Response to Comments June 10, 2013

Response to Comments June 10, 2013 SAWTOOTH NATIONAL FOREST KETCHUM RANGER DISTRICT BALD MOUNTAIN SUMMER TRAIL PROPOSAL 30-day Comment period: March 20, 2013 to April 18, 2013 Proposal On March 20, 2013, the Ketchum Ranger District, Sawtooth National Forest issued a Notice of Proposed Action requesting comments on a proposal by Sun Valley Company to construct or reconstruct 11 miles of summer, non-motorized trail on the National Forest portion of the Bald Mountain Ski Area to increase lift-assisted mountain biking recreational opportunities. Sun Valley Company is the holder of the ski area term permit authorizing use of National Forest and Bureau of Land Management (BLM) public lands on Bald Mountain. Public Involvement Sun Valley Company hosted a public meeting at River Run Lodge on May 24, 2012, to announce the proposal and answer questions about 19.57 miles of new summer trail designed for the Bald Mountain Ski Area. Approximately 90 people attended this public meeting. On October 17, 2012, The Forest Service and BLM issued a narrative description and map to the public seeking informal comments on the 19.57 miles of new trail in the proposal. Comments received were shared with Sun Valley Company to allow them the opportunity to modify their proposal based upon public concerns. On March 20, 2013, the Ketchum Ranger District, Sawtooth National Forest issued a Notice of Proposed Action requesting comments on the proposal to construct or reconstruct 11 miles of summer, non-motorized trail on the National Forest portion of the Bald Mountain Ski Area. A legal notice announcing the opening of a formal 30-day comment period was published in the Idaho Mountain Express on March 20, 2013. The 30-day comment period was open from March 20 through April 18, 2013. 43 comments were received by April 18th. These comments were cataloged as they arrived, and after the comment period closed they were reviewed for content. Individual comments were extracted and categorized. Four comments were received after April 18 th. One of these commenters also commented by April 18th, however the other three post-april 18th commenters are not eligible to appeal the Decision. Nonetheless, these late comments are considered and responded to below. All comment letters are included in the project record. What follows is a listing of the 20 main themes of issues identified by commenters. Under each theme, representative comments are summarized. Specific quotes from individual letters or e- mails that raised a given issue are noted. Many of the issues raised are interrelated, creating a high potential for redundancy in the responses. We endeavored to reduce repetition by crossreferencing responses where appropriate. 1

THEME 1 TRAIL USE OPPORTUNITY More novice- and intermediate-rated mountain bike trail riding opportunities, and more trail variety, are needed within the Bald Mountain Ski Area. 1.1 I am a strong supporter of expanding the Mountain Bike trails on Bald Mountain. We need more beginner and intermediate level trails on the mountain. Please approve the proposal to expand the current trails on Baldy. 1.2 I wanted to say that I enthusiastically support any and all trail development for hikers, bikers, and other recreational users on Bald Mountain. 1.3 I believe this would broaden the scope of trails for many of varying abilities. Letters Addressing Theme #1-1, 3, 4, 5, 6, 11, 12, 15, 20, 22, 23, 24, 26, 35, 36, 38, 39, 43. Response: Comment noted. THEME 2 COMMUNITY ASSET New trails on Bald Mountain would be a community asset. 2.1 I support developing new non-motorized mountain bike trails on baldy---they will be an asset for the community. 2.2 I live in Huntingdon, PA which has a large IMBA designed trail system near by (http://www.allegrippistrails.com ). The experience of having this network has been fabulous for the local community. It has helped bring in people from all over the country and has helped the local population have another outdoor exercise option. IMBA does a fabulous job with trail design and the Sun Valley system would benefit the larger community. 2.3 In addition to the economic value, biking also adds to the quality of life in the Wood River Valley, making it a fabulous place to live and visit. Letters Addressing Theme #2-2, 8, 9, 11, 17, 21, 23, 24, 25, 33, 35, 39. Response: Comments noted. THEME 3 ECONOMIC DEVELOPMENT New trails on Bald Mountain may aid the economic health of the Wood River Valley. 3.1 Economically this sort of offering is vital to the furthered growth of this area as a destination mountain bike community. 3.2 I know that more Oregon riders would be among the many who would travel to the area specifically to ride these trails and attend events that use them. I believe that planned trails like those in this proposal have low environmental impacts, help promote stewardship of the land parcels through personal interaction with the environment and that they can be a sustainable resource for economic development. 2

