (i.e., based on patches larger than 5 acres) vegetation data set was
consulted. Based on that data, the proposed action would impact 2.8 percent of the SMNRA aspen habitat.
The BCT alternative would impact 2.5 percent. These levels of impact would not have a substantive effect
on aspen populations in the planning unit. The FEIS will include this analysis.
I still feel not enough planning has been done to protect the biodiversity hotspots and the
number of sensitive plants. (I45-1)
Response: The effects on sensitive plants species are described in DEIS section 3.5.3.2.1, which quantifies
impacts on each individual sensitive species. The only species with a notable adverse effect projected under
the proposed action is Clokey’s eggvetch. However, the BCT alternative would reduce the impact on
Clokey’s eggvetch from 13 to 2 percent of surveyed, occupied habitat (section 3.5.3.3.1). This reduction
would mean that the BCT alternative may impact individuals but is not likely to cause a trend toward federal
listing or loss of viability of that species.
The EIS does not mention Rocky Mountain Juniper (Juniperus scopulorum) in the ski area.
I have observed a number of these Pleistocene remnant trees during hikes in 2004, about
500 feet due northwest of the lower terminal of Chair 8 in the BCT Alternative. Fortunately
there are currently no plans for development in the area of Rocky Mountain juniper trees
and it should stay that way. (I45-5)
Response: The discussion in the EIS is limited to designated special-status species. Rocky Mountain juniper
was observed during plant surveys in 2016 and 2017. It has not been assigned a conservation status in
Nevada, though it has a G5 (Secure) status globally. It is not considered threatened, and thus has no
protective designations. As noted by the commenter, there are no plans for development in the area where
Rocky Mountain juniper trees are found.
Wildlife
General
It is also disappointing to see obvious errors in the document such as occur in Table 3.6.2.3
[Table 3-23] on page 110, where chuckwallas are listed as inhabiting cliff areas on the
site. Chuckwalla habitat is limited to elevations below 5000 feet. (O5-2)
Response: The SMNRA establishes the land type associations and their associated management indicator
species. It does not distinguish between high elevation or low elevation cliff communities. Therefore, Table
3-23 includes species found in the listed communities regardless of whether the species would occur in the
project area so long as the community occurs in the project area. The paragraph directly above Table 3-23
clarifies that the project area is above the maximum elevation range of chuckwalla and dismisses it from
further discussion.
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Winter use of upper Lee Canyon has little to no impact on wildlife because is [sic] wildlife
is either absent or dormant during the winter. However, a major expansion of summer
recreational activities will have impacts on wildlife and they will not be beneficial. (O5-6)
Response: Section 3.6.3 discloses the direct and indirect effects of the alternatives on wildlife including the
potential effects of the proposed summer recreational activities. Section 3.6.4 discloses the cumulative
effects on wildlife species.
We [the EPA] also suggest any relevant documents associated with the ESA Section 7
consultation process, including any Biological Assessments and Biological Opinions, be
summarized and included in an appendix to the Final EIS. (A9-5)
Response: Pertinent conclusions of the BA and BO will be added to the FEIS, and both the BA and the BO
will be included in the project record.
What is the impact of this on wildlife, such as horses, deer, and wildcats. (I3-1)
The DEIS does not address the Rocky Mountain Elk that inhabit the Spring Mountains. In
2017, NDOW noted 146 elk in the Spring Mountains. The small population make elk an
interesting part of this area and worthy of discussion in this EIS as well as design criteria
to protect their habitat. (I46-1)
Response: The purpose of NEPA is to identify significant environmental impacts, not all environmental
impacts. Accordingly, the DEIS addresses potential impacts on threatened, endangered, and candidate
species; Forest Service sensitive species; SMNRA management indicator species; Spring Mountains
Conservation Agreement species of concern; Clark County Multiple Species Habitat Conservation Plan
covered species; and migratory birds (DEIS section 3.6.1). While many other species occur in or near the
project area, including those noted in these comments, they are either managed by other plans (e.g., wild
horses and elk) or are common enough that the proposed action could not significantly affect them.
3. Detrimental effect of Tree removal for new ski trails on birds and other small forest
animals.
a. One of the things that the Upper Bristlecone trail offers is an abundance of
Birds. Caution is warranted, as the removal of trees for the ski resorts original plan and
BCT alternative both may negatively effect [sic] this experience.
b. https://www.researchgate.net/publication/258627337_The_Effect_of_Ski-
Pistes_on_Birds_and_Mammals
i. “Ski-pistes below the tree line produce a negative edge effect: forest
plots at the edges have lower bird diversity and species richness than those far from
edges,…Moreover, plots adjacent to ski-pistes support a significantly lower bird
abundance than plots far from ski-pistes, suggesting these ski-pistes, besides exerting a
direct negative effect upon their avifauna, may also exert an indirect, detrimental effect on
the number of individuals utilizing nearby areas. Small forest mammals clearly avoid ski-
piste:s…”(I49-4)
Response: Potential impacts on special-status birds under the proposed action and the BCT alternative are
discussed in sections 3.6.3.2.6 and 3.6.3.3.6 of the DEIS, respectively. To summarize, the BCT alternative
would have less of an effect on birds in the vicinity of the BCT than the proposed action due to the relocation
of proposed infrastructure and shortening of proposed ski runs to move them away from the trail instead of
overlapping it. See the preceding response regarding common species.
It appears that the Forest Service intends to design the mountain bike trails in the
alternatives to be outside of a 5 meter buffer surrounding suitable MCBB habitat. (DEIS
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at 129) However, there is no justification provided as to why a 5 meter buffer around

