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APPENDIX E
DEIS Comments
FINAL ENVIRONMENTAL IMPACT STATEMENT FOR ARIZONA SNOWBOWL FACILITIES IMPROVEMENTS PROPOSAL, COCONINO NATIONAL FOREST, SOUTHWEST REGIONS, 2005
Comments on the NEPA Draft EIS decision issued by Norma Rasure, Forest Supervisior, Coconino National Forest. The comments were received by the Forest Service in 2004. The Forest Service finalized the initial draft decision in 2005 even though it received the comments below.
This section of the Environmental Impact Statement for the Snowbowl records public comments received by a consortium of tribes and groups. These comments give a clearer view of the breadth of the expansion and its impacts. The majority of comments are critical of the Forest Services decision to approve the facilities expansion. The comments sometimes reference additional drafts and charts that are found in the full copy of the Draft EIS for the Arizona Snowbowl. Addressed to the Forest Supervisor, the comment section begins:
April 12, 2004
Nora B. Rasure
Forest Supervisor Coconino National Forest
Snowbowl DEIS Comments
2323 E. Greenlaw Ln.
Flagstaff, AZ86004
These comments express concerns and issues raised by the organizations and individuals signed below:
Roxanne George, Sierra Club
Klee Benally, Save the Peaks Coalition
Sharon Galbreath, Southwest Forest Alliance
Robert Tohe, Dine Bidziil Coalition
Jim McCarthy, Sierra Club Plateau Group-Grand Canyon Chapter
Andy Bessler, Sierra Club Environmental Justice Program
Carly Long, Flagstaff Activist Group
Kelly Burke, Grand Canyon Wildlands Council
Paul Torrence, PhD
Richard and Jean Wilson
Shonto Begay
Doug Brown
Michelle T. Harrington, Center for Biological Diversity
Comments on Draft Environmental Statement for Arizona Snowbowl Facilities Improvements
The Proposed Action as Displayed in the DEIS is a New and Significant Action. The DEIS inappropriately continues the assertion raised in the scoping document that most of the activities covered in the Proposed Action were approved within the 1979 FEIS and associated Record of Decision for the Arizona Snowbowl Ski Area Proposal. Projects not specifically identified in the 1979 Record of Decision are said "to
remain within the contextual scope of the 1979 approvals." However, the DEIS goes on to state the only the ski area size (777 acres), the skiable acreage and the comfortable carrying capacity of 2,825 are carried forward from the 1979 Record of Decision (ROD).
The DEIS does mention that any new decision will provide the framework for a new master development plan. The manner in which this issue is address makes it unclear to the public that this is a significant and new action.
As we stated in our scoping comments, the Arizona Snowbowl has essentially completed the site specific actions assessed in the 1979 FEIS. The new Sunset Lift called for in the Proposed Action is a completely different location, with a different set of impacts than the route originally proposed in the 1979 FEIS. The Logjam and Ridge Runs are significantly wider than was called for in the 1979 EIS. The Casino Run proposed in the 1979 FEIS actually became two runs and the Blackjack Run was not even in the FE IS. Subsequent to the 1979 FEIS, the Snowbowl built two lifts in Hart Prairie in slightly different locations than called for in the FEIS. The building of the new Humphrey's lift, realigning the two Hart Prairie lifts, building a new Sunset Lift and creating new runs are all new and significant actions.
The Forest Service correctly determined that any environmental analysis conducted for the 1979 ROD is out of date and inadequate by today's standards. According to the DEIS, "because of the length of time that has passed since the approval of the 1979 Master Plan, the advent of new procedural requirements, and potentially changed conditions, these approvals are no longer valid without additional site specific environmental analysis." (DE IS at 1-3) In the same paragraph, the Forest Service provides that the comfortable carrying capacity ("CCC") for the ski area of 2,825 - without any site specific environmental analysis - is being carried forward from the 1979 document. Given this decision, the Forest Service needs to explain why the carrying capacity and skiable acres are still valid since they were based on an analysis that is no longer viable. The fact that the 1979 decision was incorporated in the 1987 forest plan revisions does not allow the Forest Service to rely on an outdated analysis.