3.3 Summer recreation and mountain biking in particular have significant impact on our local economy. In 2011, mountain biking contributed over $33 million to our local economy during the riding season. Letters Addressing Theme #3-10, 11, 12, 13, 14, 15, 17, 20, 21, 24, 25, 27, 28, 29, 30, 31, 32, 38, 43. Response: comments noted. THEME 4 MOUNTAIN BIKER VS HORSE & RIDER CONFLICT The proposed Bald Mountain summer trails may affect horse and rider safety. 4.1 As a horseback rider I am very concerned about the proposed trail project and how it will effect horse and rider safety. Will these be multi-use trails? I am not necessarily wanting to share any new trails with bikes, just hoping that all the new bike traffic it will bring will not create more run-ins between bikes and horses due to the lack of education bikers may have regarding shared use trails. I prefer to avoid heavily biked trails in favor of those not so inviting to bikers, but the increase in bike numbers will create more potentially hazardous encounters as their numbers increase all over the mountain. Over the last few years I've seen an exponential increase of bikers ignorant to shared trail etiquette. Many ride as though they are on a downhill race course. They used to be a minority. Letters Addressing Theme #4-19 Response: The proposed new summer trails on Bald Mountain are not intended nor designed for stock use. Though not prohibited, there is little recent history of stock use on Bald Mountain because the heavy use by hikers and mountain bikers, lack of locations to water stock once on the mountain, and lack of facilities for stock users at the River Run and Warm Springs base areas do not create the recreation experience most stock users are seeking. Local horse riders have found better trail riding opportunities at other locations throughout the Wood River Valley. Neither the existing nor the proposed new trails on Bald Mountain connect directly to any other trail system in the Wood River Valley. Therefore, no additional conflict between stock riders and mountain bikers is expected due to construction of the proposed trails on Bald Mountain. THEME 5 UPHILL AND LOOP MOUNTAIN BIKING OPPORTUNITIES Uphill and loop mountain biking opportunities should remain on Bald Mountain. 5.1 An early concern was loss or lack of uphill and loop options. Maintaining Warm Springs, Cold Springs, and the development of Trail #1 for uphill travel from River Run side provide uphill and loop options. The addition of #9 adds a segment for climbing. We commend the effort to expand downhill and lift access riding opportunities, while not to the detriment of 3

uphill and loop options. We recommend expanding Trail #1 to the top or at least to Round House to increase the loop options and for the benefit of hikers. 5.2 However, the Proposal should also include egress to the top of Bald Mountain without using chair lifts. The chairlifts operate for only a short time during the long days of summer. Sometimes, there is lightning and the lifts shut down? what a bummer. In spring and fall the lifts don t run at all. Riding up a trail gives one time to stretch, breathe, and ponder. On top, there is time to rest, recover, and wonder what is over yonder? The ride downhill will be sweet; however, a good uphill cannot be beat. Letters Addressing Theme #5-21, 36 Response: Five options will be available for bikers looking to access the top of Bald Mountain without riding a lift: - Cold Springs -> Broadway Trail -> Trail #9 - Warm Springs -> Broadway Trail -> Trail #9 - Warm Springs -> Traverse Trail -> Bald Mountain Trail - Bald Mountain Trail - Trail #1 -> Traverse Trail -> Bald Mountain Trail Approval of the new trails proposal would increase mountain biking loop opportunities within the Bald Mountain Ski Area. THEME 6 PROPOSED TRAILS #1 AND #2 There is no discussion of proposed Trails #1 and #2 in the Forest Service Notice of Proposed Action (NOPA). 6.1 Your chart on page 2 does not include Trails #1 and #2, yet they are on the map. Can you provide info on their grade, width, etc.? Thanks. 6.2 Could you please update me on the proposal regarding trail #1 and #2. Specifically the Bald mtn trail and River Run trail. I see the proposed changes on the initial proposal but on the recent proposal there appears to be no discussion about them. Letters Addressing Theme #6-7, 16 Response: Trails #1 and #2 are not included in Table 1 of the NOPA because they are proposed on BLM lands, not National Forest lands. The BLM will undertake its own analysis of trails #1, 2, 3, & 5. The Forest Service s NOPA is for the trails or portion of trails proposed on National Forest Lands only. The map with all the proposed trails is included to provide a reference to the rest of Bald Mountain. An opportunity to comment on Trails #1 and #2 will be available when the BLM undertakes its analysis. 4