suitable habitat would provide adequate protection for the MCBB. It appears 5 meters has
been arbitrarily chosen. Indeed, previous research on the topic of butterfly interactions
with on-trail recreationists suggests that 20 meters may be a more appropriate buffer, as
researchers found a “significant difference” between female butterfly oviposition in
habitats up to 15m away from a trail or greater than 20m away; and a “significant
difference” between host plant choice in habitats up to 15m away from a trail or greater
than 20m away.10 We would encourage the Forest Service to revise the DEIS to include a
more robust buffer, and a scientific justification for the choice of buffer size. (O2-15)
Response: The key distinction here is that the cited research (Bennett et al. 2010) addressed recreational
trails that adjoined occupied butterfly habitat, while these proposed bike trails would be no closer than 5
meters from suitable habitat (this buffer is now incorporated directly into the methodology for identifying
habitat in the BA, removing the need for bike trails to be further than simply outside of marked suitable
habitat). The proposed 5-meter buffer was derived from the same research, which indicated that butterflies
did not detect passersby beyond distances of 0.62 to 4.21 meters, or an average of 1.74 meters. Therefore,
5 meters was used as a very conservative buffer distance. The significance of the buffer is that it prevents
the initial startling of individual butterflies that in turn can startle others and potentially affect oviposition
up to 20 meters away. Without the initial startle effect to begin this cascade, there is no impact.
The mitigation measures appear to be recommendations rather than requirements. For
instance, wildlife mitigation measure 3: “Wherever practical, avoid impacting marked
suitable MCBB habitat…” (DEIS at 129) And wildlife mitigation measure 9 is similarly
non-binding: “If possible, use access routes that do not cross, or enter within a 5 meter
buffer around, suitable habitat.” Enigmatically, mitigation measure 9 then says, “If not
possible, see measure 17,” which does not exist. The Forest Service must revise the DEIS
to be clearer about how vehicles and construction equipment will access the project site.
(O2-16)
Response: The reference to mitigation measure 17 should have been to measure 16. This will be corrected
in the FEIS. The reason why the cited mitigation measures use conditional wording such as “wherever
practical” and “if possible” is that some adverse impacts on suitable MCBB habitat may be unavoidable.
FEIS sections 3.6.2.1.1 and 3.6.3.2.1 have been revised to explain that the estimate of suitable habitat in
the project area is conservative (i.e., an overestimate), that the projected disturbance acreage is the
maximum possible, that mitigation would be in place to reduce the actual extent of disturbance, and that
the total disturbance of suitable habitat could not legally exceed the “incidental take” acreage that will be
established by the FWS based on ESA Section 7 consultation that is underway.
The Forest Service makes the unsupported claim that development of a downhill mountain
biking trail system would reduce off-trail foot use within the ski area (DEIS at 115). This
is hogwash. To begin with, the Forest Service presents no data regarding current off-trail
foot use, and verbal communication indicates that no such data exists, so there is no
baseline for making such an assertion. A visit to the ski area on a busy summer day reveals
dozens of people in the base area, and a handful riding the chair lift, but almost nobody is
marauding the ski slopes (i.e. the suitable MCBB habitat) at will, as the DEIS claims
currently occurs. As it exists, it appears there is little off-trail use by humans of occupied
MCBB habitat at the ski area. (O2-17)
The mountain bike proposal has several glaring problems. The blue butterfly is endangered
as attested by the current and proposed signage and yet the ski area proposes "glading"
paths for skiers that would improve butterfly habitat but does not indicate whether
mountain bikers would also be using these gladed areas as they descend thus destroying
the butterflies and the plants they depend on. Further on the EIS states that mountain bike
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trails would "traverse lower quality potential or historically occupied habitat." I am not
sure how destroying "lower quality" habitat and historically occupied habitat improves the
more important issue of species preservation. (I18-3)
Having a larger trail network up there will also help to increase the awareness of the
butterfly habitat and allow for hikers to stay on a trail through the are instead of making
their own. (I6-2)
Response: This comment incorrectly paraphrases the DEIS. The cited text in section 3.6.3.2.1 deals with
the hiking trail, not biking trails, explaining that currently the ski area has no control over where people go
since it is public land. People do indeed hike around, most riding the lift up and making their way down
where they choose, as there are currently no designated trails. Under the proposed action, a dual use
hiking/biking trail would provide a designated route down, and the ski area would be able to enforce
requirements to stay on the trail due to safety and habitat-protection concerns. This would reduce off-trail
use.
Some proposed biking trails go through the proposed gladed areas, but bikers would be restricted to the
trails and not the gladed areas as a whole. The potential effects of bike trails, including those passing through
glades, are documented in DEIS section 3.6.3.2.1.
As noted in that section, under the current, preliminary alignments, some bike trails go through cells that
are identified as having some potential MCBB habitat or areas where historically biologists have delineated
habitat. However, mitigation measure 10 in DEIS section 3.6.5 states that during final trail layout, “no
mountain biking or hiking trails will be placed within the 5-meter buffer around marked habitat.” This
measure is likely to be revised for the FEIS based on the changes in how MCBB habitat will be delineated.
However, in any case, implementation of this mitigation measure would preclude the potential impacts
attributed to preliminary trail alignments noted in the DEIS. The FEIS will reflect effects of this mitigation
measure on bike trail associated impacts.
By contrast, the proposed action or BCT alternative would introduce literally tens of
thousands of people to this sensitive habitat in the summer. We don’t know exactly how
many (see discussion above), but the estimates are between 10,000 and 25,000 mountain
bikers alone, plus untold numbers of hikers, roller coaster riders, zip liners, and other
recreationists. The total number, if taken from the inferences in the DEIS referenced above
in Section 3 of this letter, could be somewhere between 20,000 to 50,000 users per summer.
If even a small fraction of a percent of these people begin to walk around off-trail in
suitable MCBB habitat, it will constitute a significant increase in impacts to suitable
MCBB habitat from off-trail foot users as a result of the proposed action or BCT
alternative. (O2-18, see also Recreation)
Off-trail use through suitable habitat could result in significant habitat fragmentation,
erosion, loss of plant cover, loss of host or nectar plants, crushing of eggs or larva, and
other impacts to the MCBB. (O2-20)
This will reduce the habitat for all species, including, I believe, the endangered Mt.
Charleston blue butterfly. (I8-2)
Along with some butterfly experts, I realize that, if properly designed and implemented,
some resort work could open up the forest canopy and improve the species habitat.
However, because the species breeds during the summer, the expansion for summer
commercial recreation could offset these potential benefits and possibly cause more
adverse impacts on the species than the status quo situation. (I103-2)
Response: The DEIS addresses the potential effects of increasing summer use on the MCBB and identifies
a number of ways that potential adverse effects would be mitigated (see 17 mitigation measures in section
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3.6.5). As discussed in the preceding response, development of designated trails would allow the ski area
to manage summer use in ways they cannot now. In accordance with mitigation measure 10, trails would
be routed outside suitable habitat and its surrounding buffer zone. Other summer infrastructure was sited
outside buffered habitat during initial design. Per mitigation measure 17, education, signage, and fencing
measures would also be used to protect special status wildlife, particularly the MCBB. Beyond that, all
ticketed activities would include a user agreement to abide by rules restricting use to designated trails, and
the ski area would have the authority and responsibility to enforce them, including employing trail patrols
similar to ski patrol. All in all, the analysis indicates that with this mitigation in place, the potential impacts
of growing summer visitation on the MCBB and other special-status species would be managed and
minimized in ways that are not currently possible.
Lee Canyon overall agrees with the methodology that has been applied to calculate the
potential impact on the MCBB if a mountain biker were to fall off a trail into a buffer area
around suitable habitat for the MCBB. We however believe the incident rate listed in the
below paragraph may be somewhat overstated [at] 10 incidents per day. In order to
directly impact the MCBB, these accidents would have to occur within the approximately
1.7 percent of the trail system that would be within 8 meters (5 meter buffer plus a 3 meter
accident impact area) of suitable habitat.
Our understanding is most of the suitable habitat areas are in more open areas, such as
ski runs. Bike trails will usually be going in a straight line, traversing a ski run rather than
having any corners. This should greatly decrease the likely hood of a biker falling in these
areas. (O4-4)
Response: We recognize that 10 incidents per day is a conservative estimate to ensure that potential impacts
on the MCBB would be fully disclosed. The DEIS also points out that 0.8 acres of estimated suitable habitat
would be within 8 meters of the trail system which represents 4 percent of the estimated suitable habitat at
the ski area. Therefore, the risk of biker falls to the MCBB would be small. Note that the methods for
delineating suitable habitat prior to construction may change slightly as a result of ESA Section 7
consultation. Any such changes will be reflected in the FEIS.
I am somewhat alarmed that the DEIS states that, “There is no literature available
describing the impacts of human disturbance on the MCBB.” (DEIS p.107) I know for a
fact the works of Spring Mountains Lepidopterist Bruce Boyd, in surveys, communications
and website pages, provide numerous descriptions of human impacts on butterflies and
their habitats, including those of the MCBB. These sources should be available in both
USFS and USFWS archives. (O7-4)
Response: The quoted statement in the DEIS was specifically related to impacts of human disturbance (i.e.,
humans disrupting the activities of individual butterflies rather than their habitat) on the MCBB. To our
knowledge, there are no studies, published or otherwise, addressing this aspect of MCBB ecology. Other
work completed by Boyd, including Boyd and Austin (1999) and Boyd and Murphy (2008), is recognized
earlier in the section.
USFS places much emphasis on protecting “suitable MCBB habitat”, while among those
works, Boyd pointed out that ALL of the previously existing MCBB populations, from the
ski area down canyon, had been extirpated, BY USFS’ FUEL REDUCTION PROJECTS
AND AND [sic] OTHER EXAMPLES OF POLICY AND IMPLEMENTATION FAILURES,
despite the fact that much money and effort were spent to have protective guidelines in
place for those projects. (O7-5)
Response: We recognize that past activities undertaken or authorized by the Forest Service may have
reduced MCBB habitat. Our objective at this point is to understand habitat dynamics better and facilitate
recovery of this species. Cumulative effects on the MCBB are disclosed in section 3.6.4.1 of the DEIS.
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These include discussion of past, present, and reasonably foreseeable projects with impacts that overlap in
time and space with the impacts of the proposed action. Some of these actions include fuel reduction
projects undertaken by the Forest Service.
This expansion includes mountain biking and hiking trails, a zip line, a mountain roller
coaster, and additional lifts and ski runs. Construction of these will require grading,
excavation, and clearing, some of which will occur in suitable habitat for MCBB, which
has the potential to affect the MCBB through degradation and loss of its habitat, crushing
of immature life stages, and flushing of adults. (O8-1)
In addition, by opening up the area to year-round use, the butterfly will be impacted during
all parts of the year, in all parts of its life stage, not just the overwintering period when it
may be relatively protected under seasonal snow. The new infrastructure would further
fragment existing habitat and new hiking and mountain biking trails could lead to
increased mortality through trampling of eggs and larvae on host plants. (O8-3)
Response: Potential impacts on the MCBB are discussed in sections 3.6.3.2.1 and 3.6.3.3.1 of the DEIS.
The amount of suitable MCBB habitat affected would be 6.4 acres under the proposed action and 5.4 acres
under the BCT alternative. The analysis also explains that while some suitable habitat would be adversely
affected, the intent of the proposed action as a whole is to increase suitable habitat over time, primarily by
opening up the tree canopy that has shaded out host and nectar plants and connecting known butterfly
populations. The opening of potential habitat by the removal of trees consists of 124 acres under the
proposed action and 95 acres under the BCT alternative. Beyond that, 17 mitigation measures are identified
in the analysis to minimize impacts on the MCBB. Note that the methods for delineating suitable habitat
prior to construction may change slightly as a result of ESA Section 7 consultation. Any such changes will
be reflected in the FEIS.
The DEIS notes that new runs in Chair 5 Pod and Chair 8 Pod “were laid out to maximize
potential benefits to MCBB habitat extent, quality, and connectivity.” However, the DEIS
does not go into further detail as to how these will specifically benefit MCBB habitat. (O8-
4)
Response: DEIS section 3.6.3.2.1 explains these anticipated benefits in basic terms, appropriate to NEPA
review. ESA Section 7 consultation will address them in much greater detail. This is consistent with NEPA
direction that analysis not be “encyclopedic” and with ESA concerns regarding publicizing locations of
listed species. No proposed development would be authorized by the Forest Service without FWS
concurrence.
Given the paucity and irregularity of surveys for MCBB in this area and our lack of
knowledge about preferred plant densities for this subspecies (see comments in next
section), it seems possible that historically occupied habitat or areas of lower plant density
still harbor MCBB populations or function as suitable habitat. (O8-5)
The DEIS states that surveys for the subspecies were conducted “over 12 days from June
26 through July 24, 2017,” which “yielded 17 observations in the ski area permit
boundary.”… the Mount Charleston blue butterfly could be present at a location and
remain undetected in areas with suitable habitat even with intensive surveys as exemplified
by the preceding surveys during a 5-year time period.”
Given this subspecies’ short adult activity window each year (roughly 2-4 weeks), annual
fluctuations in adult emergence and activity periods, and the fact that this subspecies can
remain dormant for multiple years and/or go undetected, 12 days of surveys over a single
season seem highly inadequate for delineating areas of occupancy. Routine annual
monitoring of MCBB populations in Lee Canyon should occur for several years before
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determining whether an area is occupied, and only then should project planning take place
to determine areas for possible development. (O8-7)
Response: We agree, and that is why the analysis documented in DEIS sections 3.6.3.2.1 and 3.6.3.3.1
focuses primarily on potential effects on suitable habitat rather than on individuals. For the purposes of the
analysis in the DEIS, all suitable habitat was assumed to be occupied. Consultation with the FWS may
provide additional information on what habitat is to be considered occupied. See the preceding two
responses.
Amendments to the existing Forest Plan would allow development within a biodiversity hot
spot and remove protections for the MCBB and its habitat, not to mention protections for