Purpose and Need For the Proposed Action
The Draft EIS notes that "The overall purpose and need for these projects responds to two broad categories: 1) to provide consistent/reliable operating season, and 2) to improve safety, skiing conditions, and recreational opportunities by bringing terrain and infrastructure into balance with existing demand." The analysis in the Draft EIS fails to
adequately present data supporting the purpose and need statements and to address shortcomings regarding both of the stated purposes.
The analysis in the DEIS does not clearly make a case for the proposed expansion of the ski area. On most days, the current carrying capacity of 1,880 skiers is not met. According to an unsupported assertion in the DEIS, "on days with good to excellent conditions, Snowbowl is typically used at or near its capacity." (DEIS at 3-79) It further appears that additional capacity is only needed to address peak days, generally less than 10 days per year.
Purpose #1: To ensure a consistent and reliable operating season, thereby maintaining the economic viability of the Snowbowl, and stabilizing employment levels and winter tourism within the local community.
One of the primary goals of the project is to be able to run Snowbowl into the month of March with man made snow. Warmer and dryer weather has been producing temperatures in Northern Arizona which are not conducive to snowmaking. Yet the DEIS does not provide any discussion or comments regarding weather and temperature patterns or forecasts. The effects of climate are routinely discussed in NEPA documents related to forest health, fire, cattle grazing and wildlife management.
The Draft EIS fails to address maximum temperatures under which snow can be made, the effects of climate change on more southern and lower elevation ski areas, and the Humphrey Pod's southwest aspect.
Climactic effects on Snowmaking
Snow can only be made below 28F without the use of additives, and only optimally below 25F. This begs the question, does the snowmaking plan entail the use of additives such as Snomax, which can impact water quality. Studies are very limited to this effect, but any effects analysis must disclose whether Snowbowl plans to use Snomax or some other coagulant additive, and identify any potential impacts including a review of the literature on the subject. The Draft EIS also fails to disclose any temperature data to determine when snow can actually be made. The analysis in the DEIS appears to have assumed that snow will be made all fall and into February.
The DEIS fails to consider the growing impacts of global warming and cycles of extended drought. Precipitation changes as a result of global warming are impossible to predict, but what is certain is that whatever amount of precipitation comes, more of it will come as rain, and for longer into the shoulder seasons. The DEIS fails to discuss this either as a direct influencing factor, or as a cumulative effect. See Mid-States Coalition v. Surface Transportation Board (www.ca8.uscourts.gov/opndir/03/10/021359P.pdf), where the Court accepted the Sierra Club's argument that the EIS for the proposed construction of a new rail line was deficient. The purpose of the rail line was to haul 100 million tons of coal per year 980 miles from Wyoming's Powder River Basin to Midwest electric plants. The court held that global warming and other atmospheric effects of all that coal burning was within the reasonably foreseeable, if indirect, impacts of the proposed rail line. The court's remand put this $2 Billion project on hold.
The DEIS, at page 3-139, notes regarding the proposed Humphrey's pod unfavorable southwest aspect, that "operations at other western ski areas - at similar elevations - has demonstrated that this can be effectively overcome through the installation of snowmaking infrastructure and through concerted effort in maintaining adequate coverage in this pod." The DE IS does not define what constitutes a concerted effort.
Meanwhile, the Draft EIS fails to identify what other ski areas they are referring to. While they purportedly consider other ski areas at "similar elevations", they fail to consider latitude - obviously critical in assessing the utility of snowmaking and ability to retain snow.
