Post on 18-Jul-2020
Notice of Proposed Action
Keystone Resort
Dercum Mountain Improvements Project
Dillon Ranger District, White River National Forest Summit County, Colorado
Comments Welcome
The Dillon Ranger District of the White River National Forest (WRNF) welcomes your
comments on proposed projects on Dercum Mountain at Keystone Ski Resort. Your
comments will help us complete an environmental assessment (EA). Details on how to
comment are found at the conclusion of this document.
Consistent with direction found in 36 CFR §215.5 (Legal Notice of Proposed Actions) this
Notice of Proposed Action (NOPA) has been prepared to solicit public comments on: the
Purpose and Need for Action; the Proposed Action; and potential alternatives to the Proposed
Action. Potential effects of the Proposed Action on the human and biological environment
will be analyzed and disclosed in an EA, which will take into account public comment
received in response to this NOPA. A Decision Notice will be released concurrent with the
EA. A Decision Notice will document the Responsible Official’s selected alternative. Per 36
CFR §215 (Notice, Comment, and Appeal Procedures for National Forest System Projects
and Activities) a 45-day administrative appeal period will accompany release of the Decision
Notice.
Background
Keystone Ski Resort (Keystone) opened to the public in 1970. Keystone operates under a
Forest Service-issued special use permit (SUP) authorizing the use of National Forest System
(NFS) lands for the purposes of constructing, operating, and maintaining a winter sports
resort, including food services, rentals, retail sales, and other ancillary facilities. The SUP
covers 8,536 acres on the Dillon Ranger District of the WRNF approximately six miles south
on Highway 6 from the Silverthorne/Dillon exit off Interstate 70.
Guest expectations continue to evolve in today’s competitive skier/rider market and resorts
must constantly focus on raising service standards and improving the overall recreational
experience. Keystone has not made many substantive infrastructural or qualitative
improvements over the past two decades (since the Outpost Gondola was installed in 1991).
The most notable improvements since that time include: the replacement of the Ruby chairlift
with a detachable six-pack in 2000; the addition of the A-51 Terrain Park in 2004; and
replacement of the River Run Gondola in 2009.
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In accordance with the terms of the SUP, Keystone completed a Master Development Plan
(MDP) in 2009 to outline its plans for future development and improvement on NFS lands
within its SUP area. Projects contained in this proposal are identified in, and consistent with,
Keystone’s 2009 MDP, which has been reviewed and accepted by the WRNF. The WRNF
recently accepted Keystone’s proposal for these projects, and is now initiating a site-specific
NEPA analysis.
The Dercum Mountain Improvements proposal is designed to improve the overall
recreational experience at Keystone by accommodating existing and future guest
expectations. Proposed projects specifically address: the resort’s family atmosphere; on-
mountain guest services; teaching opportunities, snowtubing at Adventure Point;
snowmaking infrastructure and coverage; the mountain bike trail network; and resort
maintenance/operations.
With one exception (a snowcat access route), all proposed projects are within Keystone’s
Forest Service-administered SUP boundary, which encompasses 8,536 acres of NFS lands.
With two exceptions, proposed projects are limited to the front side of the resort on Dercum
Mountain.
Purpose and Need for Action
The Purpose and Need for Action is focused on improving the quality of the experience at
Keystone.
All guests – regardless of their ability level – access and depart Keystone’s lift and trail
network via Dercum Mountain. Select trails on the front side of Dercum Mountain also have
lights for night skiing. With primarily beginner and intermediate terrain, Dercum Mountain is
very popular with Keystone’s core market sector (intermediate skiers) and is heavily used for
teaching terrain. All of Keystone’s beginner teaching terrain is located on Dercum Mountain.
In addition, the nationally recognized A-51 Terrain Park is located on the west side of
Dercum Mountain.
The summit of Dercum Mountain provides two key facilities: The Summit House and
Adventure Point. The Summit House provides rental lockers, limited retail, a bar/lounge and
restaurant, restrooms, ski school, and a ski patrol area. This facility is heavily used
throughout the ski day and during the evening for night skiing. Adventure Point provides
snowtubing for alternative winter recreation throughout the day and evening.
Due to the importance of Dercum Mountain for defining the recreational experience at
Keystone, strategic improvements are necessary to maintain and enhance Keystone’s
reputation as a family oriented resort in today’s recreation and action sports market.
Keystone has identified upgrades to the front side of Dercum Mountain as the highest priority
projects from the 2009 MDP. Specific projects that have been designed in response to each
need are identified and discussed in detail below.
Need #1: Improve On-Mountain Guest Services
The existing Summit House was built in 1970 and has been expanded and retrofitted several
times over the years. The result is a series of disconnected and inefficient spaces and
outdated architecture that neither meets guest needs/expectations nor fits with the character
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of the resort. The 2009 MDP identifies a 13,000 square foot deficiency at the Summit House
in the following areas: bar and lounge space, ski school space, restaurant seating, food
preparation, restrooms and ski patrol.
In addition, the existing on-site wastewater treatment system for the Summit House is
antiquated and requires the maintenance of a septic system, leach fields, and a sewage lagoon
on public lands.
To respond to this need the following projects are proposed:
Removal and replacement of the Summit House Restaurant with a larger facility
New water and wastewater infrastructure to support this facility
Need #2: Enhance Keystone’s Ability to Provide Early Season Terrain
Keystone depends on its snowmaking system to ensure a consistent and quality snow surface
throughout the season. Numerous components of the snowmaking system on Dercum
Mountain have been identified that represent inefficiencies in terms of water, electricity, and
time.