a number of other federally listed and at-risk plants and animals. The MCBB was
specifically given ESA protection due to the threat posed by loss and degradation of its
habitat. Designated critical habitat exists throughout the proposed project area, and
expansion of the Lee Canyon Ski Area does not support efforts to recover this subspecies.
(O8-6)
Response: Primarily as a result of this EIS, the MCBB at the ski area are being subjected to higher level
analysis than has been brought to bear on the species since its 2013 listing. All knowledge gained will come
to bear in the ESA Section 7 consultation that is currently underway—the consultation conducted for the
MCBB. In contrast, designation of “biodiversity hot spots” and critical habitat for the MCBB were based
on less detailed analysis. We are confident that the analysis documented in the DEIS, the BA, the biological
evaluation (BE), and consultation with FWS will result in increased opportunities to recover the MCBB
and other endemic species found within the ski area permit boundary.
Throughout the DEIS, an emphasis is placed on net positive effects of development on
MCBB populations, deflecting the short term negative impacts that are expected to the
MCBB. The DEIS claims that “improving habitat conditions for the MCBB was an
objective in designing the proposed development.”
Specifically, the DEIS states “Beneficial habitat effects [for the MCBB] are anticipated as
natural forb communities are re-established in previously forested areas.” However, more
information is needed to support this statement. While re-establishing natural forb
communities can certainly be beneficial to insects such as the MCBB in the long term,
multiple factors must be considered. (O8-8)
Response: The analyses documented in the DEIS and BA make no assumptions on if or how much habitat
will be improved in order to reach their conclusions. These analyses do in fact focus on direct and indirect
adverse effects. DEIS sections 2.2.1 and 3.6.3.2.1 do note that benefitting habitat is a project objective, and
section 3.13.4 notes that adverse effects on MCBB will hopefully be offset by future benefits. However,
these benefits are not presented in either document as anything other than speculative potential future
benefits. The Responsible Official’s decision will recognize that.
The DEIS further states “Overall, the net effect of the proposed development on pollinators
will depend on the efficacy of efforts to restore, increase and link MCBB habitat, which
includes a variety of alpine forbs that support and are supported by the area’s pollinators.
Success would offset some of the adverse effects of climate change.” However, no
information is provided on specific restoration efforts, and discussion of increasing and
linking MCBB habitat is vague. (O8-9)
Response: DEIS section 3.13.8, under the heading of Other Disclosures, discusses the current national
initiative to protect and restore pollinator habitat and the Forest Service’s role in it. That discussion notes
that pollinator populations in the SMNRA are currently doing well, that climate change may have an
adverse effect in the future, and that the net effect of this project will depend on the degree of success
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achieved in improving and increasing habitat for MCBB and other pollinator species – the issue addressed
in the preceding response. This is sufficient analysis and discussion to comply with the national initiative.
Climate change poses a serious threat to high altitude butterfly populations in Nevada and
throughout the West, and warming climatic conditions are expected to cause some species
to shift their ranges north or to higher elevations5,6. Butterflies with fragmented or isolated
distributions such as the MCBB are at a greater risk of local extinction from climate
change or large disturbance events, such as fire. Projected climate changes in the West
include increased frequency and severity of seasonal flooding and droughts, reduced
snowpack, and increased air temperatures7, all of which could impact this subspecies’
habitat unfavorably. Increased recreational use of this butterfly’s habitat is expected to
further threaten the subspecies. (O8-10)
Response: In response to concerns such as this, the Forest Service has completed in-depth studies of
projected effects of climate change on snowpack and winter recreation on the HTNF and the Intermountain
Region as a whole (Tausch 2011 and Halofsky et al 2018, respectively). These studies are cited in several
places in the DEIS discussed in most detail in 3.4.2. Section 3.6.3.2.1 notes that climate change could
adversely affect MCBB but any such effects would occur after the direct and indirect effects of this project,
whether negative or positive, had been realized. As discussed in the preceding response, the indirect effects
on MCBB habitat are anticipated to be positive, hopefully offsetting any adverse effects of climate change.
Trying to improve habitat is a more proactive approach to addressing climate change than settling for the
status quo.
I have some concerns about the saucers zooming through butterfly habitat and artificial
snow making. (Where is the water coming from? How is the melt controlled? Are there
chemicals or additives that will seep into our aquifers or runoff? How much energy is used
in the process? (I50-1, see also Soils, Water, and Watershed)
Response: As explained in DEIS section 1.7.2.1, the proposed action does not include increased water use
for snowmaking, and energy use is correlated with water use – i.e., via the pumping process. Lee Canyon
does not use chemical snowmaking additives. It is not clear what the commenter is referring to in regard to
saucers.
Your attempt to unlawfully disregard the legally required protection of the blue butterfly
is a disgraceful attempt to circumvent the environmental protection of Lee Canyon. (I66-
4)
The Mt. Charleston blue butterfly is one of the most vulnerable species in the country, with
its habitat restricted to just a few small patches in the Spring Mountains, one of which
largely burned in 2013. As a result of that loss, the Lee Canyon ski area is this butterfly's
most important remaining refuge.
That's why I'm opposed to the Forest Service turning the butterfly's habitat into a year-
round extreme-sports amusement park. Carving up its critical habitat with miles and miles
of braided downhill mountain-bike trails will limit the butterfly's connectivity and ability
to move across the landscape over time. Introducing thousands of new recreational users
to the mountain will also inevitably cause new harms to those areas which are currently
largely undisturbed in the summer. That's the most critical time in the butterfly's life, when
almost all of its life functions play out over a few short weeks. (I73-1; 178-1)
It appears most if not all the proposed development is directly within or immediately
adjacent to critical habitat for the Mt Charleston Blue Butterfly, a critically endangered
species which is almost 100% dependant [sic] on host and nest plants in the expansion
area. I can't understand how the the [sic] USFS could even consider allowing this proposal
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to go forward, since their [sic] would be immediate and permanent adverse impacts to an
endangered species. (I86-1)
Response: The DEIS and the BA thoroughly address potential impacts on the MCBB, and the analysis
includes the issues raised in these comments (i.e., habitat connectivity, butterfly phenology, and impacts on
critical habitat). It also points out that forest encroachment onto suitable habitat is the primary threat to the
species. Forest encroachment is occurring primarily as a result of fire control. As discussed in DEIS sections
2.2.1 and 3.6.3.2.1, an objective of project design was to remove or thin forest cover on areas of potentially
suitable habitat to improve habitat and increase habitat connectivity – a proactive approach to recovery of
the species, though the benefits to be achieved remain somewhat speculative at this point. Accordingly, the
DEIS and BA focus on direct and indirect adverse effects, and none of the proposed development would
occur without FWS concurrence, through the ESA Section 7 consultation process, that such development
was consistent with efforts to recover the species.
Cultural Resources
…the SHPO notes that compliance with the public consultation requirements of 36 CFR
800 can be accomplished with the NEPA scoping document by including of information
about Section 106 of the National Historic Preservation Act of 1966, as amended and
requesting public comment on the effects of the undertaking on historic properties and
unevaluated cultural resources. When does the U.S. Forest Service plan to consult the
public on the effect of the undertaking? (A8-1)
Response: The scoping period began on March 23, 2017, when a notice of intent (NOI) to prepare an
environmental impact statement was published in the Federal Register (Vol. 82, No. 55, p. 14865). The
scoping period closed 45 days later on May 8, 2017. Only the Colorado River Indian Tribes provided
comments regarding cultural resources during this period. However, potential effects on historic properties,
the historic integrity of the ski area, and other cultural concerns under Section 106 of the National Historic
Preservation Act were included in the scope of the DEIS (Section 3.7).
Notice and comment on the DEIS began with the Notice of Availability of the DEIS published in the Federal
Register on August 17, 2018, initiating a 45-day comment period, as stipulated in the agency’s notice and
appeal regulations (36 CFR 215). A Legal Notice of Proposed Action was published in the Las Vegas
Review-Journal on September 19, 2018. The only cultural resources comments received were those noted
above.
Beyond that, in August 2018, the Forest Service initiated government-to-government consultation with area
Tribes via the Nuwuvi Working Group. A site visit and meeting was conducted October 26-28, and
responsive comments from the Tribes have been prepared. They will be considered in preparation of the
FEIS.
Scenery Resources
…ensure that all temporary and permanent lighting conforms to Dark Sky lighting
standards as described at www.darksky.org (A6-1)
Response: The project area is not within a designated dark sky reserve, park, or community and not subject
to these dark sky standards. However, reducing light pollution is consistent with SMNRA management
direction. The only lighting proposed is that associated with new structures. They would be subject to any
lighting ordinances that Clark County opted to enforce through their building permit process. Note that ski
area facilities are closed soon after dark, and most lighting extinguished.
Is this [mountain coaster] something that residents of Camp Lady of the Snows would hear
or see? We have a good view of the runs as they exist today, and I believe we would see it
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as proposed in the BCT Alternative but are not sure of the sound. (I3-2, see also Recreation,
Noise)
Response: The mountain coaster would not be seen from the Camp Lady of the Snows development under
the proposed action, but segments of the upper portion of the mountain coaster may be visible under the
BCT alternative.
Recreation
General
The Bristlecone Trail is one of the most used in the Spring Mountain National Recreation
Area year round. The proposed additional ski run as well as the introduction of conflicts
with snowcats and downhill skiers/snowboarders will greatly impact the casual snow
shoeing user of the trail. In addition, the mountain coaster as well as the mountain bike
routes that will traverse the trail will provide an unsafe environment and eventually
discourage the traditional use of the trail. (A2-3)
This proposal will likely create an increase of mountain bike users to the general area;
education outreach regarding wilderness and prohibition of mountain bikes in the Mt.
Charleston Wilderness area should be conducted to mitigate wilderness incursions. This
is important as it is easily foreseen that bikers using the Ski Lee routes may eventually ride
on the Bristlecone Trail which intersects with the Bonanza Trail and leads into the
wilderness area. (O3-2)
Response: Potential impacts on BCT users was the driving force for the preferred alternative, the BCT
alternative, which entails moving proposed infrastructure (e.g., pod 8 ski runs, the mountain coaster, and
the zip line) away from the trail. Potential impacts on BCT users are discussed in the DEIS under the
proposed action and BCT alternative in sections 3.9.3.2.1 and 3.9.3.3.1, respectively. Impacts on trail users
would occur under both alternatives, but the BCT alternative would reduce adverse effects substantially. In
terms of mountain-bike use of BCT or the wilderness, DEIS section 3.9.3.2.1 states “mountain bikers are
unlikely to either take their bikes on the BCT (after having paid for lift-accessed, purpose-built mountain
bike trails) or to hike the BCT.” It also states that “it is assumed that no mountain bike trail visitors would
use the BCT.” Lift-served mountain biking of the type proposed is a specialized sport. Based on logic and
experience at other ski areas, visitors engaged in it do not leave the designated trail system.
It is not difficult to envision how a ski resort base area replete with a roller coaster could
be considered an amusement park that is out of harmony with the environment of the
surrounding landscape. While zip lines are explicitly allowed by PL 112-465, roller
coasters are not. (O2-4)
Summer recreation opportunities can be enhanced without unnecessary infrastructure.
Anyone who thinks a mountain coaster is an "enhanced" recreation experience should not
be developing in Lee Canyon. How about not disturbing more land, except for trail access
and help the wildlife rather than destroying more of their habitat. (I32-2)
Response: As stated in section 2.2.3.1 of the DEIS, mountain coasters are a relatively new type of recreation
at mountain resorts, where they are proving popular. Prior to accepting Lee Canyon’s proposal and initiating
NEPA review, we determined that the proposed mountain coaster was consistent with SAROEA’s
guidelines for summer recreation. The public exhibits a wide range of preferences for enjoying the National
Forest System.
There is nothing about maintaining the ecological integrity of the upper Lee Canyon area
and the document is rather dismissive of the impacts of climate change on the long term
viability of snow sports in the Spring Mountains. (O5-1)
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Response: Ecological integrity is a very broad issue, so a more specific comment would be helpful. The
range of physical and biological resource effects discussed in the DEIS collectively address pertinent
aspects of ecological integrity. The effect of climate change on ski area viability was the second issue
addressed under Recreation in the DEIS. See sections 3.9.2.2, 3.9.2.1.2, 3.9.3.2.2, and 3.9.3.3.2.
Noise
Is this [mountain coaster] something that residents of Camp Lady of the Snows would hear
or see? We have a good view of the runs as they exist today, and I believe we would see it
as proposed in the BCT Alternative but are not sure of the sound. (I3-2, see also Scenery)
Response: The distance between the proposed mountain coaster under the BCT alternative and the Camp
Lady of the Snows development is about 1.3 miles. The noise analysis completed to support the DEIS
concluded that at any distance beyond 0.75 mile, the noise of the mountain coaster would be less than
ambient noise levels in the canyon. As a result, it would not be audible from Camp Lady of the Snows.
The new rides should not raise the noise level in the canyon. (I83-2)
Both attractions [coaster and zip line] will create noise in the quiet Forest. We don’t want
shrieks and screams overtaking the serene nature experiences, spoiling it for those seeking
solitude and the sound of the forest and the animals that live there. (I87-2, I88-2)
Response: As indicated in the preceding response, the noise analysis completed to support the DEIS
concluded that at any distance beyond 0.75 mile, the noise of the mountain coaster would be less than
ambient noise levels in the canyon. The zip line would generate less noise, and noise levels are not additive.
Accordingly, few canyon users outside the ski area would be affected by noise.
Potential noise impacts on BCT users, the Forest users most susceptible to ski area noise, are addressed in
sections 3.9.3.2.1 and 3.9.3.3.1 of the EIS. Under the proposed action, sounds from the mountain coaster
would reach noticeable levels on large segments of the BCT due to its proposed location. Under the BCT
alternative, noise levels from the mountain coaster would be substantially reduced and likely not noticeable
on the majority of the trail. Similar effects under both alternatives would occur with the zip line. A
discussion for the zip line will be added to the FEIS. Increased noise levels in some areas of the ski area