Finally, the Draft EIS, at page 3-139, regarding Humphrey's pod and its southwest aspect, notes that "ski trails have been specifically designed in a mosaic of open spaces with the intent of maximizing shading potential of the existing tree canopy. Through a combination of snowmaking, natural shading, and effective snow management, it is anticipated that the skiing terrain with the Humphrey's area would provide an acceptable skiing product throughout the majority of Snowbowl's operating season." The DE IS does not provide a definition of "effective snow management". The Humphrey's pod trails do not entail thinning or glading, as the Draft EIS, at page 2-8, notes that
" ... approximately 47.4 acres of tree thinning/glading would occur within the Agassiz and Sunset pods" (as opposed to Humphrey's pod). Observing Figure 2-2, it appears that no tree cover would be kept within these trails of between 200 and 400 feet in width. Subsequently, little of these trails will retain tree cover or shading, contradicting the Draft EIS's suggestion of "maximizing shading potential of the existing tree canopy".
Finally, should it rain, it matters little how much snow you've made. Ski areas in the eastern U.S. frequently "lose their snow" due to rain. More precipitation as rain, especially in the shoulder seasons, will surely undermine the intent of snowmaking making the ski area more consistently reliable. Yet the Draft EIS apparently fails to consider this, for instance by recording current weather trends and on what days of the year rainfall would significantly destroy the snow base that the proposed snowmaking would create.
Purpose #2: To improve safety, skiing conditions, and recreational opportunities, bringing terrain and infrastructure into balance with current use levels.
1. Bringing Terrain and Infrastructure Into Balance with Existing Demand
The Draft EIS, at page ES-4, states that "Currently, areas of intermediate and beginner terrain are inadequately sized to accommodate the public's demand for terrain of these ability levels on peak days" (emphasis added). This implies that the Forest Service is designing improvements for peak days, rather than the some percentile of peak day visitation, which is generally the ski area design standard.
The Draft EIS, at page ES-4, claims that "When compared to ski industry norms (and guest expectations), Snowbowl exhibits a deficit of intermediate and beginner level terrain and a surplus of novice terrain as shown in Table ES-1." Neither Forest Service nor ski industry design standards call for comparison with "ski industry norms". The Forest Service should be comparing terrain with the skill level of skiers that patronize
Snowbowl. It appears that no such information is presented in the Draft EIS. The Draft EIS fails to cite how "ski industry norms" were determined.
The Draft EIS breaks terrain ability levels down into six categories. This is beyond what is common in other ski areas in the Southern Rocky Mountains. Typically terrain is broken down into five categories, with four being more of the norm: beginner, intermediate, advanced, and expert. It is unclear from the DEIS how the Forest Service and Snowbowl differentiate between said categories. A more realistic assessment for instance would combine beginner and novice terrain simply under a "beginner" category, and then compare with Snowbowl skier ability levels rather than "industry norms".
Ultimately however, any claimed lack of skiing acreage is undermined by the conclusions in the Draft EIS itself. The Draft EIS fails to demonstrate any purpose or need for ski acreage expansion, but rather points to a lack of any such need. For instance, the Draft EIS, at page ES-5, notes that "The inadequate size and limited conditions of on-mountain facilities have resulted in a crowded, undesirable guest experience in many areas, such as in the lodges and on the chair lifts" (emphasis added). The Draft EIS further buttresses the fact that to improve the recreation experience, Snowbowl needs not additional skier acreage, but additional uphill lift capacity (high speed quad chairlifts replacing slower triple chairs for instance), and lodge capacity improvements. At page 3-125 for instance, the Draft EIS similarly notes that "CCC at Snowbowl is currently limited by uphill (i.e. lift) capacity of 1,880 guests and is ultimately limited by overall parking capacity."
Most notably, Table 3F-4: Terrain Density Analysis (Existing) (Draft EIS, page 3-128) notes tremendous acreage for target trail densities. For instance, Agassiz Top has an actual terrain density of 2 guests/acre, yet the target is 5.5 times that amount (11 guests per acre). In other words, the terrain can accommodate 11 skiers per acre, yet is only experiencing 2 skiers per acre. Similar conclusions are drawn for each of the other ski lift (pods) assessed. The Draft EIS, at page 3-128, acknowledges that "Snowbowl has very low terrain densities, and that the current lift capacity is insufficient to accommodate the existing terrain, resulting in underutilized terrain." Clearly, skiing acreage is no bottleneck to recreational quality at Snowbowl.
