Sunday, April 7, 2019



Issue 1: The village proposal expands impacts of the federally permitted ski area development
Issue 2: Judicial orders preclude reliance on FEIS
Issue 3: The Forest Service has never made Leavell-McCombs Joint Venture’s proposal (ANILCA alternative) available for review by the public or other local, State, and Federal agencies with jurisdiction and control over the Wolf Creek Ski Area complex 
Issue 4: The purpose and need and designation of the NEPA “Federal Action” are invalid
Issue 5: The FEIS perpetuates the same structural flaws addressed by the previous injunction and settlement
Issue 6: The range of alternatives considered is inappropriately narrow

Issue 7: Alternatives involving mitigation measures and ANILCA terms and conditions were not analyzed
Issue 8: The no-action alternative is inappropriately dismissed
Issue 9: The Forest Service failed to incorporate the input of several key cooperating agencies
Issue 10: ANILCA and existing Forest Service regulations do not require enhanced road access be provided to the federally encumbered Leavell-McCombs Joint Venture parcels
Issue 11: New information and stale (dated) analysis requires new NEPA process
Issue 12: ANILCA as preferred alternative is not compared to other alternatives
Issue 13: The consideration of connected actions and indirect and cumulative impacts in the DEIS is inadequate
Issue 14: The property appraisal confirms adequate access and comparable properties exist
Issue 15: The effects on wetlands are inadequately analyzed
Issue 16: The ANILCA alternative would lead to a loss of Canada lynx habitat and reduced functioning of an important Canada lynx linkage
Issue 17: The proposed decision would violate standards, guidelines, and objectives for lynx conservation
Issue 18: Spruce bark beetle impacts on lynx habitat requires additional analysis
Issue 19: The proposed conservation measures would not be effective in reducing impacts to lynx nor promoting recovery to a full, viable population
Issue 20: The Lynx Conservation Strategy was developed without any public involvement, in violation of NEPA
Issue 21: Application of any conservation measures is at best uncertain
Issue 22: The action alternatives would harm other wildlife
Issue 23: The action alternatives would reduce water quality
Issue 24: Lack of mitigation measures
Issue 25: Water supply for either action alternative may not be sufficient or reliable
Issue 26: In violation of NEPA, the FEIS fails to analyze the feasibility of, and the possible impacts from, a grade separated interchange at the village access road with Highway 160
Issue 27: The FEIS fails to analyze the comparative impacts of expanding federal control via the scenic easement
Issue 28: Failure to reinitiate consultation for the yellow-billed cuckoo pursuant to Section 7 of the Endangered Species Act
Issue 29: Bias and proponent control of the third party NEPA contractor was built into the contract
Issue 30: Failure to consider new information
Issue 31: Failure to consider the best available scienceIssue 32: Failure to adhere to NEPA’s public involvement mandates
Issue 33: Reasonable use and enjoyment that minimizes environmental effects requires an analysis of the visual effects to the congressionally designated Continental Divide National Scenic Trail

VWC-EIS, Objection Issues and Responses. 

November 15, 2018

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