would be a recognized unavoidable adverse effect (DEIS section 3.13.4.6).
Safety
General
Safety needs to be a priority. With the increased number of people the crowds have become
overwhelming and more terrain needs to be opened for skiing and snowboarding.
Currently there are skier/snowboarder collisions and other crowd related issues.
Expanded terrain would help eliminate the problem. (I20-2)
Response: This is consistent with the stated purpose and need for action (DEIS section 1.4). The proposed
action includes additional ski terrain.
My largest concern is sprouted from that of safety…. I have taken part of snow sports at a
multitude of resorts all around Nevada and California and I have never experienced the
types of crowding issues as I have at Lee Canyon… My biggest concern is that if the resort
cannot safely accommodate the runs, chairs and crowds that they receive now, how on
earth are they going to be able to accommodate more chairs, runs and ultimately more
people if the base of the mountain is remaining the same size. (I32-1)
Response: This is also consistent with the stated purpose and need for action (DEIS section 1.4). The base
area infrastructure would not remain the same size. As described in DEIS section 1.3, the proposed action
includes expanded parking, skier services, administrative, and ski patrol/first aid facilities.
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Collisions on BCT
Chair #8 will drop to runs that cross the bristlecone trail in the winter and the proposal
for mountain bike trails, mountain coaster, and zip lines crossing the trail in the summer
will create a collision hazard. (A2-4)
Although the BCT Alternative does avoid most user conflicts, it is important to address
user conflicts from downhill mountain bike users and downhill skiers/snowboarders where
use on the Bristlecone Trail overlaps with hikers and snowshoers using the trail.
Specifically, users using the Ski Lee routes should be made aware that a section of their
route (Bristlecone Trail) will intersect with a wide variety of users not going in their
direction (downhill), at various speeds. (O3-1)
Response: This was the first issue addressed under the heading of Safety in the DEIS (section 3.10).
Collision hazard under the proposed action is addressed in DEIS section 3.10.3.1.1 and under the BCT
alternative in 3.10.3.3.1. The BCT alternative was developed to reduce impacts, including safety impacts,
on BCT users, and the analysis indicates it would be effective in that regard. Section 3.13.4.7 states that the
BCT would retain the minor adverse safety effects for summer BCT users, associated with a mountain bike
trail crossing, but would eliminate any adverse safety impact on winter users. Section 3.10.5 contains
mitigation measures to minimize risk of collision among users.
Emergency Services
MCFPD is concerned that the planned update and expansion of the existing facility, as
well as the addition of new summer activities, will exponentially increase the number of
emergency calls and negatively impact public safety for both the residents and visitors.
(A3-1)
The current volume of calls and responses to the ski resort is already a burden on the
limited resources of the Mt. Charleston Fire Protection District. Rescue units spend several
hours a day responding, assuming patient care and transporting patients to next level of
care via ground or air on any given weekend. (A3-3)
Issue 2 the quote “may affect provision of emergency services” The current visitor volume
already affects emergency service levels and responses within the Fire District. (A3-8)
The EIS indicates an anticipated 25% increase in call volume with the expansion. MCFPD
requests the opportunity to review the basis for this estimate and the anticipated
distribution by month (or season). MCFPD has one rescue unit which can be [sic] and it
can be unavailable for several hours. (A3-15)
The MCFPD does not have the staffing or equipment to be able to dedicate an ambulance
or ambulance service full time to the ski resort to facilitate patient transportation from
facility to hospital. (A3-2)
The MCFPD does not provide a dedicated ambulance service to the ski resort. Depending
upon private ambulance company availability and staffing levels, one unit may be staged
on the mountain during heavy holiday, snow and visitor days. This ambulance is dispatched
for all MCFPD emergencies, not solely for the Ski Resort. Historically the ambulance has
been provided at no cost to the District and subject to availability. There are no guarantees
that it will be provided in the future at no cost. MCFPD services are already taxed with
responses to the ski resort. (A3-7)
An ambulance company unit is staged at the Ski Resort for Fire District responses. Due to
heavy traffic delays or road closures, response times can be greater than 45 minutes or
more. This unit is coordinated by MCFPD thru the ambulance company and not staffed or
staged all the time. (A3-10)
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Almost every time I am at my home in Kyle Canyon, rescue helicopters and emergency
vehicles are active there. The same is true in Lee. People get hurt by accident or doing
really stupid things. We need to have larger, permanent, medical facilities on the mountain
– maybe at the Kyle Visitors’ Center and near the snow resort? (I50-2)
Relying on MCFPD for primary emergency response is ALREADY taxing its minimal
resources, as currently provided by Mt Charleston residents and Clark County tax payers.
While USFS and PowdrCorp are working together to draw greater volumes of visitor
traffic to this facility, this DEIS is not clearly proposing to take responsibility and alleviate
this burden. …We have suggested for years that the MDP include an ambulance housing
facility, whether for a contract service or owned outright by PowdrCorp, as part of the new
building infrastructure, to provide permanent, year-round emergency capability for Lee
Canyon. (O7-3)
The department is concerned that congestion will prevent a timely emergency response.
The Emergency Services section 3. 10.3.2.2 outlines a current average wait time of 45
minutes for an ambulance during peak traffic hours. Doubling the number of trips to the
canyon will only increase this delay. Mitigation plans for congestion on SR 156 should –
be suggested for the safety of the recreating public. (A4-1)
Response: The effect on emergency services is the second issue addressed under Safety in the DEIS.
Potential impacts of the proposed action on emergency services are addressed in section 3.10.3.2.2 of the
DEIS. To summarize, based on past ambulance call data provided by the MCFPD and skier-growth
projections provided by the ski area, either alternative could increase ambulance calls from 40.8 per season
to 102.6, or roughly 150 percent. Most calls would occur during high-use periods, when there is typically
an ambulance stationed at the ski area, avoiding the trip from Kyle Canyon to the ski area. The bike park
could add another 10 to 25 ambulance calls per year, but these would occur during summer when traffic
congestion is not an issue.
The analysis concludes by stating: “Additional medical staff at the ski area, or arrangements with private
ambulance companies may be needed to ensure adequate patient care. Nevada Department of
Transportation efforts to improve traffic flow on SMNRA highways under their management could also
alleviate this issue.” Call volumes and needs for emergency services would be increased under either
alternative, which is identified as an unavoidable adverse effect in DEIS section 3.13.4.7. We would be
happy to discuss the calculations used in the analysis with the MCFPD.
Beyond that, the proposed action includes the addition of a first aid/ski patrol building to assist with
emergency situations and provide more efficient ambulance transfers. Additional medical facilities outside
the ski area special use permit boundary are beyond the scope of this analysis.
We should also note that provision of emergency services in Lee Canyon is the responsibility of the
MCFPD, which is a Clark County agency. The sales tax revenues generated at the ski area are paid to the
county to support such services, as are federal payments in lieu of taxes. Accordingly, more ski area visitors
should result in more funding to provide emergency services. Similarly, as discussed below in response to
traffic comments, maintaining an adequate level of service on state highways within the SMNRA is the
responsibility of the Nevada Department of Transportation (NDOT) and Nevada Highway Patrol (NHP).
We have cooperated with these agencies in the past and will continue to do so within the limits of our
authority.
Finally, MCFPD operates Fire Station 856, located only 1.5 miles from the ski resort. A new facility at the
ski area or elsewhere in Lee Canyon seems unnecessary.
We need more public service personnel – police, fire department, forest service,
paramedics, traffic control. (I50-3)
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It is well known that the influx of visitors during the winter months causes an enormous
strain on the emergency services required to manage the volume of people visiting the area.
Both canyons are impacted to such a degree, that the roads must be shut down to control
access. Many times during a snowy winter, the roads are completely jammed and traffic is
stopped in both directions due to many visitors attempting to find appropriate parking (and
there are very few parking areas). The personnel from NHP, LVMPD, NDOT, and our Fire
Department personnel are completely overwhelmed. The costs for providing emergency
services (medical emergencies, traffic accidents, lawlessness, and parking violations) for
these additional visitors are not addressed in this plan. The geography isolates the
deployment of emergency services to one canyon or the other, leaving many residents and
visitors without any resources at all. (I107-1)
Emergency response to the Resort contributed to an accident a few seasons ago involving
a fire truck that was totaled and the community was without this resource for many months.
Most single medical events occurring at the Resort should be the entire responsibility of
the Resort, and should involve no support from services dedicated to the community and
visitors. (I107-3)
Response: See preceding response and responses under Traffic below. Beyond that, a number of these
concerns are regional issues unrelated to the proposed action and outside the scope of this analysis.
Lee Canyon Ski Resort staff does not have Southern Nevada Health District License to
provide services at the EMT level as required by the State of Nevada and Clark County.
MCFPD Fire Station 853 is located 14.6 mile to ski resort not 26 miles as stated. Fire
Station 856 is located 1.5 miles from the ski resort station and units available as staffing
allows. (A3-9)
Response: The ski area employs certified EMTs and other trained emergency personnel who are not part of
the county’s emergency response team and not subject to the licensure requirements of the Office of
Emergency Medical Services & Trauma System. They are certified under the National Ski Patrol’s Outdoor
Emergency Care (OEC) program, considered the standard of training for emergency care in the outdoor
environment and recognized by resorts and recreational facilities in all 50 states. As noted in DEIS section
3.10.2.2, ski area emergency personnel “…provide appropriate on-site treatment. In addition to medical
qualifications, these personnel have avalanche rescue, lift evacuation, and vehicle accident training and
experience. However, they do not have the capability to transport accident victims to hospitals.” Their
training and certification are appropriate to these functions.
FEIS section 3.10.2.2 will be corrected to note that the fire station is 14.6 miles from the ski area.
The summer activities included in this plan will require specialized training for personnel,
personal protective equipment, and other support equipment. These resources are not
available to Mt. Charleston Fire Protection District to perform patient rescue and
extrication. MCFPD requests to be included on all specialized training related to activities
at ski resort. (A3-12)
Response: Evacuation from the mountain coaster or zip line would be similar to ski lift evacuation, and
falls on biking trails would be similar to ski incidents – all covered by NPS/OEC procedures, including bike
patrol activities. All in all, we do not anticipate substantial new skills or equipment being necessary. Beyond
that, we would welcome MCFPD participation in any specialized emergency training.
MCFPD request that USFS and developer comply with all local, state and federal building
codes related to fire code and provide for adequate water resources for any type of fire
suppression. Provide for all facilities the following fire protection systems, alarms, fire
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hydrants, fire lanes, Knox Box type control keys. Include also a designated helicopter
landing zone for urgent medical emergencies. (A3-13)
Response: We anticipate that Clark County will, at their discretion, issue building permits, perform
construction inspections, and provide final inspection and occupancy certification for any new buildings
following NEPA review and authorization. This should ensure compliance with applicable fire codes and
water storage requirements for fire suppression purposes. There is a designated helicopter landing zone at
the upper BCT trailhead.
Pg. #16 Discussion and Mitigation
Fire "The ski area maintains a fire truck and trained fire control personnel”. The Mt.
Charleston was not made aware of this unit to include capabilities, equipment, and trained
fire control personnel for structure and wildland fire emergencies. (A3-14)
Response: The truck maintained by the ski area is simply to suppress fires quickly or, if unsuccessful, to
buy time until the MCFPD arrives. The cited text from the scoping report does not indicate capabilities
beyond that.
The plan to increase parking and facilities will only increase visitor and traffic volume.
Any evacuations of the ski resort, recreational and residential areas in Lee Canyon in the
event of a natural disaster could be a major hazard to visitors, residents and first
responders. With Lee Canyon being a box canyon that is only served by a single, 2 lane
roads, and the additional volume of visitors will increase the potential for traffic issues
during this type of emergency. (A3-6)
Response: See responses below under Traffic, particularly that the potential adverse traffic impact would
be infrequent (limited to snowy winter weekends and holidays) and incremental (prolonged periods of
congestion and low LOS at existing choke points like Lee Meadows). Potential positive effects include
reduced illegal parking and congestion at Lee Meadows due to new parking at the ski area (DEIS section
3.11.3.2).
Currently, Air Operations are not reliable during the winter season and severely limited
during the other seasons due to altitude, air temperature, patients and crew weight
concerns. The USFS EIS anticipates no impact on traffic flow on SR 156 with the increased
number of customers at the ski resort. To believe that increased traffic volume won’t
adversely affect traffic flow is illogical. Additional visitors to the Ski Resort will
undoubtedly result in increased traffic and congestion which will adversely affect the speed
of ground transport from the ski area to landing zones in lower Lee Canyon. (A3-4)
Response: See preceding responses and responses below under Traffic.
Avalanche Control
In 2004 I came to your office and explained my concern relating to the avalanche control.
Someone in your office notified the Manager at the time and he 86’d me. The next year
2005, I just skied and was not employed by the Resort. On January 10, 2005, my husband
and I were in the gift shop at the resort, when over his radio, I heard there was a confirmed
buried skier. We responded and where the first responders other than just skiers at the
incident. It was a long night and after searching from about 2 pm until 8 pm, I will always
regret not being able to make the new management and forest service listen. I am today a
registered nurse and from a public safety preventive, believe the federal government and I
mean military air force should help control the avalanche area in Lee Canyon. (I62-2)
Response: As a condition of their special use permit and associated annual operating plans, Lee Canyon is
required to complete avalanche control activities as necessary to provide for the reasonable safety of their
guests. They employ current, industry standard forecasting and control procedures developed by the Forest
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Service, the Avalanche Artillery Users of America (AAUNAC), and the U.S. Army. Avalanche control
activities are under the supervision of the Forest Service permit administrator. Our monitoring indicates
that the ski area is in compliance with this requirement.
Traffic and Parking