On Dercum Mountain, existing snowmaking infrastructure that has historically been used to
provide coverage on Whipsaw, Crosscut, Bachelor and Jack Straw trails, as well as trail
connectors, is antiquated and inefficient. For example, Jack Straw (below Zuma Highway)
has no permanent snowmaking infrastructure (pipes or hydrants). The location of the nearest
air/water hydrant makes for a long push for snowcats. Furthermore, while snowmaking
coverage has historically been provided on Wild Irishman, this trail does not have dedicated
infrastructure. Instead, hoses are dragged over-the-snow from Frenchman (adjacent to Wild
Irishman) to accommodate snowmaking coverage there.
To respond to this need the following projects are proposed:
New snowmaking coverage on strategically located trails and areas across Dercum
Mountain. Specifically, new snowmaking coverage would be provided on School
Master, Hoodoo, around the expanded Adventure Point snowtubing area, around the
proposed surface conveyor near the mid-station of the River Run Gondola, and on the
proposed beginner area between the Ranger and Kokomo lifts.
Strategic snowmaking infrastructure upgrades and installations in order to continue to
provide coverage on Bachelor, Cross Cut, Wild Irishman, Whipsaw, and Jack Straw
Need #3: Improve and Enhance Adventure Point
Adventure Point, at the top of the River Run Gondola, is popular with all ages, including
both skiing and non-skiing guests. However, due to the limited area in which this facility
exists, only five tubing lanes can be constructed during the season and the number of
snowtubers is therefore limited during each one hour session. During busy times such as
holidays and spring break, as well as the popular evening hours, guests routinely wait in long
lines between tubing runs (limiting the number of runs they can make in a one hour session),
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or wait for later sessions that can accommodate their group. Furthermore, the guest services
at Adventure Point are currently provided in a yurt that is undersized and does not provide
restrooms.
To respond to this need the following projects are proposed:
Construct two-to-four new additional tubing lanes
Remove and replace the existing yurt with a larger facility with restrooms
Need #4: Improve Teaching/Learning Areas at Keystone’s Ski and Ride School
Keystone’s learning/teaching areas are located at three sites across Dercum Mountain: at the
Mountain House base area; at the River Run Gondola mid-station; and at the summit.
Generally, the children’s ski school participants stay in the base area and then move onto the
Kokomo carpet lift and the Ranger chairlift at the summit of Dercum Mountain; the adult ski
school participants start at the summit.
The majority of beginner skiers use the teaching terrain at the summit; therefore these two
lifts and the associated terrain are in high demand. Because surface lifts are ideal for beginner
skiers who often times find loading and unloading chairlifts difficult, there is a need for an
additional carpet lift at the top of Dercum Mountain in this popular teaching terrain. Given
the heavy use of beginner lifts at the summit, there is a need for additional beginner terrain
and associated surface lifts elsewhere on Dercum Mountain.
To respond to this need the following projects are proposed:
Develop new teaching terrain and install an additional surface conveyor lift at the
summit of Dercum Mountain
Install a new surface conveyor lift at the mid-terminal station of the River Run
Gondola
Install a new surface conveyor to accommodate a teaching terrain park above the A-
51 terrain park.
Need #5: Improve on Keystone’s Family Atmosphere
Keystone’s reputation as a family-friendly resort is a result of the many children’s events
offered, the Tubing Hill, and the innovative teaching terrain (kid-friendly runs and adventure
zones). Keystone currently offers adventure zones within tree islands throughout the front
side of Dercum Mountain. The adventure zones include obstacles and features that help
children learn skiing and riding techniques in engaging ways. The adventure zones are short
isolated courses including Klondike’s Adventure, Lost Mine, Ripperroo’s Forest and
Ripperoo’s Alley. Often, beginners ride traditional chairlifts to reach adventure zones
dispersed throughout the front side of Dercum Mountain, which can be difficult to navigate
for families and small children.
Keystone has identified opportunities on Dercum Mountain for expanding on this theme and
creating a dedicated adventure zone with more diverse terrain and features that would be a
fun and innovative way to teach skills and build confidence. Additionally, enhancing the
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adventure zones with forest interpretive features would broaden its appeal and provide an
educational aspect for kids and adults, and also provide the opportunity for Keystone to
promote their relationship with the Forest Service. These zones would also encourage
families to make a stronger connection to the forest and outdoor recreation.
To respond to this need the following project is proposed:
Conversion of four tree islands on the western side of Dercum Mountain into a
dedicated "Family Adventure Zone"
Need #6: Improve Skier Egress from Bergman Bowl
Bergman Bowl is located east of The Outpost on North Peak. The upper bowl has gentle
slopes suitable for low intermediates, while the lower slopes are somewhat steeper and
suitable for intermediate/advanced intermediate skiers. The lower half of the bowl is tree
covered and only a small portion of it is skied. There is no lift service to this portion of the
SUP area. Keystone Adventure Tours primarily uses the upper half of Bergman Bowl to
begin snowcat tours for guests prior to engaging them in more difficult terrain in Erickson
and Independence bowls. To ski out of the bowl, guests must navigate a narrow, treed trail,
requiring more advanced skills. To improve egress for the public, as well as ski patrol, a new
egress trail is proposed.
To respond to this need the following project is proposed:
Construct a groomable egress trail above the drainage in Bergman Bowl
Need #7: Separate Resort Snowcats and Guests
Currently, snowcats operate on Dercum Mountain to navigate between the maintenance
facility (at the Mountain House base area), North Peak and the Outback. During operational
hours, snowcats that drive up and down the front side encounter skiers and riders coming
down the mountain. Additionally, traveling up and down the steep terrain between Dercum
Mountain and the Outback requires more fuel than traveling a flatter route.
To respond to this need the following project is proposed:
Construct of a dedicated snowcat access route between the Mountain House
maintenance facility and Keystone Gulch Road
Need #8: Improve Lift-Served Mountain Biking at Keystone
Keystone has earned a reputation for its advanced lift-served mountain bike trails and
features; however, the resort sees the need to provide more beginner and intermediate bike
trails for its guests. The resort has identified opportunities across Dercum Mountain for
expanding its beginner and intermediate mountain bike terrain.