THEME 7 GETTING LESS ACCOMPLISHED BIKE RIDERS TO THE BOTTOM OF BALD MOUNTAIN How will riders of the new novice mountain bike trails constructed above the Roundhouse Restaurant get to the bottom of River Run if they don t want to ride intermediate-rated trails? 7.1 Another concern is situating beginner trails at the top of the mountain. This will encourage lift use, which can be economic motivation for Sun Valley Co. We understand the terrain at the bottom is steeper and perhaps less conducive for beginner trails and that Trail Solutions, Gravity Logic, and other professionals have put a lot of thought into the design; however, ideally there would be beginner options more accessible from the base. Please make it very clear to beginner riders that they must either download or ride intermediate or expert trails to get down. Will the lifts close at 4pm? Will summer trails staff leave at 4pm? We would like to avoid beginners feeling stuck at the top and unnecessary accidents. 7.2 A second concern is regarding the placement of the beginner trails at the top of the mountain. While this may be the most appropriate terrain for this level of riding experience there are concerns that novice riders will find themselves stranded at the top when lift service has stopped for the day. This could potentially place riders at risk if they are not capable of riding the advanced trails back to the base. Letters Addressing Theme #7-21, 36, 42 Response: According to independent feasibility studies by Whistler s Gravity Logic and the International Mountain Bike Association (IMBA Trail Solutions), the two largest mountain bike trail consulting and building firms in the world, a 3-5% novice trail is not feasible on the lower section of Bald Mountain due to terrain constraints and the existing service road infrastructure. Proposed novice trails on the upper portion of Bald Mountain will access the Roundhouse Restaurant area allowing less accomplished mountain bike riders the opportunity to download on the Roundhouse Express Gondola with their bikes rather than ride intermediate-rated trails to the bottom of River Run. Sun Valley Company will utilize signs and their staff to inform lift riders that those mountain bikers uncomfortable riding intermediate-rated trails to the bottom of Bald Mountain will need to ride down the Roundhouse Express Gondola prior to its daily closing. THEME 8 BIKER VS HIKER CONFLICT, SAFETY, EDUCATION, ETIQUETTE Trail use needs to be managed to avoid user conflict. 8.1 Minimizing user conflict is important to the Bike Coalition. Maintaining Bald Mountain Trail, Warm Springs, Cold Springs, and the addition of Trail #1 for foot traffic is prudent. 8.2 We also recommend adequate signage particularly for unidirectional and single use trails. An educational kiosk at the bottom is advisable. Sun Valley Co. is in great position to educate bikers and hikers of proper trail etiquette that could emulate throughout the valley. 5

8.3 I would also like to see the biking and hiking trails be separate to avoid any user conflicts and potential injuries. 8.4 Specific routes should be designed as up only routes to minimize the chance for collision and should be clearly designated with signage. Other signs should be mandated throughout the project area that indicates that off trail travel is prohibited. There are also opportunities to use this trail system for environmental education purposes and we encourage installing interpretation sites where suitable. Letters Addressing Theme #8-19, 21, 23, 41 Response: Sun Valley Company is the primary manager of summer trails and their use within the Bald Mountain Ski Area permit boundary. To provide their guests with enjoyable recreation experiences the Bald Mountain Trail Network will be appointed with a variety of enhanced wayfinding, waypoint, and viewpoint signage. In addition, a Bald Mountain Trail Network map will be published that references the proposed trail information and trail user etiquette. Unidirectional and user-specific trails will be signed accordingly so to prevent conflict between users and preserve safety. Sun Valley Company will provide a mountain bike safety patrol during hours of lift operation. One of the duties of this patrol will be to monitor trail user safety and educate trail users to avoid conflict and incidents. The Bald Mountain Trail will be maintained as the primary hiking trail from River Run to the Roundhouse Restaurant (via the Roundhouse Connector Trail) and the top of the ski area. Though open to uphill-only mountain biking, it receives infrequent uphill mountain bike use because other trails within the ski area boundary provide a more enjoyable uphill mountain bike riding experience for most bike riders leading to self-segregation of mountain bikers from hikers. THEME 9 TRAIL MAINTENANCE Maintenance of existing and proposed trails on Bald Mountain is necessary for providing both a quality user experience and environmental protection. 9.1 With the trail expansion, we would like to see a compensatory increase in summer maintenance and management on Baldy. 9.2 Proper trail maintenance is critical to prevent erosion over the long term. Road and trail maintenance associated with this project should use preventative erosion measures that discourage sedimentation release. In addition, an adequately protective monitoring program should be in place to detect trail maintenance requirements or modifications. Trails that are known to have erosion issues should be closed until the issue is resolved. 9.3 One major concern that applies to the entire project is the need for a maintenance plan. Lift serviced trails can be built to handle the volume and intensity of use they receive. However, to maintain the quality experience and ensure rider safety year after year there must be a maintenance plan in place. We recommend that the plan incorporate evaluation and maintenance standards to ensure that undue environmental impacts are avoided and that the trails continue to fulfill their intended purpose. 6

Letters Addressing Theme #9-21, 29, 41, 42 Response: Sun Valley Company is the primary manager of summer trails and their use within the Bald Mountain Ski Area permit boundary. To provide their guests with enjoyable recreation experiences and protect the large investment they have made in summer trails, Sun Valley Company has committed to employing a trail crew that will perform trail inspections, as well as active and ongoing maintenance throughout the lift-accessed bike season. As the trail network grows, the staffing of the trail crew will grow appropriately. Proper maintenance of facilities, including summer trails, is a condition of the ski area term permit issued to Sun Valley Company by the Forest Service and BLM. Both agencies will monitor that Sun Valley Company is complying with this condition of their permit. THEME 10 LIFT TICKET PRICING Summer lift tickets should be reasonably priced. 10.1 Because this design is largely geared towards lift access, we would like to know the lift pricing plan. Our request is that it does not become cost prohibitive for a lot of Wood River Valley riders. Letters Addressing Theme #10-21 Response: The Forest Service, through the ski area term permit, has the authority to check and regulate the adequacy and type of services provided to the public and to require that such services, such as lift ticket pricing, conform to satisfactory standards. However the permit holder (in this case Sun Valley Company) shall not be required to charge prices significantly different than those charged by comparable or competing enterprises. According to Sun Valley Company, their bike ticket rates are currently well below the national average for lift assisted mountain bike experiences. With future trail development, ticket and pass pricing will grow consistent with industry norms. THEME 11 WILDLIFE AND FISH New trails may impact big game species, fish, and hunting, fishing, and trapping opportunities. 11.1 Big game and forest grouse hunting are extremely popular activities that occur on an annual basis in and around the project area. In 2011 as an example, 1,518 hunters spent 6,413 days hunting mule deer during the archery and general any weapon hunts in Game Management 7