Traffic
Traffic Congestion is an on-going problem on SR 156 due to the ever increasing number
of visitors to the area and has been exacerbated in recent years by road closures,
construction projects, road congestion, slow traffic and delays. (A3-5)
We also don’t need more traffic in this sensitive area causing pollution, congestion,
accidents…(I79-2)
Response: As discussed in DEIS section 3.11.2, the main impediment to smooth traffic flow on SR 156 in
Lee Canyon is not traffic volume per se, but illegal parking concentrated around Lee Meadows, a popular
snow-play destination that attracts many visitors from the Las Vegas area on snowy winter weekends and
holidays. The combination of a large number of vehicles in the canyon and a substantial amount of illegal,
unsafe parking causes serious congestion around popular recreation areas such as Lee Meadows. The level
of service (LOS) on SR 156 around the meadows falls to a rating of F (severe traffic congestion and roadway
failure) during busy periods. These conditions occur on an estimated 20 days per year.
Potential impacts on traffic and the LOS on SR 156 due to implementation of the proposed action are
discussed in section 3.11.3.2 of the DEIS. To summarize, the vehicles associated with additional skiers and
visitors coming to the ski area on peak days would increase traffic on SR 156 by 388 vehicles, a 12 percent
increase over the 2005 peak-day count. However, the majority of skier vehicles would be on the road during
1.5-hour periods around the ski lift start time of 9 a.m. and the closing time of 4 p.m., before and after peak
traffic associated with snow play activities in the upper canyon. The net effect would be to potentially
prolong periods of congestion and low LOS at existing choke points like Lee Meadows on about 20 days
per year.
Positive effects are also identified in the analysis. The additional parking proposed at the ski area may
reduce the number of illegally parked cars in the canyon by providing non-skiing visitors with more legal
options. A shift from snow play to ski area recreation could occur resulting in fewer illegally parked cars
and better flow.
The increased use of the ski area will negatively impact the traffic flow on Lee Canyon
Road as well as Deer Creek and Kyle Canyon Roads. A comprehensive Traffic Impact
Analysis would be required through the land use entitlement process with the County. (A2-
5)
A technical traffic study is required to adequately analyze the impacts of doubling the
number of visitors to the winter ski area. If at current levels, the LOS on SR 156 is F for a
portion of the winter season, doubling the trips will exacerbate the current congestion.
(A4-2)
The project notes the illegal parking problem alongside Lee Meadows but suggests no
permanent solution. As Lee Meadows is within the SMNRA, the recreation area as a whole
should be analyzed for traffic impacts. (A4-4)
The increased visitor volume will contribute to higher traffic congestion on SR 156. The
MCFPD also encourages the developer or USFS to fund a traffic/visitor impact study. This
study should cover periods of maximum usage including winter break for the Clark County
School District, and holiday weekends. (A3-11)
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Response: We recognize that periodic traffic congestion, particularly during winter holidays and weekends
when visitors flock to the area for snow play, is a long-standing issue within the SMNRA. We work closely
with the Mount Charleston Winter Alliance (MCWA) and other entities to address this issue (see response
below regarding traffic mitigation). That said, the function of this DEIS is to analyze and disclose the effects
of the current proposed action, which we believe it does (see preceding response). A broader, more
comprehensive analysis of SMNRA-wide traffic issues is beyond the scope of this analysis. If such a study
were necessary, it should be initiated by the NDOT, the agency responsible for maintaining an adequate
level of service on the state’s highway system. See response above under Process/Other Permits and
Approvals that explains why we do not believe that Clark County’s land use entitlement process applies.
This proposal must also consider and mitigate for the increase in visitor traffic, especially
during the summer months. Currently, most users are dispersed amongst the various picnic
areas and campgrounds. The only two trailheads in Lee Canyon are the Upper and Lower
Bristlecone Trailheads. This proposal will increase overall use and concentrate users to
the top of Lee Canyon. (O3-3)
Response: As discussed in DEIS section 3.11.2, summer traffic congestion is not an issue on SR 156 in Lee
Canyon, but it can be on SR 157 in Kyle Canyon. We anticipate that new recreational opportunities in Lee
Canyon would result in more dispersed summer use, helping to alleviate congestion in Kyle Canyon.
…what steps will be taken to remedy the already poor traffic and crowding situation in
order to encourage even more people to visit? (I32-3)
I believe that for winter weekends and holidays, there may eventually be a need to restrict
traffic into Lee Canyon and utilize a shuttle system from the Sawmill Trailhead parking lot
which would serve both Lee Meadows snow play area and Lee Canyon ski resort. (I35-5)
The vehicular traffic is a huge problem. We could use a solar / natural gas transit system
running through the mountain, like they have in many ski resort communities. (I50-4)
Parking and traffic remain a difficult problem. Perhaps a tram system similar to the one
operating at Zion Park may relieve part of that problem. (I53-3)
Response: As discussed in preceding responses, the DEIS addresses the traffic situation in detail, identified
illegal parking at popular snow-play areas like Lee Meadows on winter holidays as the primary impediment
to traffic flow, and described the adverse impact of the proposed action as a potential prolonging of periods
of congestion on the estimated 20 days per year when low LOS occurs on SR 156. The DEIS also identifies
potential positive effects on traffic associated with the new, legal parking options the proposed action would
provide in the upper canyon, and the potential for recreationists to be drawn to the ski area rather than snow-
play areas because of the improved recreation opportunities and visitor services that would be available
there.
In terms of mitigating potential adverse effects on traffic, providing for adequate LOS and safety on state
highways in the SMNRA is primarily the responsibility of the NDOT and NHP. The Forest Service works
with these agencies and others (i.e., Clark County, the MCFPD, Las Vegas Metropolitan Police Department,
the National Weather Service, the ski area, and the Southern Nevada Conservancy) in the Mt. Charleston
Winter Alliance (MCWA). The MCWA was organized to promote public safety, including timely
emergency response, during winter months when sharp peaks in Kyle and Lee canyon visitation occur. A
recent press release from the MCWA advised winter visitors that “To ensure timely emergency response
and public safety, [NHP] and Las Vegas Metropolitan Police Department (Metro) monitor traffic
congestion and road conditions in both Lee and Kyle canyons and regulate access. Depending on traffic
volume and available parking, periodic road closures may occur on Nevada State Routes 156 (Lee Canyon
Road), 157 (Kyle Canyon Road) and 158 (Deer Creek Rd.).” The press release went on to advise ski-area
visitors to have their passes available to show law enforcement personnel monitoring traffic in order to
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bypass road closures. This indicates the MCWA’s recognition that traffic issues on SR 156 are not caused
by the ski area.
In summary, the DEIS fulfills its appropriate role in identifying the potential adverse effect of the proposed
action on SR 156’s LOS, but the ski area—and thus this proposed action—are not the driving force in this
larger issue. Accordingly, we are working collectively with all pertinent agencies and organizations in the
MCWA to mitigate traffic congestion within the SMNRA.
An Encroachment Permit from NDOT will be required for any work performed within State
right-of-way. (A4-5)
Response: The ski area will conform to pertinent NDOT requirements while working in the state right-of-
way, as indicated in Table 1-1 of the DEIS.
Parking
My concern is PARKING…. Please make sure they SIGNIFICANTLY EXPAND the
PARKING AREA!!! (I25-2)
…what measures would be taken to accommodate parking for the increase in customers?
(I32-2)
The parking area be expanded, including additional handicap parking. (I64-2)
Any expansion of the ski resort will adversely impact an already overcrowded area. A
change to all year operations will adversely impact an already overcrowded parking lot.
It will drive away current hikers by implementing Parking fees year round. (I75-1)
Response: The proposed action includes a new 500-car parking lot (DEIS section 2.2.4.4) that
would more than offset the projected increase in winter ski area visitors (section 3.11.3.2). The new
parking lot as well as existing lots would have to comply with Forest Service access standards,
assessed during our engineering review.
In regard to summer parking, the new lot would not be used for parking in order to keep it available
as a detention basin during high-intensity rain storms. However, the remaining parking would be
adequate to meet summer needs, as projected summer visitation is less than winter.
As noted in DEIS section 1.7.2.4, the ski area is authorized to charge parking fees to offset their
expenses for snow removal.
The project proposes to leave up to 2,409 vehicles without legal parking. Section 3.11
Traffic does not provide sufficient data to justify this course. Further study is needed. (A4-
3)
Lee Canyon agrees that there is currently a congestion problem on highway 156 on peak
days, primarily in the Lee meadows area. Lee Canyon has worked with the Mt Charleston
Winter Alliance over the last few years to look for ways to reduce the issue. Visitors to the
ski area in general are looking to get to and from the ski area rather than finding a parking
space somewhere on highway 156 and in our opinion are not a large factor in the
congestion. We also believe expanding parking at the ski area by 500 spaces whilst only
increasing the number of cars for ski visits by 388 will provide the opportunity for other
visitors to Lee Canyon to park in a designated parking space and also utilize facilities such
as restrooms. (O4-6)
Before encouraging more people to flock to the mountain, particularly when they will have
to drive along slick stretches of highway already choked with a bad mix of pedestrians and
traffic, the plan should be amended to include adequate parking for those who stop in route
to the ski area. (I52-4)
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Response: The cited figure comes from DEIS section 3.11.2, which describes the affected
environment, or current conditions. The 2,409-vehicle parking deficit is for Lee Canyon as a whole,
not the ski area. As discussed in DEIS section 3.11.3.2, the proposed action would add 500 parking
spaces to the ski area while adding a projected 388 vehicles to canyon traffic. Beyond that, the
additional parking may encourage some canyon visitors to park legally at the ski area rather than
illegally at Lee Meadows. In short, the proposed action would more than offset its impact on
parking. As discussed in the response above under Traffic that deals with mitigation, the larger
SMNRA-wide issues of traffic and parking are being addressed by the appropriate agencies and
organizations, including the Forest Service and the ski area, in the context of the MCWA, as is
appropriate.
5. The new parking lots use as water retention facility seems to be hazardous for summer
automobile parking and for retention of parking lot surface. See video under #2 above.
[https://www.youtube.com/watch?\=79SICzOAOM4 “Lee Canyon flood August 16,
2018”] (I49-6)
Response: As discussed in DEIS section 2.2.4.4, the proposed parking lot would not be used for summer
parking and would be designed to withstand its intended summer use as a detention basin.
...although an additional 500 parking spaces are proposed for the ski area, the Foxtail play
area is in equally urgent need of parking. (I52-2)
Response: The Foxtail Group Picnic Area is 1.5 miles down canyon from the ski area, and the proposed
action would have no effect on parking supply or demand there. As a result, providing parking at Foxtail is
beyond the scope of this analysis.
…we suggest that the Final EIS evaluate the need for additional parking year-round before
selecting an option that precludes summer vehicle use. (A9-2)
Response: The DEIS does not address an alternative that precludes summer vehicle use. Depending
on the design of the new parking lot, some portions may be able to be used during the summer
while still serving its detention basin function. However, summer parking at the ski area is not
expected to be limiting and such use should not be necessary.
I don't want lots of trees cut down to make way for parking or roads. The design would
have to include parking without cutting trees. (I83-1)
Response: The proposed new parking lot would require some tree removal. As discussed in DEIS section
1.7.2.2, tree removal is not an issued carried into in-depth analysis in the DEIS.
Air Quality
DAQ determines that this action should have no significant impact to ambient air quality.
(A1-1)
Response: We appreciate your review.
a. Air pollution and its effects on Flora and Fauna is a concern that did not appear to have
published results in this EIS. (I49-2)
Response: Air quality was not identified during scoping or internal, interdisciplinary review as an issue
requiring analysis in this EIS (DEIS section 1.7). The ski area will acquire all necessary permits and
approvals to implement any projects authorized on the basis of this analysis. The list of permits that may
be required include those identified in Table 1-1 of the DEIS. The Clark County Department of Air Quality
will be consulted prior to construction to ensure that all regulations and requirements are followed. As
indicated by the preceding comment, the Department of Air Quality has determined that the proposed
actions should have no significant impact to ambient air quality.
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Opinion
This section includes general statements, statements in favor, or statements opposed to the proposed
improvements. Where appropriate, statements are combined within similar categories. Responses are not
required or provided.
General
….we have rated the preferred alternative as Lack of Objections (LO) (A9-1)
Cafeteria food is extremely expensive, many skiers or their families or visiting tourists,
which there are a number of, find it prohibitive. (I64-5)
In Favor
…we support the proposal for the development at Lee Canyon. We believe the year-round
attraction would provide expanded opportunities for tourists and locals alike to enjoy the
natural beauty of the area. (O1-1)
We request your agency to approve the expansion of Lee canyon resort. (I1-1)
I urge you to move forward with the development of the Lee Canyon Ski resort. (I2-1)
We have been eagerly waiting for the expansion. Bring it on! (I4-1)
I support the expansion of Lee Canyon Ski Resort. (I5-1)
This project is an excellent and needs to move forward. All of the facility upgrades are
needed and will only help to improve the overall safety and community of skiers that attend
this location on an annual basis. (I6-1)
I am in full support of the proposed upgrades and changes. (I7-1)
Love the idea for that area. (I9-1)
Love the idea and especially the new parking and summer activities!(I10-1)
I feel the expansion of Lee Canyon should definitely be allowed to move forward. (I12-1)
I agree with proposed expansion I think that you should approve it. (I13-1)
This is the best idea to expand. (I14-1)
I am in full support of Lee Canyon's expansion proposal to include mountain bike trails.
(I15-1)
Please approve the proposed development of the ski area for both winter and summer
activities. (I17-1)
My family and myself are fully in favor of the development of the Lee Canyon Ski Area.
(I20-1)
I support the proposed action to responsibly increase recreational opportunities in Lee
Canyon. (I22-1)
Lee Canyon is way past the need for expansion. (I23-1)
I have no problem with expanding the ski area. (I25-1)
I support the proposed improvements to Lee Canyon, and the Mountain Bike Trails. This
would be a great addition to the area and something that is lacking in Southern Nevada.
(I26-1)
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I totally approve the expansions that lee canyon is asking to do. (I27-1)
I agree with the proposed action. (I29-1)
I would love to see this project go through to see the ski resort benefit from this cause it is
getting a lot more popular now & sometimes they can't ceal with the large crowds or
sometimes the slopes are packed. (I30-1)
I support the expansion plans wholeheartedly, particularly the improvements on facilities
and mountain biking trails. (I31-1)
I would love for it to be allowed to expand. I also mountain bike and would really love an
mtb park. (I33-1)
I am in favor of the proposed action generally. (I28-1)
I am writing to express my strong support for an expansion of the Lee Canyon ski area.
(I36-1)
This would be a great addition to the ski resort. (I37-1)
I support the changes for the resort (I39-1)
This expansion is much needed. (I40-1)
Yes! All for this expansion of Lee canyon. (I41-1)
I support the Lee Canyon expansion. (I43-1)
…we especially support Lee Canyon management’s commitment to the concept of,
“channeling visitor traffic into controlled, limited activities that provide satisfying
recreational opportunities, while minimizing the negative environmental impacts of
uncontrolled, random use.” (I50-5)
I wholeheartedly support this exciting proposed expansion at Lee Canyon. (I51-1)
I think the expansion of the ski area is great and long overdue. (I52-1)
I support the year round plan. (I54-1)
The summertime venues are an excellent idea for the resort and our city. Love the mountain
bike plans and the coaster and zip lines are great ideas. Expanding the ski resort for winter
and summer activities makes total sense. (I55-1)
We need a half decent area near Las Vegas! (I56-1)
We need a half decent area near Las Vegas!... The new lifts for ski and MTB Park are the
most important items. (I57-1)
The expansion would keep more families form having to travel out of state for the same
entertainment. (I58-1)
I suggest making the area a Fee use area, this will help reduce the over crowding and fund
improvements to combat over crowding. I highly suggest looking into Snow Summit
Ski/Mountain Bike park in Big Bear Lake, CA. as a model. Very successful program! (I59-
1)
Please approve the proposed development of the Lee Canyon ski area for all season
activities. (I60-1)
I believe this could be one of the greatest things to happen for the love of winter sports.
(I62-1)
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I am in favor of offering more outdoor activities to be available to our residents. I