Currently lift-served mountain bike trails at Keystone allow riders to choose between easier
and more difficult trails several times along each route. Although this can be beneficial for
more skilled riders who want to bypass certain trail segments, it can be challenging for lower
ability level riders to share trail segments with more seasoned riders. Keystone has identified
opportunities across Dercum Mountain for maintaining existing trail connectivity while
providing other trail segments that are entirely beginner or intermediate. Additional trail
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segments could also be designed to offer bikers options to avoid using mountain access
roads.
To respond to this need the following project is proposed:
Construct new mountain bike trails that would: 1) divide trails into distinct ability
level zones – beginner, intermediate and advanced; 2) develop more beginner and
intermediate trails; and 3) improve trail design by minimizing vehicle/bike conflict
areas.
Proposed Action
Components of the Proposed Action focus on addressing the needs that were previously
identified. Each proposed project component is identified on the attached figure. If approved,
construction of the proposed improvements would occur primarily in the summer months
and, given the short construction season at Keystone’s higher elevations, are expected to be
completed over multiple construction seasons. In conjunction with any approved ground
disturbing activities, best management practices would be implemented to avoid or minimize
resource impacts (e.g., soil, water and vegetation). All disturbed areas would be revegetated
and stabilized promptly.
Calculations presented in this NOPA document were produced using Geographic Information
Systems (GIS) software and while accurate, they are approximate values. As further analysis
is completed for the EA, these values will become more precise.
1. Summit House
The Summit House would be replaced with a larger, multi-story facility (approximately
20,000 square feet) with capacity for roughly 700 indoor guests and 200 outdoor guests. The
Summit House would accommodate daytime and evening use, food service, ski patrol,
restrooms, and ski school. The facility could also accommodate special events.
The proposed Summit House facility would be constructed consistent with the provisions of
the Forest Service’s Built Environment Image Guide (BEIG) and would incorporate energy
efficient building systems. The new design would better fit with the existing buildings at
Keystone and would incorporate ranching, mining and/or rustic influences as prescribed by
the BEIG for the Rocky Mountain Province. Under BEIG standards, the building form would
be relatively simple and compact with pitched roofs and modest overhangs. Natural building
materials, such as stone, wood, and heavy timber would be used when available and
practical. Color schemes would be inspired by the natural surroundings.
While the final location of the proposed facility at the summit of Dercum Mountain has not
been determined, it would be in the general vicinity of the existing Summit House
Restaurant, between the top of the Outpost Gondola and Ruby Express. An approximately
three acre disturbance area is proposed to be graded at the top of Dercum Mountain. This
proposed graded acreage accounts for removal of the existing facility and construction of the
proposed facility (refer to attached figure).
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2. Adventure Point
To better accommodate existing use at Adventure Point, two to four additional tubing lanes
are proposed adjacent to, and parallel with, the existing lanes (refer to the attached figure).
The new lanes may extend further down slope to accommodate a longer ride. Approximately
four acres of grading and tree removal would be necessary to implement this project.
Additional snowmaking coverage, utilizing existing infrastructure at Adventure Point, would
be necessary and is discussed below.
The existing yurt at Adventure Point is proposed to be removed and replaced with a new
2,500 square foot permanent facility. The proposed Adventure Point facility would better
accommodate operations and guest needs, and would include a small food and beverage
service outlet, observation platform, restrooms, ticketing and storage. Keystone’s long-term
goal for this proposed facility is for it to become an interactive outdoor adventure complex
that integrates the tubing operations with summer mountain bike operations.
The proposed Adventure Point facility would be located uphill of the existing yurt. The
location would minimize conflicts with existing infrastructure. As with the proposed Summit
House facility, it would be constructed consistent with the provisions of the BEIG. Utility
lines for this proposed facility would tie into the Summit House infrastructure. Construction
of the proposed facility would result in approximately one acre of new ground/vegetation
disturbance, and the location of the existing yurt would be revegetated.
3. Infrastructure
New water and wastewater systems would be required to support both the proposed Summit
House and the adjacent Adventure Point tubing facility. Water and wastewater lines are
proposed from the summit of Dercum Mountain down the Mine Shaft and Diamond Back
trails, tying into existing sewer and well water services located on the Keystone Gulch Road.
These new sewage lines would eliminate the need for the septic system, leach fields, and a
sewage lagoon on NFS lands south of Adventure Point.
4. Teaching Area and New Carpet Lifts
The existing learning area at the summit of Dercum Mountain is proposed to be
supplemented with approximately four acres of new teaching terrain and an additional
surface conveyor lift. The new terrain is proposed west of the Summit House between the
Ranger and Kokomo lifts, and would address existing demand for teaching terrain.
Additionally, by adding the terrain and lift, the area would be better defined as a teaching pod
and would encourage a separation of ability levels in that area. Four acres of tree clearing and
grading would be required to create this new teaching terrain.
Two other areas are proposed for new teaching (carpet) lifts: 1) the lower end of Schoolmarm
uphill of the Peru Express top terminal; and 2) near the mid-terminal station of the River Run
Gondola. The proposed teaching lift at the mid-terminal of the Gondola would supplement an
existing carpet lift already in that location. This area is especially busy on days with
inclement weather. The proposed carpet lift uphill of the Peru Express would service a terrain
park teaching area near the more advanced A-51 Terrain Park. Less than one acre of tree
clearing/grading would be necessary for the proposed surface conveyor near the mid-terminal
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station of the gondola, but no new clearing or grading would be required for the proposed
carpet lift near the Peru Express Lift.