Unit 48. In the same year over 550 hunters spent 3,772 days hunting elk during the archery and controlled any weapon hunts in the same management unit. While we recognize not all of the hunting activity occurred within the project area boundary, it does demonstrate the popularity of the general area for hunting. Hunting combined with other fish and wildlife based recreation (fishing, trapping, and viewing) should be analyzed relative to the proposed action. 11.2 The project area provides calving and fawning habitat for mule deer and elk. We recommend the analysis include an evaluation of seasonal closures (mid-may through July 1) to protect big game during this important period. 11.3 Impacts to wildlife need to be avoided, minimized and mitigated. Letters Addressing Theme #11-34, 41 Response: Bald Mountain is a highly developed ski area with virtually year-round activity whether it is recreational use or Sun Valley Company and communication site construction, operations, or maintenance work. Hunting and trapping are not prohibited within the ski area boundary however the high level of other recreational activity, extensive infrastructure, and road closures to general public use do not make it a desirable place for most hunters to hunt or trappers to trap. Additional trails and trail use within the ski area boundary are not expected to have any detrimental effect on hunting or trapping opportunities in the remainder of Unit 48. The spring closure of the Warm Springs and Cold Springs Perimeter Trails until the last weekend in June annually will remain in effect to protect calving and fawning big game. There is no fish habitat within 3/4-mile of the trails proposed on National Forest lands, therefore no effects to fishing opportunities are expected from the project. THEME 12 EXISTING ROADS AND TRAILS Adding more trails will increase trail and road densities and have related effects to soil and wildlife resources on Bald Mountain. 12.1 The proposed development of 11 miles of new single-track trail represents a substantial increase in trail densities (and potential use) in an area already highly fragmented by roads and trails. 12.2 The proposal indicates 1.5 miles of existing trails would be redesigned under this proposal. We recommend the analysis include an evaluation of utilizing existing roads and trails to meet the purpose and need rather than constructing new trails. 12.3 Utilizing existing routes and concentrating the footprint of the proposed action will most effectively avoid and minimize both the short- and long-term effects to soil, water, vegetation, and fish and wildlife resources in the area. 12.4 We recommend the Forest Service using this opportunity to close and decommission any unauthorized roads and trails within the project area. 8

12.5 All trail construction needs to be administered using the network of existing access routes and no new roads should be constructed. Letters Addressing Theme #12-34, 41 Response: The Sawtooth National Forest Land and Resource Management Plan s Management Prescription Category (MPC) for the Bald Mountain Ski Area is 4.3, Concentrated Recreation. This category represents 1% of the National Forest lands within the plan s Management Area 4, Big Wood River. As stated in comment 12.3 above concentrating the footprint of the proposed action will most effectively avoid and minimize both the short- and long-term effects to soil, water, vegetation, and fish and wildlife resources in the area. This proposal will concentrate trail construction within an area already designated for high recreation use and minimize effects to natural resources compared to authorizing new trails in a more backcountry setting. More mountain bike use of the existing Bald Mountain summer service road system is not proposed because of safety concerns with mixing bicycle and authorized motor vehicle uses on relatively steep dirt roads within the ski area. Existing road and trails on Bald Mountain do not serve the purpose and need for this proposal because they do not provide the flow-style bike riding recreation experience Sun Valley Company wants to provide their guests. There are no unauthorized roads or trails on Bald Mountain to decommission. No new roads are proposed and none will be authorized by a decision on this proposal. THEME 13 THREATENED, ENDANGERED & SENSITIVE SPECIES New trails may impact threatened, endangered, and sensitive plant, animal, and fish species. 13.1 Forested habitats within the project area provide habitat for a variety of native wildlife species including Region 4 sensitive species like northern goshawk, boreal owl, and flammulated owl (also a species of greatest conservation need in Idaho). 13.2 The Forest Service needs to consult with the U.S. Fish and Wildlife Service and submit a Biological Assessment (BA) for ESA Threatened and Candidate species, U.S. Forest Service Sensitive, Indicator Species, migratory bird species and Idaho Department of Fish and Game big game species of concern that may be impacted by this project. Letters Addressing Theme #13-34, 41 Response: The Forest Service conducted a Biological Assessment and Evaluation (BA/BE) of the Effects of the Bald Mountain Summer Bike Trail Project on Fish, Wildlife, and Plant Species listed under the Endangered Species Act of 1973, as amend, and Region 4 sensitive species, and determined the bike trail project would not adversely affect, or have no effect on listed and candidate species under the Act including whitebark pine, wolverine, yellow-billed cuckoo, sage 9