2. Visitation/Demand
According to the DEIS, "daily skier visitation is not proposed to increase as a result of the Proposed Action." (DEIS at 1-14) The impacts addressed in the DEIS appear to be based on the assumption of no growth in daily visitation. There does not, however, appear to be any basis for this assumption. Even according to the DEIS, "the frequency of ... peak days is anticipated to increase throughout Snowbowl's operating season." (DEIS at 3-44) Contrary to the prior assertion, this means that the Forest Service anticipates an increase in daily visitation. The Forest Service needs to provide a thorough analysis of the impacts of each of the alternatives in light of realistic projections of daily (not just annual) visitation. If there is no increase in daily visitation, there does not appear to be any need for this project. If there is an anticipated increase, the Forest Service needs to fully disclose, discuss, analyze and consider this issue.
According to the DEIS, the current eee for Snowbowl is 1,880 skiers. (DEIS at 2-1) Peak day visitation is in excess of 3,400 skiers. (DEIS at 2-2) Under the proposed alternative the eee would increase to 2,825 skiers. (DEIS at 2-5) Peak day visitation would continue to be in excess of 3,400 skiers. (DEIS at 2-5) There is, however, no reasoned analysis as to why the current eee of 1,880 skiers (and configuration at Snowbowl) is not adequate. Indeed, it appears that "Snowbowl is typically used at or near its capacity level [1,880] on days when there is good or excellent quality skiing." (DEIS at 3-79)
The data on visitation included in the DEIS is misleading. For example, the peak day
estimate of 3,400 skiers is based on "an analysis of the ten highest attendance days for each year between the 1992/93 and 2002/03 seasons." (DEIS at 3-38) For the 2002 season there were, however, only 2,850 total visits to Snowbowl. (DEIS at 3-40) Thus, it appears that the proposed expansion and construction of facilities are meant to handle crowds above the current eee for only a few days out of the year. If this is the case, the DEIS has not adequately justified the proposed expansion. An analysis of daily visitation rates is essential to informed decision-making, especially in light of the proposed Purpose and Need for the project. The DE IS, however, contains no analysis of daily visitation or whether or not this project is justified.
3. Scenic Sky Ride and Trail
The DEIS fails to address any environmental issues surrounding the building of a hiking trail from the top of the Agassiz lift to the midway area. The only analysis displayed in the DEIS relates to potential increases in summer time visitation as the result of a new hiking opportunity. The DEIS completely ignores normal trail construction issues related to soil disturbance, increased erosion potential, vegetation removal as well as human impacts related to garbage and human waste. Assessment of these potential impacts is even more critical in a situation where use is likely to be high because of easy uphill access via the skyride.
The DEIS provides no discussion of past impacts resulting from Forest Service attempts to accommodate this use. The Forest Service did try marking a trail from Agassiz to the upper portions of the Humphrey's Trail to prevent damage to the soil and the Senecio franciscanus, a threatened plant species. In spite of a marked trail and the full time presence of Forest Service employees, hikers wandered all over the sensitive habitat in the bowl area. This behavior resulted in the current prohibition of hiking down from the sky ride. In spite of increased recreation use in the area, the Forest Service has consistently failed to commit the resources necessary to manage the use of existing trail systems, let alone the manpower a new trail down Agassiz would require. The DEIS completely ignores the on-the-ground impact of this lack of resources and the likelihood of future funding.
The DEIS also ignores the fact that the proposed hiking trail is a road and access route for ATVs ... not a trail. The DEIS does not make a case for why summer maintenance that has been successfully conducted all of these years without ATV access suddenly requires a major action with significant on-the-ground effects.
4. Snowplay
As we stated in our scoping comments, we agree that there is a huge need for designated snowplay areas with safe parking. However, in our scoping comments we raised the issue of suitability of the Snowbowl as an appropriate location for such an activity. The DEIS failed to address the issue of suitability in terms of resulting impacts.