5. Family Adventure Zone
Four tree islands on the western side of Dercum Mountain are proposed to be developed into
a "Family Adventure Zone." The Family Adventure Zone is intended to be exciting and
unique and would help further distinguish the Keystone brand as a premier family
destination. The design intent of this project is to provide the opportunity to promote the
partnership between the US Forest Service and Keystone in helping families make a stronger
connection to the forest and outdoor recreation.
This project would involve grading, tree clearing and construction of numerous interactive
features within and around the tree islands on Schoolmarm, Schoolmaster and Hoodoo to
create a unique family-oriented experience. The project entails developing trail sections into
highly interactive, educational, skiing/riding features for children of all ages and their
families. All ability levels would be able to engage in this experience. It is important to note
that it is not intended to be a skier/rider "park" such as the terrain parks, but is proposed to
provide fun locations for children to learn the basics of the sport through an educational and
interpretative process. Guests would visit both permanent and seasonal themed areas with
dynamic, hands-on learning experiences such as a mining town, snow forts/igloos, tree
houses, a mock fire lookout tower, smart terrain modifications (i.e., strategic grooming
intended to aid in the teaching/learning experience), and ecological and educational
attractions. Refer to the attached figure for the location of the Family Adventure Zone
including features interspersed throughout.
As discussed previously, snowmaking would be necessary to maintain the experience of the
Family Adventure Zone (on Hoodoo and Schoolmaster). Other infrastructure components
include electrical lines, a tunnel and a bridge. Tree clearing, grading, and installation of
additional features in the Family Adventure Zone would result in approximately five acres of
disturbance. In conjunction with this project, portions of Hoodoo are proposed to be
revegetated (refer to attached figure).
6. Jane’s Journey Snowcat Skiing Egress
In order to improve egress for guests and ski patrol in Bergman Bowl, a groomable trail is
proposed to be created above the drainage in Bergman Bowl. The proposed trail would be
approximately 50-60 feet wide and 3,500 feet long, requiring minimal tree removal and spot
grading.
7. Keystone Gulch Snowcat Access Route
A snowcat access route is proposed to connect the maintenance shop near the Mountain
House base area west to Keystone Gulch Road. This dedicated snowcat access route would
eliminate snowcat/skier conflicts as well as reduce fuel consumption between the Outback
and Mountain House. The approximately 35 foot-wide route would extend for approximately
5,150 feet and would generally follow Granny‟s mountain bike trail alignment, requiring
approximately four acres of tree removal and grading along its extent. The area would be
revegetated upon completion of construction and Granny‟s trail would be re-established.
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8. Mountain Bike Trails
Seven new mountain bike trails are proposed. The intent of new mountain bike trails is
threefold: 1) divide trails into distinct ability level zones – beginner, intermediate and
advanced; 2) develop more beginner and intermediate trails; and 3) improve trail safety by
minimizing vehicle/bike conflict areas. Proposed mountain bike trails would be constructed
using a combination of hand tools and Sweco machinery, and would require grading and tree
removal for the length of the trails. The following proposed trails are identified, by number,
on the attached figure.
MTB #1: a 3.5-mile beginner trail starting at the summit of Dercum Mountain and
terminating at the base of the resort.
MTB #2: a one-mile intermediate route off the summit of Dercum Mountain.
MTB #3: a 0.5-mile intermediate extension of an existing advanced trail.
MTB #5: a 2.5-mile intermediate trail.
MTB #6: a 0.25-mile intermediate trail providing access to Helter, an existing 3-mile
intermediate trail.
MTB #7: a one-mile intermediate trail designed to improve circulation and improve
trail safety by reducing usage of an existing intermediate trail in the same area.
Girl Scout Trail extension: a new portion of the existing beginner Girl Scout trail. As
the existing trail is intersected by advanced trails the design intent is to separate
different ability levels and create an easier trail for intermediate riders.
The single proposed beginner trail (MTB #1) would be approximately eight feet wide, while
the intermediate trails would be approximately three to six feet wide. Wetlands within the
vicinity of the trails would be avoided or bridged.
9. Snowmaking Infrastructure
Proposed snowmaking projects fall into two categories: 1) trails with existing coverage that
require upgraded/expanded infrastructure; and 2) new coverage.
New snowmaking coverage is proposed on School Master, Hoodoo, around the expanded
Adventure Point snowtubing area, around the proposed surface conveyor near the mid-station
of the River Run Gondola, and on the proposed beginner area between the Ranger and
Kokomo lifts.
New snowmaking infrastructure on School Master and Hoodoo would be used to provide
coverage for the proposed Family Adventure Zone trails. The School Master and Hoodoo
snowmaking infrastructure would provide coverage for the entire Family Adventure Zone
both directly and indirectly (i.e., by dragging hoses through existing and revegetated areas).
Existing snowmaking infrastructure that has historically accommodated coverage on
Bachelor, Cross Cut, Wild Irishman, Whipsaw, and Jack Straw is proposed to be upgraded
and or expanded. Replaced and expanded snowmaking infrastructure on these trails would
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expedite snowmaking operations and improve snow consistency on these important and
heavily used trails. Note that the area of coverage on these trails would not increase as a
result of proposed upgrades.
New and upgraded snowmaking would require additional water which is within Keystone’s
existing water rights. Temporary ground disturbance as a result of installing and replacing
snowmaking infrastructure is expected to total approximately 15 acres, excluding areas of
ground disturbance accounted for under other tree removal and grading calculations. All
disturbed areas would be revegetated and returned to their pre-construction condition.