grouse, and sensitive species including northern goshawk, boreal owl, flammulated owl. The U.S. Fish and Wildlife Service has concurred with this determination. THEME 14 RIPARIAN AREAS Bald Mountain riparian areas may be impacted by the new trails. 14.1 A map of the proposed project indicates portions of the trail system will be developed in close proximity to and necessitate the crossing of perennial and ephemeral springs and streams which are tributaries to Warm Springs and the Big Wood River. As noted in the Sawtooth Forest Plan (page III -146), soils in this management area have moderate to high surface erosion potential. Roads, dispersed and developed recreation, and livestock grazing are a few of the factors that are contributing to localized sediment impacts to subwatersheds within the management area (Forest Plan, page III-146). Further, riparian vegetation is functioning at risk in localized areas due to roads, developed and dispersed recreation, and grazing (Forest Plan, pages III-146 to III-148). We recommend the analysis specifically evaluate the proposed action relative to Soil, Water, Riparian, and Aquatic Resources Objectives 0438 and 0440 and Wildlife Resources Objective 0456. 14.2 It does not appear that Riparian Habitat Conservation Areas (RCA) are located within the project zone. If RCA are present, all construction and development in these areas should be avoided. No fuel or material staging should occur in RCAs or within topographic lows where water may concentrate during runoff. Letters Addressing Theme #14-34, 41 Response: According to the Final Environmental Impact Statement Sun Valley Resort (Bald Mountain) 2005 Master Plan Phase 1 Projects: No perennial stream channels reside within the Bald Mountain Special Use Permit (SUP) area, with the exception of two small springs in the Cold Springs Gulch drainage just south of the Roundhouse Restaurant. The two springs flow into a slightly defined channel with riparian and wetland species growing along the fringes. These springs comprise the only Forest Service identified Riparian Conservation Areas (RCAs) within the Bald Mountain SUP. Tributary to the Big Wood River, there are four topographically defined drainages: Cold Springs Gulch, the River Run drainage, the Frenchman s drainage, and the Warm Springs drainage. Field review of these drainages reveals that these topographic drainage-ways do not contain any defined channel with bed and bank, nor is riparian or wetland vegetation present. These areas may convey surface drainage during spring snowmelt, but they do not act as functioning riparian corridors. No new summer trails are proposed in the vicinity of the two springs in the Cold Springs Gulch drainage noted above, thus there will be no impacts to riparian resources on Forest Service- or BLM-managed public lands within the Bald Mountain SUP area from construction or use of new proposed summer trails. Therefore the proposal complies with Sawtooth Forest Plan Soil, Water, Riparian, and Aquatic Resources Objective 0440. 10

New trails will be constructed utilizing the Required Project Design Criteria and Best Management Practices for Bald Mountain (see Table 1). Retaining walls will be constructed where needed. Proposed flow trail design and construction, with frequent grade reversals and other constructed features, helps get water off trails quickly, before it develops the volume and velocity to create soil erosion. Therefore the proposal complies with Sawtooth Forest Plan Soil, Water, Riparian, and Aquatic Resources Objective 0438. Trails proposed on National Forest lands would be constructed above 7,000 feet. Therefore the proposal complies with Sawtooth Forest Plan Soil, Water, Riparian, and Aquatic Resources Objective 0456 because there will be no impact to lower elevation sagebrush habitat for deer, elk, migratory land birds, and sage grouse. THEME 15 PROPOSED TRAILS ARE TOO WIDE Proposed trail widths are excessive. 15.1 I want to ask you to deny the proposed trail construction project on Bald Mountain due to the excessive widths of the trails and also because the routes are through forest stands which would necessitate a lot of trees being cut. The mountain has already suffered excessive clear-cutting and while I support a tree thinning project I don't think cutting six to eight foot swaths through the woods is a good idea. If the trails were to be single track in width and would be routed more on existing ski runs then I think the project would be great. However, I do not like the idea of flow trails with all the contrived bank turns and humps and bumps. I don't think public land should be used in such a manner. 15.2 My understanding of the Forest Service is that multiple use of our lands is encouraged but that preservation of that land and forest is of primary concern. I think this project, as proposed, violates the principle of preservation. Letters Addressing Theme #15-37, 40 Response: Sun Valley Company has clarified that the trail and disturbance widths found in Table 1 of the Notice of Proposed Action are the maximum widths where banked turns and technical trail features are located. The average trail width between turns and features is expected to be 36 to 48 inches, comparable to the existing Forbidden Fruit and Punchline flow trails in other locations of the Wood River Valley. The new trails proposed on National Forest System lands may impact skiers in the winter, however Sun Valley Company has proposed their placement and technical features to minimize impacts to winter skiers & riders and snow grooming equipment. Existing summer trails underneath winter ski runs include the Warm Springs Perimeter Trail under the Lower Warm Springs, Greyhawk, Hemingway, and Cozy ski runs and the River Run Trail underneath the Canyon, Exhibition, and Lower Olympic ski runs. These existing summer trails have had no discernible effect on skiers, riders, or grooming equipment over the years, regardless of whether 11