The DEIS notes that the proposed tubing facility is likely to attract a new market and will increase numbers in the permit boundary area well beyond the "proposed on mountain" carrying capacity of 2, 825. With this simple statement the Forest Service proposes to significantly increase the number and type of use occurring within the permit area boundary. There is no analysis in either the 1979 ROD or the current DEIS that adequately supports increasing the overall usage within the permit boundary area. The Forest Service failed to analyze the advisability of increasing use in area already plagued with traffic, parking, over crowding issues and public access issues. The proposed development of snowtubing facilities with a carrying capacity of "600 tubers- at-one-time", will actually translate into as many as 1680 guests on peak days. The DEIS does not address how the Forest Service will successfully manage this increase in use.
The only justification in the DEIS for creating this new attraction seems to be that it will meet an existing demand and make money for the Snowbowl. However, it is still unclear in the DEIS whether snowplay activities other than tubing for pay will be allowed in this area. The DEIS fails to address question regarding the overall use of the new parking area associated with the Snowtubing facility. If the Forest Service wishes to assert that this expansion is needed to satisfy public use, then the DEIS must specifically state how this new parking will provide access for people not wishing to pay to go tubing. Simply claiming that dispersed snowplay elsewhere will be reduced by this action does not translate into a cumulative effects analysis that shows how safety, sanitation, and vehicular and pedestrian congestion would be alleviated.
The on the ground impact of the proposed snow play area and associated parking will be substantial. This is a completely new use within the permit boundary and will cause significant soil disturbance on a currently undisturbed meadow. The DE IS does not display an analysis based on specifics of this disruption. The general discussion and tables of terrain to be graded by slope class, sediment detachment and Best Management Practices provide an initial layer of information related to potential impacts. Unfortunately, the DEIS does not go on to specifically discuss terrain changes necessary for the 7 acre tubing facility. The DEIS does not convey the depth of soil disturbance and potential changes in run off patterns due to slope changes, soil comp action and soil disturbance.
Issues and Indicators
Without explanation, the Forest Service classifies issues as: (1) significant issues that drive alternatives, require mitigation, or generally require in-depth analysis/disclosure; (2) tracking issues that do not necessarily drive alternatives or mitigation, but are tracked throughout the analysis with their effects disclosed; and (3) non-issues. (DEIS at 1-1) Deciding which issues are important is a significant aspect of the NEPA process. By simply identifying those issues that are not worthy of driving alternatives or mitigation, the Forest Service is subverting its obligations under NEPA. The determination of which issues will receive adequate consideration requires an adequate explanation and analysis, including public input.
As a practical matter, the Forest Service issue "classifications" in the DEIS are inconsistent and make no sense. For example, the DE IS identifies the social and economic effects on Flagstaff and Coconino County as a "tracking" issue. (DEIS at 1- 15) However, according to the Purpose and Need section of the DEIS, one of the primary justifications for the Project is to "increase local employment levels, and boost winter tourism within the community." (DEIS at 1-6, 1-5) The classification of an important element of the Purpose and Need for the Project as only a "tracking issue" is internally inconsistent. Recreational opportunities and experiences is classified as a "tracking issue" even though it is a primary element of the Purpose and Need for the Project.
The Forest Service also "classifies" impacts from, for example, (1) listing of the Peaks on the National Register of Historic Places; (2) increased noise; (3) traffic and access; (4) aesthetic impacts; (5) recreational opportunities and Experiences; (6) wilderness values; (7) ski area infrastructure and utilities; (8) watershed resources; (9) soils and geology; (10) vegetation; (11) wildlife; (12) geotechnical feasibility; and (13) air resources, as "tracking issues." (DEIS 1-13 to 1-22) These are, however, the very types of "direct," "indirect," and "cumulative" impacts that must be analyzed under NEPA - not merely "tracked."