Table 1: Summary of the Proposed Action
Project Component
Linear
Length Disturbance Area
Acres of New
Snowmaking
Coverage
1. Summit House N/A 3 Acres N/A
2. Adventure Point N/A 1 Acre 3 Acres
3. Infrastructure
6,450
Linear
Feet 6 Acres N/A
4. Teaching Area and New Carpet Lifts N/A Less than 5 Acres Total
Less than 5 Acres
Total
4a. Summit Teaching Area N/A 4 Acres 4 Acres
4b. Mid-terminal Teaching Area N/A Less than 1 Acre Less than 1 Acre
4c. Terrain Park Teaching Area N/A None N/A
5. Family Adventure Zone N/A 5 Acres 14 Acres
6. Jane's Journey Snowcat Skiing Egress
3,500
Linear
Feet Minimal Spot Grading N/A
7. Keystone Gulch Snowcat Access Route
5,150
Linear
Feet 4 Acres N/A
8. Mountain Bike Trails
9 Miles
Total
Less than 15 Acres
Total N/A
8a. MTB #1 3.5 Miles 8 Acres N/A
8b. MTB #2 1 Mile Less than 1 Acre N/A
8c. MTB #3 0.5 Mile Less than 1 Acre N/A
8d. MTB #5 2.5 Miles 2 Acres N/A
8e. MTB #6 0.25 Mile Less than 1 Acre N/A
8f. MTB #7 1 Mile Less than 1 Acre N/A
8g. Girl Scout Trail extension 0.25 Mile Less than 1 Acre N/A
9. Snowmaking Infrastructure
3 Miles
Total 16 Acres Total N/A
9a. Upgraded Snowmaking Infrastructure 2.5 Miles 13 Acres N/A
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9b. New Snowmaking Infrastructure 0.5 Mile 3 Acres N/A
9c. Total New Snowmaking Coverage N/A N/A
Approximately 27
Acres
Management Direction
The 2002 White River National Forest Land and Resource Management Plan (Forest Plan)
includes 33 separate Management Areas for different portions of the forest based on
ecological conditions, historic development, and anticipated future conditions. All
components of the Proposed Action fall within the 8.25 Management Area – Ski Areas
(Existing and Potential), which directs:
“Facilities may be intensively used throughout the year to satisfy a variety of
seasonal recreational demands… Protection of scenic values is emphasized through
application of basic landscape aesthetics and design principles, integrated with
forest management and development objectives… Transportation systems provide
convenient access to National Forest System lands in key portal locations with
adequate public parking, base facilities, and community infrastructure. Base areas
that serve as entrance portals are designed as gateways to public lands. They are
architecturally designed to blend with the forest setting and contain convenient
facilities and services that provide for the needs of forest visitors.”1
As part of the analysis, the Purpose and Need for Action and the Proposed Action are being
reviewed to determine consistency with the Forest-wide/Management Area Goals and
Objectives as well as the specific Standards and Guidelines for Management Area 8.25. The
2008 Southern Rockies Lynx Management Direction (SRLMD) amended the 2002 Forest
Plan with respect to Forest-wide and Management Area 8.25 Canada lynx standards and
guidelines. No inconsistencies between the Proposed Action and pertinent standards and
guidelines have been identified at this time.
Nature of Decision to be Made
The responsible official is the Forest Supervisor of the White River National Forest. The
responsible official will review the upcoming EA and will consider the Purpose and Need for
Action, the Proposed Action (and other potential alternatives), any public comments, and the
administrative record in order to make this decision.
In addition to determining which alternative to select, the Forest Supervisor will also
determine which Project Design Criteria (PDC) and best management practices (BMP) to
require to avoid, minimize, and mitigate impacts to resources.
1 USDA Forest Service, 2002c p. 3-80
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Public Involvement
The project was first listed in the Schedule of Proposed Actions in September 2010 and
updates are provided quarterly. Further information about this project can be found on our
website at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=33608.
Alternatives to the Proposed Action
No Action
The effects of not taking action will be analyzed as required by Council on Environmental
Quality regulations (40 CFR 1502.14(d). By definition, the No Action Alternative represents
a continuation of existing management practices without changes, additions, or upgrades to
existing conditions. The No Action Alternative serves as the baseline for which to compare
the potential environmental effects of the Proposed Action.
Effects and Issues to Consider
The EA will address the effects of the Proposed Action (and any alternatives) on the
following resources: recreation, scenery, air quality, cultural environment, traffic/parking,
wildlife and aquatic species, vegetation, soil resources, and watersheds and wetlands. The EA
will be issue-driven and contain detail commensurate to the degree to which a resource may
be affected.
Issues are unresolved conflicts that arise as a result of the Proposed Action. Initially, the
Forest Service has identified the following issues that will be analyzed in detail in the
forthcoming EA. Preliminary analytical indicators are provided for each issue. Both issues
and analytical indicators will be refined prior to, and within, the EA. As discussed, the Forest
Supervisor may also require additional PDC and/or BMPs.
Human Environment
Recreation
Issue: By design, proposed projects would alter the recreational experience at Keystone,
particularly for beginners and families. This extends to winter and summer activities, and includes
alternative forms of recreation.
Analytical Indicators & Requirements:
Discussion of Keystone’s ability to accommodate public skiing of all ability levels,
particularly beginners and families.
Discussion of the recreational opportunities provided at Keystone in all seasons under
each alternative.
Quantitative and qualitative analysis of existing and proposed guest service facilities
and infrastructure.
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Scenery
Issue: Proposed projects within Keystone’s developed lift and trail network may be visible from
identified critical viewpoints.
Analytical Indicators & Requirements:
Discussion of the Scenic Integrity Objectives (SIO) for the project area, as defined by
the 2002 WRNF Land and Resource Management Plan.
Documentation of the incremental effects to the scenic environment resulting from
implementation of the proposed projects compared to historic landscape alterations
within the SUP area.
Discussion of the Forest Service’s BEIG as applicable to existing and proposed guest
service facilities.
Viewshed analysis, from identified critical viewpoints, of proposed landscape
alterations as compared to the existing condition.
Cultural
Issue: Proposed projects and associated ground disturbing activities may affect known or
unidentified cultural resources.
Discussion of cultural surveys completed to date in the vicinity of the project area.