completely support the proposed plan to add mountain biking as a summer activity at the
Lee Canyon Ski area. (I65-1)
I see a huge need to upgrade the facilities to accommodate the visitor’s needs. (I67-1)
I think the proposed items are a wonderful and long overdue addition to the very few
resources we have in the Mount Charleston area. (I68-1)
I fully support the expansion of the ski resort at Lee Canyon. (I69-1)
I am looking forward to the forthcoming expansion of Lee Canyon. It will be a big asset to
the greater Las Vegas area. (I70-1)
I am looking forward to the proposed expansion of Lee Canyon. It will add to the attraction
of the Las Vegas Area. It will add to the diverse opportunities to do new things. (I71-1)
Would love to see this happen! (I72-1)
Projects like this are needed. (I74-1)
I fully support the effort and cannot wait to see the development.(I80-1)
I fully support the effort and cannot wait to see the development. (I81-1)
Updating and enhancement of this family sport activity is long overdue and sorely needed.
(I84-1)
These proposed plans for Lee canyon will be the best thing that ever happened to it. (I89-
1)
I fully support the project to expand the Lee Canyon park and the capital improvements
that would be part of the project. (I90-1)
I would definitely like to see more attractions available because it would enhance our
experience even more. (I92-1)
As an advocate for nature, conservation and the environment, I strongly support expanding
Lee Canyon's accessable areas. For multiple reasons. The first being the space allocated
for improvements is not not sufficient… I also believe it's worth noting Lee Canyon is taking
all the risks, willing to invest millions in infrastructure and creating year round jobs. Lee
Canyon / powdr corp. has proven their commitment to the area, ability to manage a
sensitive environment and should be rewarded. (I93-1)
What a great opportunity to get more people outdoors and see the beautiful Lee Canyon
area. (I97-1)
When I first visited Mount Charleston however, I began to ask " where is the rest of it?"
For such an active, lively city why is the life in nature so under-developed. I heard about
the Blue butterflies, but that to me created a vast amount of un-checked, un-regulated trail
systems. Expanding the resort area would not only increase revenue from outside of Las
Vegas, it would keep more revenue in the city. (I101-1)
I thin this would be a great use of the area. (I105-1)
I am all for this expansion. (I106-1)
I am supportive of the Lee Canyon expansion plan. (I108-1)
I think the increased recreation options is great and badly needed. (I109-1)
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As an avid skier and outdoorsman, this expansion isnlhas by overdue and I am happy to
see it happen. (I111-1)
I would like to see more lifts mountain trails and restrooms. (I113-1)
I am in support of the Lee Canyon expansion especially for lift access mountain bike trails.
(I114-1)
I am for the expansion of ski trails, mountain bike trails, ski lifts. (I115-1)
I support the proposed to expand the Lee Canyon area for skiing and all summer use
facilities. (I116-1)
BCT Alternative
Lee Canyon’s preferred alternative is the BCT alternative…
• The BCT alternative addresses all three keys parts of the purpose and need.
• The BCT alternative includes a buffer between the BCT and new ski run
construction.
• The BCT alternative eliminates the winter user’s conflict that exists between the
BCT and the last chance ski run that overlap in places. This issue exists in both
the original proposed action and the no action alternative. (O4-3)
….any resort activity should be limited to the resort area and be kept separated from the
existing Bristlecone hiking trail. (I38-4)
The Bristlecone Trail Alternative is a step in the right direction by moving the ski runs
away from the Bristlecone Trail and its populations of Clokey eggvetch and other sensitive
plants species, as well as changing the design of Chair 8, and relocating the Mountain
coaster and zip line to the east of Chair 1. (I45-2)
I support the Bristlecone Trail Alternative. (I46-1)
4. The BCT alternative appears to offer the best alternative that produces both an increase
in trails and lifts for the skier and preservation of at least some semblance of scenic hiking
along the Upper BCT. (I49-5)
I would really like to have the lifts and the mountain biking trails as long as it doesn't
impact bristle cone trail. (I63-1)
I believe the Bristlecone Trail Alternative (BTA) is the best alternative for the National
Forest Service to select and I encourage you all to expeditiously issue your decision to
authorize that action. (I100-1)
Increased Terrain
Due to the number of skiers and boarders on the mountain, increasing the terrain capacity
is essential and achievable with minimal destruction. (I67-4)
Mountain Biking
…we are very excited and strongly supportive of mountain biking being included in the Lee
Canyon expansion proposal. (O6-1)
I am particularly in favor of the addition of mountain bike trails to the area. There are too
few mountain bike trails in higher altitude in southern Nevada and riding at lower
elevations in the summer months is difficult and dangerous. (I7-2)
I would be in favor of some additional mountain biking terrain in the resort area. (I38-2)
264
Thank you for considering mountain biking in your Lee Canyon expansion proposal. (I44-
1)
I'd love to see the resort expanded and I would love to see mountain biking added to it.
(I47-1)
Pleaseeeeeeeeeeeeee build these mountain bike trails with lift access for the
Spring/Summer/Fall! (I76-1)
I think the expansion of Lee Canyon would be beneficial to all who currently use this area
and also the new visitors it would attract. The addition of lift supported mountain biking
has been long overdue. (I95-1)
I am in support of the Lee Canyon expansion especially for lift access mountain bike
trails.(ii14-1)
Snowmaking
Due to the inconsistency in weather, snow making equipment is a necessity to provide snow
during the low seasons. An expanded water reservoir and additional snow making
equipment are basic requirements to sustain the business annually and should be
permitted. (I67-1)
Winter Improvements
I am in favor of the additional ski lifts, skiing terrain, and certain lodge improvements.
(I38-1)
Opposed
I object to the expansion into sensitive habitats. (I16-1)
Please do not expand Lee Canyon. (I24-1)
I am strongly oppose to the proposed expansion proposals and urge that these not be
approved. (I32-5)
…expansion of a ski area that serves a very small segment of our population and has a
very negative environmental impact should not happen. (I34-1)
..adamently opposed to any further commercial development in the Mt. Charleston-Lee
Canyon area. (I48-1)
…wildlife need all the refuge they have left. Let’s not disturb and distress them any more
than they already are. The least we can do in this area is leave them this national forest.
(I85-2)
i am against allowing this expansion on national land owned by 328 million american
citizens. (I91-1)
Further expansion of for-profit business plans will not benefit the unique and diverse
habitat of the Spring Mountains. (I94-1)
Let the area remain as is. (I98-1)
I FIRMLY OPPOSE this Lee Canyon development, not only for myself, but for the
environment and the wildlife in the area. (I99-1)
I totally object to the new recreation project at Lee Canyon (I102-1)
Therefore, I am opposed to this proposed expansion and additions to the Resort. (I107-6)
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I oppose the proposed expansion of Lee Canyon Ski Area. (I110-1)