Indeed, under "geotechnical analysis," the Forest Service identifies the need for a 10 million gallon impoundment to be constructed and maintained above the Sunset Chairlift. It not only defies common sense to classify this as a "tracking issue", it appears to be a "connected action" under NEPA that must be considered in the EIS. The construction identified under the heading of "ski area infrastructure and utilities," including but not limited to a 14 mile pipeline connecting the ski area to the City of Flagstaffs reclaimed water system, similarly appears to be a "connected action" under NEPA that must be considered and analyzed in the EIS. (DEIS at 1-17)
The items identified as "tracking issues" by the Forest Service, without further explanation, are important elements of the decision-making process that, under NEPA cannot be relegated to a second class status. The impacts of these issues warrant a thorough analysis, and mitigation when possible. Consideration of these impacts is also necessary to inform the Forest Service with regard to the range of reasonable alternatives that must be considered.
The Final Decision May Have Already Been Made. It appears that the only alternative acceptable to the applicant is one that includes snowmaking capabilities, i.e., Alternative 2. According to the Forest Service, "operations under Alternative 3 would continue to be heavily dependent upon natural snowfall. Correspondingly, skier visitation levels, and therefore revenues, are not anticipated to stabilize. As such, it is probable that the owners of the Snowbowl would be unable or unwilling to continue to infuse the recurring capital necessary to maintain the quality and service level currently offered, or to implement all of the projects included in Alternative 3." (DEIS at 2-17; 3-81; 3-84) Obviously, Alternative 1, the No Action Alternative, would not provide the applicant with snowmaking capabilities either. (DEIS at 3-102; 3-107)
The selection of Alternative 2 is arguably a forgone conclusion. If this is the case, the NEPA decision-making process is no more than an expensive facade and the Forest Service has failed to comply with both the letter and the spirit of the law. This analysis would also impact the alternatives that should have been considered - there is only one viable alternative considered in the DEIS.
Proposed Action: The Affect Environment and Environmental Consequences The Forest Service fails to take a "hard look" at the relevant scientific evidence underlying the assumptions in the DEIS. As a part of the scoping process, the Forest Service was made aware of a diversity of scientific studies related to the use of reclaimed waste water and associated hydrological issues that appear to contradict or undermine the assumptions make in the proposed action. Despite being brought to the Forest Service's attention, the DEIS does not analyze newer science or incorporate the new science into the DEIS's alternatives. Since scoping ended, Dr. Catherine Propper presented research to the City of Flagstaff raising numerous issues that should be addressed in the EIS.
NEPA requires the Forest Service to consider in an EIS process the available, relevant scientific evidence regarding the proposed action and associated analysis. The Forest Service must "insure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements," "identify any methodologies used," and "make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the statement"( 40 C.F.R 1502.24). In failing to consider the available, relevant scientific evidence concerning the potential impacts of using reclaimed waste water and associated hydrological issues at appropriate times in the NEPA process, the Forest Service breached its duty to use accurate scientific analysis in the DEIS. This must be remedied before a final decision is made.
A. Heritage and Cultural Resources and Environmental Justice
In addition to the discussion of environmental justice issues below, the DEIS fails to distinguish between the alternatives and to take a hard look at the differing heritage and cultural resource impacts of each.
In basic terms, the Forest Service appears to argue that no matter which alternative is selected, there will be comparable impacts on Native religious practices and beliefs, especially when considered with other past, present, and reasonably foreseeable future actions (DEIS at 3-18 to 3-27; DEIS at 3-28). "Under all alternatives, the spiritual and cultural values of the Peaks as they relate to the tribes would continue to be impacted and are perceived by many Tribal members as irretrievable for as long as the current and proposed facilities exist with the Snowbowl SU P area. With regard to Alternative 3, the Forest Service provides that "the issue of disturbance to the Peaks is essentially not one of how much land is disturbed, but that the land is disturbed at all. From the perspective of the Tribes, any additional disturbance to the landscape is adverse and would harm the spiritual nature of the Peaks ... " (DEIS at 3-21.)