Inventory project area for cultural resources and historic properties.
Biological Environment
Wildlife and Aquatic Species
Issue: Implementation of proposed projects (including construction and use) could affect
Threatened, Endangered and Sensitive (TES) and Management Indicator (MIS) wildlife and
aquatic species.
Analytical Indicators & Requirements:
Acreage of impacts to Region 2 Sensitive, Management Indicator, and
Threatened/Endangered/ Candidate species’ habitat.
Minimum stream flow in the Snake River related to snowmaking diversions and past
agreements.
Identification and analysis of impacts on threatened and endangered aquatic species
and habitat present in the project area. (Consultation may be required for effects of
water depletion on big river endangered fish as a result of new snowmaking.)
Analysis of physical stream health in the project area and the effects on aquatic life.
Assessment of trout and macroinvertebrate populations in project area on streams and
at reference sites as based on field surveys.
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Documentation of presence/absence of sensitive amphibians and their habitat within
the project area.
Identification of Lynx Analysis Unit (LAU) boundaries in relation to the project area.
Vegetation
Issue: Plant communities (including Threatened, Endangered, and Sensitive [TES] species, WRNF
Species with an Identified Viability Concern [SIVC] and invasive plant species) may be impacted as
a result of proposed projects.
Analytical Indicators & Requirements:
Identification of threatened and endangered plant species and habitat present in the
project area.
Identification of Region 2 sensitive plant species and habitat present in the project
area.
Identification of WRNF species with an identified viability concern and habitat
present in the project area.
Quantification (acreage) of proposed ground disturbance and overstory vegetation
removal.
Identification of invasive species in the vicinity of the project area and use of BMPs
to limit their spread.
Soil Resources
Issue: Proposed ground disturbance and snowmaking may (individually and/or collectively)
increase erosion and reduce soil organic matter.
Analytical Indicators & Requirements:
Discussion of site-specific soil conditions and baseline inventory of soil organic
matter.
Area (acres) of temporary and permanent disturbance according to high/moderate/low
erodibility soils classes.
Analysis of increased erosion hazard due to ground disturbance.
Analysis of slope stability and geological constraints associated with project
components.
Watershed and Wetlands
Issue: Proposed ground disturbance (e.g. clearing and grading) and additional snowmaking may
contribute sediment and reduce stream bank stability in Camp Creek, Revelation Creek and Jones
Gulch and affect riparian habitat, wetlands and fisheries.
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Issue: Project activities may cause changes in surface and groundwater hydrology that support
streams and wetlands.
Issue: Additional snowmaking water use may impact the following: in-stream flows; aquatic
habitat through diversion; and water yield. It also may exacerbate drainage problems within the
project area.
Issue: Proposed ground disturbance (e.g. clearing and grading) may affect the quantity of wetlands
within the Study Area.
Analytical Indicators & Requirements:
Identification/quantification of waters of the U.S., including wetlands in the vicinity
of the project area.
Identification of any Clean Water Act (CWA) impaired or threatened waterbody
segments in the project area.
Quantification of existing and proposed water depletions (acre feet [AF]) for
snowmaking under all alternatives.
Quantification of connected disturbed areas (CDA) in the vicinity of the project area.
Quantification of total consumptive water losses (i.e., evaporation,
evapotranspiration, sublimation) resulting from existing and proposed snowmaking.
Identification of clearing and grading in the Water Influence Zone (WIZ).
Quantification of changes in water yield or discharge to receiving streams from
proposed snowmaking and grading.
Narrative description of affects to wetland functions and values.
Other issues raised in response to this NOPA will be considered and addressed in the
upcoming EA. Some issues may be addressed through modification of the Proposed Action,
development of a new alternative, or mitigation measures.
Summary of Resource Surveys and Inventories
Wildlife
The project area (i.e., the Dercum Mountain portion of Keystone’s SUP area) occurs within
the upper montane and subalpine life zones, at elevations between approximately 9,400 and
11,600 feet. Major habitat types present include lodgepole pine stands at the lowest
elevations, mixed conifer (lodgepole and spruce-fir) stands at mid-elevations, and spruce-fir
stands at upper elevations. All but two (a bike trail and snowcat access route) of the
components of the Proposed Action occur within or around the periphery of the developed
portion of Dercum Mountain where habitats have been fragmented by prior subalpine ski
terrain development. Furthermore, lodgepole pine stands at lower and mid-elevations of the
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project area have been more recently affected by the mountain pine beetle (MPB,
Dendroctonus ponderosae) epidemic.
Field surveys were conducted through all project component areas in each of the years
between 2008 and 2011. Surveys characterized and field verified habitat and lynx habitat
types and opportunistically searched for evidence of all federally-listed, proposed, and
candidate species, USFS R2 sensitive species, Management Indicator Species (MIS), and
migratory birds that may occur in the vicinity of project component areas or that may be
affected otherwise by the implementation of the Proposed Action. Consideration was also
given to the project area’s location in the landscape for broader habitat connectivity
considerations. Project-specific field surveys supplemented the extensive plant, habitat, and
animal database that is available for Keystone as a result of other project-related field surveys
conducted virtually every year dating back to 1990.
Ecological analysis of the Proposed Action (and any other action alternative[s] that might be
developed) may be considered at up to six scales: proposed disturbance areas, the project
area, the SUP area, the lynx analysis unit (LAU), the regional area, and the Planning Area,
depending upon the scales that are appropriate for a species or taxa. The effects of past and
present actions and the existing environmental baseline will be described for each of the
species carried forward for detailed analysis in the Affected Environment section of the
upcoming EA.
Field survey results have not been fully analyzed at the time of this writing, so project effects
considered herein are general, qualitative, and tentative. Impacts of the Proposed Action will
be quantified with respect to direct losses of individuals of particular species, habitat types,
lynx habitat types, and changes to LAU statistics. Reasonably foreseeable and reasonably
certain project effects will be analyzed, as appropriate, on those species that would be
affected by the Proposed Action.
