The public took full advantage of a second, extended comment period regarding the federally-mandated draft environmental assessment of Taos Ski Valley, Inc.'s "Gondola and other improvements" project, with a total of 619 comments submitted electronically to the Carson National Forest.
The vast majority of project comments were submitted after the original comment period ended on April 9. The final day for submitting comments to be considered as part of the project's National Environmental Policy Act (NEPA) review process, which Questa District Ranger Adam LaDell extended in response to a multitude of requests from the public, was Monday (May 22).
Many comments were critical of the decision to perform a less rigorous environmental assessment instead of a detailed environmental impact statement (EIS), and largely came from residents who live downstream from the ski resort in Valdez, Des Montes and San Cristobal. Environmental protection and conservation groups, members of the agricultural community, and some winter sports enthusiasts also submitted comments that criticized the decision. The last time an improvements project was proposed in the ski valley, an EIS was completed.
"The fact that this project was analyzed with an environmental assessment (EA), and that the EA analyzes only a single alternative — the Proposed Action — are two very big red flags that merit significant discussion," Hilary Eisen, policy director for Winter Wildlands Alliance, wrote in the Bozeman, Mont. group's May 17 comments. "With only one alternative, the EA doesn’t analyze the impacts of the proposed projects because it doesn’t compare the Proposed Action to anything else. Totaling a mere 59 pages, the EA is more focused on describing TSVI’s desired projects than on seriously considering the impacts of those projects on myriad natural resources or how TSVIs goals might be achieved through other means."
Another commenter, Sylvia Rodriguez, a commissioner on the Acequia de San Antonio in Valdez and professor emerita of anthropology at the University of New Mexico, questioned whether the geographic scope of the environmental assessment was sufficient. She argued that the "spectacularly deficient draft EA" should be tossed in favor of a "proper and full-scale environmental impact study."
Asked if it was usual for an environmental assessment to examine only one alternative, a spokesperson for the Carson National Forest told the Taos News that "no specific number of alternatives is required or prescribed; a stand-alone no-action alternative is not required. Existing conditions described in technical reports should provide the 'baseline' in question."
"The agency is preparing an environmental assessment for a proposed action because the significance of the effects is unknown or unlikely," the spokesperson added. "This helps direct the agency to either a finding of no significant impact or the need for an environmental impact statement.
"Once the analysis is complete, the responsible official will have more information to determine if an environmental impact statement is necessary," the spokesperson said.
Rodriguez asserted that the NEPA process "systematically and repeatedly fails to recognize and address questions of environmental justice in the Rio Hondo watershed."
"They do this first and foremost by excluding the traditional downstream acequia and land grant communities from their official definition of the watershed and impact zone as limited to the area lying between the mouth of Twining canyon and the alpine basin immediately surrounding the resort," Rodriguez said in her comments. "They do this also by failing to acknowledge and deal with downstream acequias and land grants as legal subdivisions of the state that should have been included as cooperating agents in the NEPA process from the start."
In overhauling President Trump's winnowed-down NEPA regulations, which were intended to speed up the environmental review process and dispense with red tape, President Biden issued new NEPA rules in May of last year that included environmental justice considerations.
The forest spokesperson told the Taos News that a subject matter expert was not available to respond by press time to Rodriguez's assertion regarding the geographic area studied in the environmental assessment. He also confirmed that ski valley project NEPA review "was initiated in April 2022 before the May 2022 guidance."
"However nothing about this project is meant to 'speed up the NEPA process,'" he added. "Since the 1970s, regulations have been in place to reduce paperwork and delays, and promote better decisions consistent with national policy."
The project proposes several resort improvements, as well as new infrastructure, within the ski valley's special use permit area on the Carson. Components include construction of a 7,300-foot-long gondola capable of moving 1,800 people per hour between the resort's main base and the Kachina base areas; the replacement of Lift 2 and Lift 8; creation of Nordic skiing and snowshoe trails; construction of a restaurant near the top of Lift 7; relocation and replacement of the Whistlestop Café; and construction of a hiking trail near Lift 4.
One commonly expressed criticism of the gondola proposal is that it may not provide an equitably accessible service to those seeking access to the Kachina Basin, where the Williams Lake Trailhead and several other popular recreation opportunities are located on public land adjacent to the Wheeler Peak Wilderness.
Representatives from the ski valley noted that the gondola is intended to reduce traffic along Twining Road, the hazardous steep dirt road that connects the resort's main basin and the center of the Village of Taos Ski Valley with the Kachina Basin. They say the gondola would also alleviate parking concerns.
"The idea is to take everybody out of their cars, off the road and put them in the gondola," Taos Ski Valley Inc. CEO Dave Norden said. "It'll be easy, fast, safe and take you eight minutes versus 15 or 20 minutes."
But will the gondola be free, like the road?
"We haven't determined exactly the operating parameters of it yet," Norden said. "Right now, we're in the environmental process."
The ski resort also proposes to install a 5-million-gallon water tank and booster station on the mountain for snowmaking purposes. The construction of the tank, which would be mostly underground and hold water equivalent to seven Olympic-size swimming pools, would be a major undertaking, but not an unheard of proposition. Ski Santa Fe installed one in 2020 to bolster its snowmaking capabilities.
"It's important to note that even with that storage, we will never take more than 200 acre-feet" of water to make snow, Norden told the Taos News, referring to the resort's current total annual water right.
A link to the virtual reading room for the Gondola and other improvements environmental assessment is posted on the Carson National Forest's project webpage: fs.usda.gov/project/?project=61390.
There is a method to evaluate the impact of any project affecting the water resources of the State of New Mexico. That method is to obtain baseline data of crucial chemical conditions, turbidity, and other physical properties of the water from the Taos Ski Valley down to the confluence of the the Rio Hondo and the Rio Grande, Stations can be established and samples taken to be sent to the Environmental Laboratory for analysis. At the same time water samples of all local wells can be taken to evaluate the nitrate levels throughout the valley to determine ground water degradation due to septic tanks. Ecoli can also be detected during this phase as well thereby providing safe drinking water protections to the public.
These regulations can be a double edged sword. There are plenty of projects that need done that get stuck in paperwork limbo. Some are literally decades sitting in red tape. Improvements can be stuck for years by frivolous lawsuits. Thousands of jobs get thrown away. There’s also the inverse, some things steamroll right through when we know it’ll hurt the land. But TSV is a different story. Taos has maintained its identity as unique forever. The ski valley is great, tons of people rely on it economically, but it’s a balancing act to use the area, provide recreation and work without destroying what makes it so great. There are plenty of other environmental experts, firms with no bias either way. If the first EA is deficient, great, USFS should accept the feedback and do it again with a new source. We absolutely cannot take this lightly. If it’s a good project, great. If not, we should know. Get a second opinion.
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