With regard to the No Action Alternative, the Forest Service asserts that "while the No Action Alternative would not change the current configuration of the Snowbowl and would cause no additional ground or vegetation disturbance to the area, the Hopi Tribal Council and other tribes remain in opposition to the Snowbowl's continued presence on the sacred San Francisco peaks landscape because of the negative impact on the religious practices of their people." (DEIS at 3-19)
It is incorrect for the Forest Service to characterize the impacts of all three alternatives as if they are the same. Comments, letters, public statements and resolutions from tribal members and tribal governments have made it clear that the action alternatives pose a new and significant threat to the culture, religion and heritage of at least thirteen Native American tribes.
A. The Forest Service Has Failed to Meet Its Obligations to Address Environmental Justice Issues Under NEPA Executive Order 12898, CEQ Guidance and USDA Regulations.
Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," requires that "each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations." Exec. Order No. 12,898,59 Fed. Reg. 7629 (1994) (hereinafter cited as "E.O. 12898"). The Order states that it "shall apply equally to Native American programs" and specifically mandates that agencies shall take environmental justice concerns into account during the NEPA process. Id. at 7632.
The Council on Environmental Quality ('CEQ'), the Environmental Protection Agency ('EPA') and the United States Department of Agriculture ('USDA') have all provided guidance applicable to agency actions such as the proposed Snowbowl expansion. Council on Environmental Quality, Environmental Justice: Guidance Under the National
Environmental Policy Act (Dec. 10, 1997) (hereinafter cited as "CEO, E.J. Guidance"); U.S. Environmental Protection Agency, Final Guidance for Incorporating Environmental Justice Concerns in EPA's NEPA Compliance Analysis (April 1998) (hereinafter cited as "EPA, Guidance for E.J. in NEPA"); U.S. Department of Agriculture, Departmental Regulation: Environmental Justice (Dec. 15, 1997) (hereinafter cited as "USDA, EJ Reg"). The USDA's regulation is particularly applicable to Forest Service actions since the Forest Service is a division of that agency. The CEO's guidance specifically defines how potential disproportionate and adverse effects should be addressed during the NEPA process.
1. The Draft Environmental Impact Statement's Articulation and Analysis of Environmental Justice Issues Is Insufficient
The CEO guidance explicitly directs agencies, such as the Forest Service, with regard to properly conducting environmental justice analysis. "Agencies should integrate analyses of environmental justice concerns in an appropriate manner so as to be clear, concise and comprehensible within the general format suggested by 40 C.F.R. 1502.10." CEO, E.J. Guidance at 10 (emphasis added). The Forest Service's methodology for analyzing environmental justice within the Snowbowl DEIS is insufficient under this standard. The agency completely disconnects the environmental justice analysis from logically related and intertwined cultural heritage issues. It also fails to be sufficiently clear and comprehensible as required by CEO guidance.
a. The Environmental Justice Section is Neither Clear nor Comprehensible
The CEO guidance calls on the Forest Service to prepare environmental justice analysis, like all other NEPA analysis, in a manner that is "clear, concise and comprehensible." CEO, E.J. Guidance at 10. In this case, the Forest Service has certainly managed to render the environmental justice analysis concise, dedicating a mere five pages to these complex issues but, the analysis is anything but clear and comprehensible.
The first three pages of the "Environmental Justice" section are a cut and paste litany of environmental justice regulations. The listed regulations, however, are not well organized, well explained or well cited. For example, the last half of page 3-336 includes sections entitled "Human Health Effects" and "Environmental Effects" that define how the agency should determine whether those effects are disproportionately high. These sections, however, do not cite to any particular authority, leaving the reader confounded as to their relevance and weight. Furthermore, at no point during the regulatory recitation does the draft environmental impact statement ('DEIS') explain the particular applicability of the law to the Snowbowl action. This section is neither clear nor comprehensible.