Federally Listed Threatened and Endangered Species
The focal wildlife issues associated with the Proposed Action will be potential project effects
to the threatened Canada lynx (Lynx canadensis) and the four, endangered, big river fish
(humpback chub [G. cypha], bonytail [Gila elegans], Colorado pikeminnow [Ptychocheilus
lucius], and razorback sucker [Xyrauchen texanus]). With respect to lynx, most of the project
components involve small intertrail islands and the edges of larger islands, virtually all of
which are currently skied and that have little value as foraging habitat (because of the
absence of snowshoe hares) and no value as diurnal security habitat. It is unlikely that the
project components that are part of the Proposed Action would individually or collectively
result in an adverse effect to lynx based upon qualitative preliminary analysis. However,
some habitat conversion associated with the Proposed Action would involve spruce-fir forest
that still retains some snowshoe hare use. Such habitat still provides opportunistic foraging
values to transient and resident lynx in an LAU where foraging values have been appreciably
impaired by the MPB epidemic.
A Southern Rockies Lynx Management Direction (SRLMD) consistency analysis will be
conducted for the Proposed Action. Tentatively, the Proposed Action would not
meaningfully impair existing habitat connectivity across the ski area and would be consistent
with all applicable SRLMD. Employee and guest-related traffic contributions to regional
highways through lynx linkages used to access Keystone will be quantified to determine if
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the incremental contributions would be significant or insignificant and discountable relative
to adverse effects (increased highway mortality, traffic-impaired habitat connectivity and
permeability, reduced home range efficacy, and impaired recovery of the Southern Rockies
lynx population) of environmental baseline traffic volumes.
The big river fish issue revolves around whether the additional water depletions associated
with proposed snowmaking exceed limits authorized in prior Section 7 consultations. If they
do not exceed authorized limits, no additional Section 7 consultation on the four big river fish
would be required. However, if additional depletions exceed previously authorized limits,
Section 7 consultation would have to be reinitiated and that consultation would likely require
additional compensatory measures to avoid adverse effects.
Other federally-listed and proposed species will be evaluated, including Uncompahgre
fritillary butterfly (Boloria acrocnema), greenback cutthroat trout (Oncorhynchus clarkii
stomias), and others as appropriate.
Forest Service Region 2 Sensitive Species
Regarding R2 sensitive species, potential project effects will be evaluated on those animals
on current lists that could occur in the project area. Some R2 animal species and/or their
habitats are present in project component areas. Determination of potential project effects to
sensitive animals (including insects, fish, amphibians, reptiles, birds, and mammals) will
consider the area, configuration, and function of suitable and occupied habitat affected, home
range size and number of individuals affected, size, density, and location of the population,
and consequence of adverse effects on the species as a whole within the WRNF and within
its range.
Management Indicator Species
Regarding MIS, from the current list of Forest-wide MIS, elk (Cervus elaphus), aquatic
macroinvertebrates, and all trout will be evaluated in detail as project MIS, based on Forest
Plan selection criteria and the presence or potential occurrence of these organisms and their
habitats on NFS lands within or adjacent to the project area. Other MIS were not selected as
project MIS and will not be evaluated in detail because they do not occur on NFS lands in the
project area and they and their associated habitats on NFS lands would not be affected by the
Proposed Action.
Migratory Birds
Regarding migratory birds, the analysis will consider project effects to migratory bird species
that have been identified as candidates for conservation priority by at least one of the
following five lists: (1) the USFWS’s Birds of Conservation Concern list for the Southern
Rockies/Colorado Plateau Bird Conservation Region 16, (2) Colorado Partners in Flight Bird
Conservation Plan for the Southern Rocky Mountains Physiographic Area (Area 62), (3) the
Colorado State Threatened and Endangered list, (4) species designated as Sensitive by the
U.S. Forest Service Rocky Mountain Region, (5) species listed under the federal Endangered
Species Act, and (6) species designated as MIS on the WRNF.
Watershed
The Proposed Action includes components that could potentially affect stream and riparian
health in watersheds within the project area. Examples of these proposed projects include tree
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removal, terrain grading, and additional snowmaking coverage. Hydrologists conducted four
site visits in October 2011 to identify and observe key characteristics of the existing on-
mountain drainage infrastructure at Keystone (i.e. condition and adequacy of water bars,
road-side ditches, culverts, etc.) and areas where resource damage, such as ski trail erosion, is
occurring. The field investigation focused on the front side of Dercum Mountain. Field
observations were combined with extensive GPS data collected by Keystone staff into a
comprehensive GIS database. The GIS database, which also contains aerial photography,
topographic maps, and data developed by the Forest Service, will be utilized for hydrologic
modeling and to prepare a Mountain Drainage Study report in conjunction with (but not
necessarily related to) the EA. The report will include a comprehensive catalog of the on-
mountain drainage infrastructure classified based upon feature condition along with
recommendations for improvement of the existing drainage infrastructure. Such
improvements will help minimize surface erosion and decrease historic and future slope
stability problems on Dercum Mountain.
An assessment of potential effects to the watersheds that would result from implementation
of the Proposed Action will be conducted using the modeled hydrographs, results and
recommendations included in the Mountain Drainage Study, and stream health data
developed by the Forest Service. Among the identified drainage issues, surface erosion was
observed in the Area 51 terrain park and known slope stability issues were verified in the
lower section of Dercum Mountain (approximately below 9,950 feet). Site-specific PDC will
be developed to fully mitigate effects of the Proposed Action in compliance with the Forest
Service’s Watershed Conservation Practices Handbook. An analysis of cumulative effects
will also be conducted to assess the potential impacts of the Proposed Action as they are
added to, or interact with, the effects of other actions (past, present, and reasonably
foreseeable).
