Keystone Resort Dercum Mountain Improvements...

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.

Dercum Mountain Improvements at Keystone Resort Notice of Proposed Action

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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.


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.


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.


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.


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.


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.


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.

http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=33608


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Scenery

Issue: Proposed projects within Keystone’s developed lift and trail network may be visible from

identified critical viewpoints.


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.


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.


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.


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.


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 [email protected] 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.

https://cara.ecosystem-management.org/Public/CommentInput?Project=33608

mailto:[email protected]


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Keystone Resort Dercum Mountain Improvements...

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