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TAKE ACTION: Protect old growth forests from the Waterville Valley Resort proposed expansion project!

The public has until August 27th to comment on the resort's proposal to construct new trails, glades, and ski lifts in rare old-growth forests and habitat for imperiled species. In total, the resort plans to double the size of the ski area in future years. Speak up now to help guide the US Forest Service and the Waterville Valley Resort to a better outcome for the White Mountain National Forest.


A photo and map of the proposed Waterville Valley Resort expansion project in the White Mountain National Forest, New Hampshire
The Waterville Valley Ski Resort has proposed to dramatically expand its footprint, threatening "old-growth" forests and important wildlife habitat located by forest ecologists throughout the expansion area. Take action by August 27th! Photo credit: Waterville Valley Resort Expansion Story Map (modified by Standing Trees).

Waterville Valley Resort, which operates under a special use permit in the White Mountain National Forest (WMNF), has proposed a major expansion of its ski terrain and lift system to "remain competitive," as stated in its project application to the US Forest Service. According to the Story Map developed for the project, the objectives of Waterville Valley Resort are to "connect the Resort and the Town of Waterville Valley amenities and increase the availability of terrain and services." These aren't inherently unreasonable objectives, but the resort and the Forest Service have arbitrarily decided that there is only one way to achieve them, even if the facts point to better solutions that have so far been rejected for further study. We wonder if this is because the real motivations for the project are a much larger (and hidden) proposal to essentially double the size of the ski area, as outlined in the resort's 2020 Master Development Plan.


Can Waterville Valley Resort meet its stated objectives without expanding beyond the present footprint of the ski area?


Absolutely.


Should New Hampshire's Waterville Valley Resort be able to cut down "old growth" forests for new lifts, trails, and glades, especially in the context of diminishing snowfall in the Northeast?

 

Absolutely not.


Please weigh in on the Waterville Valley Resort Expansion Project Draft Environmental Impact Statement (Expansion Project or Draft EIS) by the comment deadline, August 27th, to ensure that a sensible and legal solution is pursued that safeguards old-growth forests, habitat for imperiled species, and addresses the issues that the resort suggests are actually at the root of its management challenges. Below are instructions for how to comment, and some suggestions for what you might include. Want more background? We have debunked several of the resort's claims in the blog, below, so please keep reading!


TAKE ACTION:


Key details:



Please consider including the following points in your comment letter:

  1. Do you have personal experience with the community of Waterville Valley or the resort? Do you think this proposed expansion will lead to the purported benefits described in the Draft EIS? What is left out of the analysis? Please add your own personal commentary to strengthen your comment letter.

  2. Please tell the Forest Service to identify and protect all "old forest habitat" and "old-growth forest" as required by the Forest Plan.

  3. Please request additional alternatives that would:

    1. Address transportation issues without constructing a new ski lift or expanding the footprint of the resort, such as by expanding the existing shuttle bus system or considering a lift from the village of Waterville Valley to the existing base lodge;

    2. Improve terrain diversity only by constructing new ski glades or trails within the existing footprint of the resort;

  4. Please analyze the viability of the resort expansion, including predictions for reduced snowfall and reduced days for snowmaking, to ensure that the project will not become obsolete shortly after construction; a casualty of climate change. It is the Forest Service's responsibility to protect public resources from destructive and poorly-planned commercial development.

  5. The Expansion Project proposes gladed terrain that is not contained in the resort's 2020 Master Development Plan (MDP). In contrast, the MDP proposes hundreds of additional acres of trail and lift construction beyond what is acknowledged in the Draft EIS. The Forest Service must come clean with the public about the cumulative impacts that are likely to result from full buildout of the MDP, especially given the role that the new gondola will play in facilitating future ski resort expansion. The Forest Service cannot hide these anticipated future impacts to make the current expansion project appear smaller in scope and scale.


DETAILED ANALYSIS:


The Forest Service's and Waterville Valley Resort's claims don't add up


Waterville Valley Resort says its objectives are to "connect the Resort and the Town of Waterville Valley amenities and increase the availability of terrain and services." On their face, these objectives seem reasonable. But that's not the whole story. The Waterville Valley Resort Expansion Project (Expansion Project) makes several claims that just don't add up. Let's explore them in detail:


Claim 1:

This is the only expansion that we're planning...there's nothing else to see here!