the ski run has snowmaking on it or not, thus the new proposed summer bike trails are not expected to have a negative effect on winter users. Silvicultural prescriptions to improve forest health on Bald Mountain recommend healthy trees have their trunks separated between 15 and 25 feet apart, depending on the age and species composition of the stand, to reduce competition for sunlight, water, and soil nutrients. Proposed trails, even at locations where they are six to eight feet wide, would fit within the spacing recommended in the silvicultural prescriptions. The Sawtooth National Forest Land and Resource Management Plan assigns Visual Quality Objectives (VQO) to the National Forest landscape it manages. All projects shall be designed to meet the adopted VQO as displayed on the Forest VQO maps (Forest Plan Standard SCST01). The VQO for Bald Mountain is Modification. Under this visual quality objective management activities may visually dominate the original characteristic landscape. Activities which are predominately introduction of facilities, such as buildings, signs, roads, etc., should borrow naturally established form, line, color, and texture so completely and at such scale that its visual characteristics are compatible with the natural surroundings. The Forest Service conducted a Visual Evaluation for the Bald Mountain Bike Trails proposal. The evaluation determined that: Based on a comparison of the natural site characteristics, existing dominance elements, the physical proximity of forest users to the project area, Forest user viewer sensitivity, and the degree of landscape alteration created by the project proposal, this project if implemented as proposed will meet the adopted Sawtooth National Forest Land and Resource Management Plan Visual Quality Objective of Modification both individually as described above and, as a result, collectively as a project whole. On November 7, 2011, President Obama signed into law the Ski Area Recreational Opportunity Enhancement Act. This law clarified the authority of the Forest Service to allow approval of facilities for non-skiing snowsports and natural resource-based summer and year-round facilities and uses at ski areas permitted under the authority of the 1986 Ski Area Permit Act. The Act specifically identified four categories of facilities that may be approved in appropriate circumstances at ski areas operating on National Forest System lands. Approved categories include zip lines, ropes courses, mountain bike terrain parks and trails, and Frisbee golf. Use of the Bald Mountain Ski Area is permitted to Sun Valley Company under the1986 Ski Area Permit Act and the mountain bike trails proposed on Bald Mountain are one of the approved categories of facility authorized within ski areas under the Ski Area Recreational Opportunity Enhancement Act of 2011. THEME 16 SOIL EROSION Trail construction and use has the potential to increase soil erosion. 16.1 We are concerned about the potential for erosion both during the trail construction phases as well as during trail use, especially with trail number 5. 12

16.2 Proper trail maintenance is critical to prevent erosion over the long term. Road and trail maintenance associated with this project should use preventative erosion measures that discourage sedimentation release. In addition, an adequately protective monitoring program should be in place to detect trail maintenance requirements or modifications. 16.3 All trails need to be designed and constructed to prevent erosion. Letters Addressing Theme #16-41 Response: As stated in the Soils Report (Hardy, 2013) for this project, No impacts from eroded soils to result in sediment delivery to adjacent streams are expected. Based on the design and location of the proposed trails, none are located within RCAs (riparian conservation areas)." Any disturbances from trail construction would be considered temporary because design features specific to erosion control and rehabilitation activities would be implemented. Sun Valley Company has determined the 18% average grade listed for Trail Number 5 in Table 1 of the NOPA was incorrect. The designed average grade is actually 9% rather than 18%. New trails will be constructed utilizing the Required Project Design Criteria (PDC) and Best Management Practices (BMP) to control soil erosion on Bald Mountain (see Table 1). Retaining walls will be constructed where needed. Proposed flow trail design and construction, with frequent grade reversals and other constructed features, helps get water off trails quickly, before it develops the volume and velocity to create soil erosion. Sun Valley Company will employ a dedicated trail crew to perform daily trail inspections, as well as routine and non-routine trail maintenance. Sun Valley Company will be responsible for keeping trails closed until they are dry after spring run-off. The Forest Service will regularly monitor trail construction to assure compliance with PDCs and BMPs. The Forest Service will also monitor trail use after construction is completed to assure trails are appropriately closed or open based upon moisture conditions and are maintained to minimize soil erosion. THEME 17 NOXIOUS WEEDS Trail construction and use has the potential to spread noxious weed seed. 17.1 During construction and trail maintenance, the Forest Service should require that all equipment be cleaned before entering National Forest lands. All construction areas need to be stabilized to prevent erosion and expansion of noxious weeds. If not already implemented, a noxious weed plan should be in place. Work crews should be trained in noxious weed recognition and removal and should patrol the project area and road access ways for a distance of 100' on either side of the trails and roads and mechanically remove any weeds or microtrash. 17.2 The Forest Service should also consider requiring the operator to install a bicycle tire cleaning station with interpretive signage about the threats associated with noxious weed spread at the base of the trail system. 13