Summer Use/Expansion
I cannot support any expansion by a for-profit organization wishing to infringe on hiking
trails in the Spring Mountains. Specifically the Mt. Charleston wilderness that sees an
enormous amount of pressure during the summer months as is. The expansion area in
question will significantly reduce the enjoyment of the existing trails, removing the reason
for hiking in this area in the first place. (I8-1)
..there's simply no way for the Lee Canyon ski area to become an extreme-sports summer
amusement park without threatening the butterfly's long-term survival. Please do not allow
the summer expansion of Lee Canyon ski area. (I73-2, I78-1)
I'm opposed to the Forest Service turning the butterfly's habitat into a year-round extreme-
sports amusement park. Carving up its critical habitat with miles and miles of braided
downhill mountain-bike trails will limit the butterfly's connectivity and ability to move
across the landscape over time. Introducing thousands of new recreational users to the
mountain will also inevitably cause new harms to those areas which are currently largely
undisturbed in the summer. (I117-1 through I344-1)
Mountain Coaster and Zip Line
Please do not allow for any coaster. Also do not allow for zip lines. (I11-1)
While the document as a whole states that only those activities not available in other, more
appropriate areas are considered, it then asserts the "mountain coaster" is "not an
amusement park style ride" when in fact the zip line and the mountain coaster not only turn
part of the national forest into an amusement park but both the zip lines and coaster rides
are available in Las Vegas and surrounding areas…. Not only are these two elements
inappropriate amusement park/Las Vegas type experiences but the coaster totally disrupts
the hiking experience on the Upper Bristlecone Trail for hikers and others of traditional
pursuits in national forests. (I18-2)
I am opposed to the mountain coaster. (I38-3)
I vehemently object to the proposal for the mountain coaster at its current location. (I42-
1)
I understand the desire to add entertainment options such as zip lines and roller coasters
to expand the lure for summer visitors, however I have no opinion on such additions and
prefer keeping a more natural recreational setting. (I67-6)
Please don't turn Lee Canyon in to another tourist attraction. Las Vegas has plenty of zip
lines and coasters. (I77-1)
I am against the proposed mountain coaster and zip line. I feel this will attract people that
have an ignorance of the wilderness experience and will invite unwanted activities like
graffiti, littering, harassing wildlife…. (I79-1)
There should be no coaster nor zip line at all. (I87-1, I88-1)
I don’t think they should be having a mountain coaster at all. (I104-1)
People that want to use a "Zip" line should go to Fremont street in Las Vegas, not have an
eyesore built in a beautiful national rec area that everyone for many miles around would
have to look at while trying to enjoy natures beauty on public lands. (I112-1)
.. not for the expansion of zip line or mountain roller coaster. (I115-2)
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Snowmaking Expansion
I strongly urge that the expansion of man made snow be rejected as not sustainable. (I18-
5)
Chair 8 and Ski Runs
I feel that Chair 8 and its associated ski runs should be entirely eliminated in the planning
process. The healthy upper elevation forest would be destroyed with construction of Chair
8 and its ski runs. (I45-3)
267