This is only the beginning of the Waterville Valley Resort's expansion plans. The figure below, from resort's 2020 Master Development Plan, shows how the ski area could (at least) double in size in future years. Although the Expansion Project Draft EIS does not explicitly propose any development beyond Green Peak, the DEIS includes a significant amendment to the WMNF Forest Plan that would facilitate future "Alpine Ski Area Expansion" on what the resort calls "South Ridge" (see bottom left of figure, below), without actually completing any analysis of these future impacts, or anticipating how the new gondola and ski trails fit into that larger vision.


Strangely, even though the DEIS claims that the official "Purpose and Need" of the resort expansion is "to respond to an application and project proposal submitted by [Waterville Valley Resort]...to analyze projects from WVR's Forest Service -accepted MDP," the 2020 MDP does not mention or map out the glades that are now proposed for creation. Does this mean the glades will later be modified into traditional ski trails once the gondola is constructed? If Waterville Valley resort is proposing to deviate significantly from its approved MDP, why can't the Forest Service or the public propose additional alternatives for consideration that deviate from the MDP? Does the MDP need to be revised and re-approved before this project can move forward?


A map of Waterville Valley Resort's proposed buildout from its 2020 Master Development Plan
Waterville Valley Resort's 2020 Master Development Plan proposes to double the size of the resort across Green Peak and adjacent "South Ridge." The Draft EIS makes no mention of these additional plans, although the proposal would grease the skids for future development.

Claim 2: The only solution to traffic congestion is to build a new gondola

The project presents traffic congestion as one of the resort's biggest challenges, and then proposes a single solution (a new ski lift) that the Expansion Project's own engineers admit will only lead to more traffic. According to the Draft Environmental Impact Statement's Engineering and Traffic Technical Report, both proposed alternatives involve construction of a new gondola from the Waterville Valley Town Square to the top of Green Peak, and both alternatives are expected to create 25% more car traffic than present volumes, with the vast majority of skiers (80%) continuing to arrive at the resort by private vehicle, most of whom will continue to use existing parking facilities located at the existing base lodge. In our scoping comment letter, Standing Trees suggested that the Draft EIS should consider expanding shuttle bus services among other possible tools for easing traffic congestion, but none of these options were considered.


Does the new ski lift solve the resort's traffic problems? No. It makes them worse.


Claim 3: The only solution to increasing "terrain diversity" is to expand the resort by 250 acres, cutting intact, old-growth forests and jeopardizing high-quality habitat for imperiled wildlife

Waterville Valley Resort claims that it needs to expand its ski terrain (especially gladed areas for tree skiing), but refuses to look at options within the ski area's existing boundary. But is logging a relatively pristine forest the best (much less a legal) solution to achieve these goals for more terrain diversity?


The late successional and old growth forests on the southeast face of Green Peak, where new ski trails and lifts are proposed, provide habitat for the American marten, the endangered Northern Long-eared Bat, and Canada lynx, among other species. Despite this exceptionally rare habitat, the US Forest Service is proposing to allow the resort to clearcut new lift lines and traditional ski trails and conduct additional logging for gladed ski terrain, destroying the unique forest that exists in this location, today.


A map of Alternative 3 from the Waterville Valley Resort Expansion Project Draft Environmental Impact Statement or EIS
Alternative 3 (pictured above), is presented as a compromise, but it maintains most of the same impacts as Alternative 2, the Proposed Action. Note the "Inclusions of Isolated Older Trees" and "American Marten Denning Habitat," both of which would be impacted by trail and lift construction. The Forest Service has not reviewed any options to increase terrain diversity within the resort's existing footprint, or options for improving skier access that would reduce car-based transportation to the resort.

After Waterville Valley Resort completed its 2020 Master Development Plan, it hired a well-known contract ecologist to survey the landscape. In a 2022 report (beginning on p19 of the resort's expansion application to the Forest Service), the ecologist identified the presence of "old growth," "late successional," and "very mature" forests directly in the path of proposed ski trails and lift lines. Old-growth forests are estimated to exist across well under 1% of the White Mountain National Forest, so it is always notable when older forests are discovered. The ecologist recommended avoiding impacts to these areas because of their "scarcity," but the plan remains unchanged.