Letters Addressing Theme #17-41 Response: New trails will be constructed utilizing the Required Project Design Criteria and Best Management Practices to control noxious weed spread on Bald Mountain (see Table 1). Sun Valley Company has a weed washing station at their River Run Mountain Operations center and all vehicles and equipment, including those of third-party contractors and communication site permittees, are required to be washed prior to utilizing the Bald Mountain road system or beginning earth-disturbing projects on Bald Mountain. Sun Valley Company has a trained and licensed herbicide applicator on their mountain Department staff, and has an active noxious weed management program on Bald Mountain. Sun Valley Company s summer trail maintenance crew has been, and will continue to be, educated on noxious weed identification and trained to control noxious weeds they encounter of Bald Mountain. The Forest Service will encourage Sun Valley Company to investigate bicycle tire wash stations and purchase or construct them if they can be effectively utilized and efficiently maintained. We have been unable to locate any bicycle tire weed wash stations at trailheads in the Intermountain West. There is no manufacturer of commercial bike weed wash stations based on our research. Their acceptance by users, effectiveness at removing weed seed, ability to be readily constructed and maintained, and cost-effectiveness compared to actively patrolling for and controlling noxious weeds as Sun Valley Company current does has not been determined. The Forest Service will not require Sun Valley Company to invest in bike tire weed wash stations for Bald Mountain until the technology and efficacy of these stations is more mature. We agree education is important to control the spread of noxious weeds. The Forest Service will provide Sun Valley Company with noxious weed educational posters for placement on Sun Valley Company s trailhead kiosks. THEME 18 WATER QUALITY Water quality has the potential to be degraded by the project. 18.1 The Forest Service should take this opportunity to assess any chronic sources of pollutants within the project area. Common problem areas include parking lot facilities or roadways that run along water routes. 18.2 All fuel Storage must occur outside Riparian Conservation Areas (RCA) and at least 150 feet from live streams. Fuels that will be stored on the Forest during this project need to be properly contained and labeled. A hazardous material plan needs to be in place in the event of a fuel leak. Letters Addressing Theme #18-41 14

Response: Sun Valley Company complies with all Idaho Department of Environmental Quality regulations for fuel storage and wastewater treatment on National Forest lands within the Bald Mountain Ski Area. All Bald Mountain Ski Area parking lots are on private lands outside of Forest Service jurisdiction. All Bald Mountain service roads, trails, and cat tracks have been built and are maintained by Sun Valley Company to minimize erosion. Proposed flow trail design and construction, with frequent grade reversals and other constructed features, helps get water off trails quickly, before it develops the volume and velocity to create soil erosion. Sun Valley Company will employ a dedicated trail crew to perform routine trail inspections, as well as routine and non-routine trail maintenance. Sun Valley Company will be responsible for keeping trails closed until they are dry after spring run-off. The Forest Service will regularly monitor trail construction to assure compliance with PDCs and BMPs. The Forest Service will also monitor trail use after construction is completed to assure trails are appropriately closed or open based upon moisture conditions and are maintained to minimize soil erosion. No new summer trails are proposed in the vicinity of the two springs in the Cold Springs Gulch, thus there will be no fuel storage near riparian resources or within 150 feet of live streams on Forest Service lands within the Bald Mountain Ski Area. The Forest Service will monitor that fuels stored on the Forest during this project are properly contained and labeled, and that a hazmat spill response plan is in place and a spill containment and clean-up kit is at the work site. THEME 19 SANITATION AND WASTE DISPOSAL Restrooms and trash collection facilities need to be available to accommodate the expected increase of use on Bald Mountain. 19.1 Facilities should be open and able to accommodate the increase in user level. 19.2 Trash facilities should be provided. Letters Addressing Theme #19-41 Response: Sun Valley Company will have restroom and trash collection facilities available at the River Run Lodge, Roundhouse, and Lookout Restaurants when lifts are operating during the summer use season. Trash receptacles will continue to be found at the top and bottom of all operating lifts. THEME 20 CUMULATIVE IMPACTS The Forest Service should do a cumulative effects analysis and disclose past, present, and reasonably foreseeable future actions for this proposal. 15