Las Vegas-Area Ski Resort Expansion Plans

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Final Environmental Impact Statement:

Lee Canyon Ski Area Master Development Plan

With the assistance of:

Lead Agency: USDA Forest Service

• Gate house on the access road.

Project-specific Forest Plan Amendment:

PURPOSE AND NEED

RELATIONSHIP TO THE FOREST PLAN

Bristlecone Trail Alternative

COMPARISON OF ENVIRONMENTAL EFFECTS

Table S-1. Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

Table S-1 (cont’d). Summary and comparison of environmental effects.

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2.2 Proposed Action .................................................................................................................................... 15

3.4.1.1 Background and Methods ................................................................................................... 44

3.7.2.3 Native American Concerns ............................................................................................... 138

3.12.1 Scope of Analysis................................................................................................................... 173

Soil, Water, and Watershed............................................................................................................... 198

Figure 3-7. Viewpoint 2, proposed action................................................................................................. 154

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CHAPTER 1: PURPOSE AND NEED

Figure 1-1. Vicinity map.

1.2 ORGANIZATION OF DOCUMENT

• Summarizes the proposed action.

1.3 PROPOSED ACTION

1.4 PURPOSE AND NEED

1.5 DECISIONS TO BE MADE

1.6 RELATIONSHIP TO THE FOREST PLAN

1.7 SCOPING AND IDENTIFICATION OF ISSUES

1.7.1 ISSUES CARRIED INTO IN-DEPTH ANALYSIS

1.7.1.1 Soil, Water, and Watershed Resources

1.7.1.4 Cultural Resources

1.7.1.5 Scenery Resources

1.7.1.9 Land Use

1.7.2 CONCERNS IDENTIFIED BUT NOT ANALYZED IN DEPTH

o applicable laws (including regulations).”

1.7.2.8 Inventoried Roadless Areas

1.8 PROJECT RECORD

1.9 OTHER PERMITS AND AUTHORIZATIONS

Agency Type of Action Description of Permit or Action

Agency Type of Action Description of Permit or Action

CHAPTER 2: PROPOSED ACTION AND

2.2 PROPOSED ACTION

2.2.1 LIFTS AND SKI RUNS

2.2.1.2 Chair 5 Pod

2.2.1.3 Chair 8 Pod

Figure 2-1. Proposed action – lifts, ski runs, and snowmaking.

Figure 2-2. Proposed action – summer activities.

Figure 2-3. Proposed action – facilities.

2.2.1.4 Tree and Glade Skiing

2.2.2 SNOWMAKING COVERAGE

2.2.3 SUMMER ACTIVITIES

2.2.3.2 Mountain Bike Trails

2.2.3.3 Hiking Trail

2.2.3.4 Zip Line

2.2.4.2 First Aid/Ski Patrol Building

2.2.4.3 Vault Toilet Facility at Overflow Parking Lot

2.2.4.4 New Parking Lot