Finally, a soils survey of individual project areas would be completed prior to construction of
any authorized projects to ensure compliance with Forest Plan standards and guidelines for
the soils resource.
Wetlands
A delineation of waters of the United States, including wetlands, on Dercum Mountain was
completed during July and August 2010, using the delineation protocol provided in the 1987
U.S. Army Corps of Engineers Wetlands Delineation Manual and the 2008 Interim Regional
Supplement. Wetlands within the area exist under both normal (undisturbed) and atypical
(i.e. graded) situations according to the 1987 Manual. Delineated wetlands were classified
based on the Cowardin classification system that identifies wetlands primarily by dominant
plant community. Three types of wetlands were delineated: those dominated by herbaceous
plants (Palustrine Emergent), those dominated by shrub vegetation (Palustrine shrub/scrub)
and wetlands that are a mixture of the two plant communities (Palustrine Emergent/Palustrine
shrub/scrub).
A preliminary assessment of delineated wetlands and proposed project disturbance areas
revealed that most wetlands could be avoided through bridging wetlands crossed by
mountain bike trails and the new ski trails in the Family Adventure Zone, and minor
modifications to the alignment of snowmaking infrastructure. At this time, the only wetland
impact identified would occur to less than one acre on Wild Irishman for installation of
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snowmaking infrastructure. Where wetland impacts occur, mitigation for the disturbance
would be required.
Vegetation
Botanical survey work for the Proposed Action was completed in August of 2010 and
September of 2011. The botanical survey covered all federally listed Threatened and
Endangered plant species, Forest Service Region 2 listed Sensitive plant species, and plant
species of Local Concern for the WRNF.
All proposed improvement areas at Keystone were surveyed, including proposed ski trails,
snowmaking lines, grading, utilities, mountain bike trails and lift alignments. When potential
habitat for a listed plant species was found, the habitat was thoroughly reviewed. Focused
(intuitive controlled) survey methods were followed, with systematic surveys being
conducted at good quality potential habitat for a listed plant species. USFS Rare Plant
Species Field Survey forms and Rare Plant Species Element Occurrence forms were
completed.
No threatened, endangered plants or sensitive plant species were identified within the survey
areas, such that results were negative for all of these listed plant species. A total of eight
plant species of Local Concern listed by the WRNF were identified in the project area. The
following outlines the plant species of Local Concern found during the botanical survey
work:
1. Northern Twayblade Orchid, (Listera borialis)
2. Sphagnum, (Sphagnum platyphyllum)
3. Stiff Clubmoss, (Lycopodium annonitum)
4. Western moonwort, (Botrychium.hesperium)
5. Mingan moonwort (Botrychium minganense)
6. Pale moonwort (Botrychium pallidum or „redbank‟)
7. Reflected moonwort (Botrychium echo)
8. Common moonwort (Botrychium lunaria)
The species of Local Concern identified at Keystone were generally found in wetlands or on
existing ski trails, with the plant populations being located at sites scattered throughout the
SUP area. The Listera borealis and Sphagnum platyphyllum plant populations were found
growing in forested wetlands. The Botrychium (moonwort) species were growing on open ski
trails, along access roads and beneath chairlifts, as moonworts frequently colonize disturbed
areas such as developed ski trails and roadsides. GPS site location data was recorded for all
plant species of Local Concern identified during the botanical survey at Keystone.
Archaeological
Multiple archaeological surveys of Keystone’s SUP area have been completed in recent
years. No cultural or archaeological resources were found in areas in which development or
ground disturbance would take place under the Proposed Action. If undocumented historic
and/or prehistoric properties are located during ground disturbing activities or planning
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activities associated with approved construction activities, they will be treated as specified in
36 CFR 800.11 concerning Properties Discovered During Implementation of an Undertaking.
Comment Process
At this time, the Forest Service is combining the scoping process with the legal notice and
opportunity to comment, as described in 36 CFR 215.3. The public is encouraged to provide
substantive comments on this Proposed Action, including supporting reasons the responsible
official should consider in reaching a decision (36 CFR 215.6(a)(3). Substantive comments
are within the scope and specific to the project and have a direct relationship to the proposed
action. This will be your only time to submit formal written comments on this project.
Comments concerning this Proposed Action will be accepted for 30 calendar days following
the publication of a legal notice in the Glenwood Post Independent, on or about February 8,
2012. The regulations prohibit extending the length of the comment period.
Written comments must be submitted via mail, fax, or in person (Monday through Friday,
8:00 a.m. to 4:30 p.m., excluding holidays) to: Scott Fitzwilliams, Forest Supervisor, c/o
Shelly Grail Braudis, Snow Ranger, PO Box 620, Silverthorne, CO 80498. Electronic
comments including Word (.docx) or PDF attachments can be submitted to
https://cara.ecosystem-management.org/Public/CommentInput?Project=33608. The name
and mailing address of the person submitting electronic comments must be included.
It is the responsibility of persons providing comments to submit them by the close of the
comment period. Only those who submit timely comments will have eligibility to appeal the
subsequent decision under 36 CFR 215. Individuals and organizations wishing to be eligible
to appeal must meet the information requirements of 36 CFR 215.6. Names and contact
information submitted with comments will become part of the public record and may be
released under the Freedom of Information Act.
If the agency determines there are no significant impacts, that finding along with the EA and
a decision notice will be published. A 45-day appeal period would be provided after release
of the EA, finding of no significant impact, and decision notice. If the EA concludes there is
potential for significant impacts, then an environmental impact statement will need to be
prepared.
Additional information regarding this action can be obtained from Shelly Grail Braudis,
Snow Ranger at sgrail@fs.fed.us or by phone at 970-262-3484.
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status. (Not all
prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print,
audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil
Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an
equal opportunity provider and employer.
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