20.1 We recommend the analysis include a drainage-wide cumulative effects analysis of direct and indirect effects of the proposed action together with the effects of other actions that have a cumulative effect on natural resources (e.g., big game parturition habitat, wildlife security habitat, soils, riparian vegetation, water quality, etc.). 20.2 The Forest Service must also analyze and disclose the direct and indirect cumulative effects of this project in conjunction will all past, present and reasonably foreseeable future actions, including additional projects in the area. Letters Addressing Theme #20-34, 41 Response: The Endangered Species Act (ESA) defines cumulative effects (50 CFR 402.2) as the additive effects of state and private activities that are reasonably certain to occur in the watershed where the Federal Action occurs. Under the ESA, an analysis of cumulative effects on ESA-listed species and their critical habitat is relevant only in determining whether the continued existence of a species would be jeopardized or whether critical habitat would be adversely modified or destroyed. No ESA-listed species would likely be adversely affected and critical habitat would not be affected by the proposed action, so a cumulative effects analysis under the ESA is not relevant. The National Environmental Policy Act (NEPA) defines cumulative effects as all past, present, and foreseeable future actions within the analysis area. The primary Federal activities that have impacted habitat within the analysis areas are past and current livestock grazing, past mining activities, dispersed recreation, and fire suppression. Since potential effects to habitat of Canada lynx, whitebark pine, spotted bat, Townsend s big-eared bat, boreal owl flammulated owl, blackbacked woodpecker, Lewis woodpecker, and fringed myotis could occur with proposed activities on Bald Mountain Ski Area, an incremental increase or continuance of cumulative effects to these species could also occur. The actions described in this document have and would contribute to cumulative effects of Regional Forester s Sensitive and Sawtooth National Forest Watch plant species. The definitive cumulative effects from the proposed action are unknown, but it is likely that associated ground disturbance, vegetation removal, potential for nonnative invasive plant species, and alterations to native plant community composition would add to cumulative effects for slender moonwort, least moonwort, Stanley thlaspi, least phacelia, obscure phacelia, bugleg haplopappus, and Marsh's bluegrass. Visual Cumulative Effects Cumulative effects consider the expected results of past, present, and foreseeable future developments. These effects may include timber harvest, roads, borrow pits, associated construction activities, as well as the existing effects of adjacent non-national Forest lands. The scale (spatial extent) from which to consider cumulative effects for the scenery resource can be represented as a viewshed, and specifically, the amount of land area that can be viewed at one time from a particular location. Also relevant in this measurement is whether or not the activity is viewed from a priority viewing area. Those land areas not viewed from priority viewing locations are classified as "not seen", for which the degree of visual alteration is permitted to be 16

greater. Cumulative effects continually change over time (temporal extent), and in general will ultimately represent the appearance of the desired condition as defined in the Forest Plan. The cumulative effects of past, present, and reasonably foreseeable effects of activities as it relates to the scenery resource is relative from the area viewed collectively at one time from any particular point along a primary travel route or use area. If the cumulative effects of activities are not viewed at the same time they can be considered as separate actions. Bald Mountain Forest 2012 Glading Plan The proposed Glading forest management project has some potential to open up lower elevation views towards the project area. Ample consideration of sensitive viewsheds should help guide forest vegetation management proposals associated with this project to ensure the viewsheds from the Warm Springs area are protected and that this project does not unintentionally develop undesirable views towards the trails development project that are currently well-screened. Past, Present, and Reasonably Foreseeable Future Actions Phases 2 and 3 of the 2005 Sun Valley Master Plan for Bald Mountain Sun Valley s Base Area Master Plan Past, present, and reasonably foreseeable actions that could cumulatively affect scenery resources at Bald Mountain are related to development of public and private lands dating back to the 1930 s. The ski area and base area have incrementally developed since 1939 as skiing has gained popularity and the residential and tourism population has grown in the American West. Historic development on NFS and BLM lands at Bald Mountain has involved clearing of trails, grading, and construction of lifts, roads, and buildings. Changes in vegetative patterns and developed facilities are visible from NFS and BLM lands within the permit area, and from the four critical viewpoints utilized in this analysis. From an aesthetic perspective, phases 2 and 3 of the Bald Mountain development plan have potential to add approximately 100 acres of ski terrain, with two additional lifts and replacement of existing lifts. In addition, base area development is proposed to take place on private lands at the base areas of Bald and Dollar Mountains. Timber removal associated with the Warm Springs Fuels Reduction Project, as well as communication sites on Baldy Mountain and Seattle Ridge is not visible from identified critical viewpoints. Soils Cumulative Effects Ground disturbance associated with the proposed construction of 11.0 miles of mountain bike trails will create roughly 11.6 acres of TSRC (total soil resource commitment). This will increase TSRC by 0.3% across the 3,332-acre Bald Mountain ski area. The minimal increase in TSRC would not adversely affect soil quality conditions and soil conditions would continue to support desirable levels of vegetation and soil cover. There will be additional, non-quantifiable acres of DD (detrimental soil disturbance) associated with work areas needed to facilitate new trail construction. These disturbances would be considered temporary because design features specific to erosion control and rehabilitation activities would be implemented. Overall, there would be some additional non-quantifiable cumulative impacts to soils resulting in a neutral cumulative effect. 17