In an interesting twist, the 2022 report was updated again in 2023, with relatively few changes other than to remove the words "old-growth" in one location where it had appeared in a previous version of the report. Why make this change? Standing Trees has been locked in legal battles with the Forest Service over its failure to look for and protect rare pockets of older forests in recent logging projects. Did this contract ecologist use terms that made the Forest Service and the resort uncomfortable?

 

The 2005 WMNF management plan (or Forest Plan) is explicit about the importance of safeguarding rare older forests. The Forest Plan prohibits logging in “old growth forest” and in “old forest habitat.” Old forest habitat equates to “very mature” and “late successional” forest, terms used by the contracted ecologist. Old forest habitat includes areas where large-diameter trees, standing snags, canopy gaps, downed wood, multi-layered canopies, or other characteristics of older forests may be present, even if the stand has not yet crossed the threshold of “old growth” based on the Forest Plan’s definitions. Because the WMNF Forest Plan defines an old-growth forest as at least 10 acres in size, the Plan’s additional prohibition on logging in “old forest habitat” is a critical safety net for patches of older forest that are smaller than the 10-acre minimum threshold required by the Plan’s “old growth” definition.


Older forests, especially those that are free of roads and trails, aren't just rare and exceptionally beautiful, they are also workhorses for biodiversity, for clean water, and for our climate. They provide habitat for rare plants and imperiled species like American marten and the Northern Long-eared Bat. And they serve as sponges for precipitation, protecting downstream communities from extreme rain and drought that are becoming the new normal in northern New England.


The moral of the story is that the US Forest Service can't allow the resort to build a ski lift, ski trails, or glades through areas that are "old forest habitat" or "old-growth," both of which exist in relative abundance where this ski area expansion is planned. The resort must avoid these sensitive areas.


Claim 4: There will be enough snow to ski on...trust us!


Located entirely below 3,000 feet in elevation, with southeastern exposure, we wonder if there will even be sufficient snow to support skiing in this expanded terrain in future years. Recent scientific evidence indicates that snowfall will continue to diminish in the Northeast as winters grow warmer and rainier. New England ski resorts have already faced increasingly difficult conditions due to climate change. Across New Hampshire, average annual winter minimum temperatures have increased by 3.3ºC from 1971-2020. There has also been an increase in winter rain and ice events, which, even when they do not melt all the accumulated snow, result in icy conditions that aren’t favorable for skiing. Past years with warm temperatures and lost snowfall have cost NH ski resorts 17% of their visitation and nearly $55 million in revenue compared to higher-snowfall years.

 

In the coming decades, the climate impacts to New England ski resorts are expected to get much worse, making it difficult for resorts to stay in operation, let alone recoup the costs of a large investment like the Resort proposes. Climate scientists estimate that, by the end of the century, there will be a 50% decrease in natural snowfall across New England, coupled with warmer temperatures and more winter rain which will make the snow that does fall less likely to persist. This makes artificial snowmaking increasingly important for the Resort’s continued operation, raising questions about increased water consumption for snowmaking. Even with advances in snowmaking technology efficiency and the ability to make snow at warmer temperatures, only 29 of the 171 ski areas in Québec and the northeastern US are projected to remain viable (i.e., >100-day season length and open for Christmas–New Year holiday) by the end of the century under a higher-emissions scenario. With a 2ºC rise in temperature, Waterville Valley Resort is projected to lose 20% of its possible snowmaking days by the end of the century, while with a 4ºC rise, the Resort would lose 48.5% of snowmaking days.


Responding to concerns that Standing Trees' raised in our scoping comments, the Forest Service claims that "[t]he decision of whether to approve the proposed action is not based on climate projections or uncertain future snow cover conditions. Terrain viability is an operational decision and is outside the scope of this analysis; therefore, this issue was dismissed from further analysis in the EIS." We seriously question this rationale. It is the very uncertainty of "future snow cover conditions" that should give the Forest Service pause before approving actions that the Draft EIS describes as "irretrievable." You cannot "undo" ski trails, ski lifts, access roads, and restaurants with the push of a button. Existing old-growth forests that will be cut to make way for new infrastructure will not recover to anything resembling their current condition, even if the resort is eventually abandoned for lack of snow.


The Forest Service must make a decision with the public's best interests in mind, rather than merely serving the desires of Waterville Valley Resort.


Please weigh in through August 27th on the Draft Environmental Impact Statement.


Thanks for taking a stand for public lands!

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