The last part of the Environmental Justice section, "Existing Conditions," first gives a cursory description of population statistics. It then includes a subsection called "Tribal
Consultation" which lists contacts between government agents and Tribal members. Neither subsection contains any discussion of relevant legal standards, an explanation of its relationship to "existing conditions" or an analysis of its significance with regard to environmental justice issues. The third subsection, "Environmental Consequences," is even more baffling. The phrase "environmental consequences" and/or a definition for that phrase do not exist within the summary of applicable law, and the section itself gives no indication of its purpose. What the section does contain are the conclusions that "no environmental justice issues" and "no disproportionately high/adverse human health or environmental effects" have been identified. The section, however, fails to explain or analyze how such conclusions were reached, leaving it entirely unclear and incomprehensible.
By failing to articulate any part of the Environmental Justice section in a clear or comprehensible manner the Forest Service fails to meet its environmental justice obligations under NEPA.
b. The Forest Service's Choice to Disconnect the Analysis of "Environmental Justice" Issues from "Heritage and Cultural Resources" Issues Is Illogical and Ineffective
The CEO guidance emphasizes that "the attainment of environmental justice is wholly consistent with the purposes and policies of NEPA." CEO, E.J. Guidance at 7. It cites NEPA's commitments to provide "aesthetically and culturally pleasing surroundings" and "an environment which supports diversity and variety of individual choice" among others in support of the consistency between the two regimes. Id. (quoting 42 U.S.C.
4331 (b)(2), (b)(4)). It calls upon agencies to "integrate analyses of environmental justice concerns in an appropriate manner so as to be clear, concise and comprehensible within the general format suggested by 40 C.F.R. 1502.1 0." CEO,
E.J. Guidance at 10.
In the Snowbowl DEIS, the Forest Service disconnects and disengages its environmental justice analysis from the rest of the document. Instead of providing an "integrate[d] analysis," the Forest Service seems to have added a formulaic Environmental Justice section as an afterthought in a failed attempt to fulfill its NEPA requirements. This short and conclusory section, which is void of analysis as noted above, ignores at least 30 full pages of interrelated analysis in the Cultural Heritage section of the document. CEO guidance has underscored that Environmental Justice in the NEPA context should include these kinds of social and/or cultural issues. The only connecting reference is a stand alone sentence at the end of each "Environmental Consequences" subsection on page 3-339 that refers the reader to "Chapter 3, Section A discussion of direct, indirect and cumulative effects to cultural values" without any indication of how such discussion is related or meaningful. The Forest Service has placed the two sections at opposite ends of the document, without any linking analysis, instead of taking a holistic approach that builds off of the inextricably intertwined nature of the Cultural Heritage and Environmental Justice issues in this case.
By failing to integrate environmental justice analysis into the NEPA document in a meaningful way, the Forest Service fails to meet its environmental justice obligations under NEPA.
2. The DEIS's Conclusion That No Disproportionately High/Adverse Effects on Native American Populations Have Been Identified Is Arbitrary and Capricious.
On page 3-339, the DEIS finds with respect to all three proposed alternatives that "no disproportionately high/adverse human health or environmental effects" on the Native American communities who live near San Francisco Peaks exist or have been identified. The Forest Service makes this erroneous finding by omitting the explicit language of relevant guidance documents and E.O. 12898 that mandate the consideration of social and cultural impacts, and by completely failing to consider the profound cultural and social impacts that the Snowbowl expansion will have on affected Native American communities.
a. The Forest Service misquotes CEO's definition of "disproportionately high and adverse environmental effects" in an effort to avoid a finding that such effects will occur under the proposed alternatives.
As mentioned above, the DEIS's finding that "no disproportionately high/adverse human health or environmental effects" exist includes no analysis and no citation to a particular authority. The reader is forced to conclude, however, that the finding is based, at least in part, if not entirely, on the definitions provided on page 3-336, since it is the only other place that a definition for "disproportionately high and adverse" effects appears within the DEIS. Although the definitions on 3-336 also fail to include citations, they are likely intended to reference the CEO's guidance because the definitions are included in a part generally describing the CEO's guidance, and because all three paragraphs of both definitions track the guidance language almost identically.
The Forest Service, however, misquotes this definition to avoid finding that environmental effects on affected Native American communities are, in fact, disproportionately high and adverse. In discussing the requirements under CEO's guidance for environmental justice analysis under NEPA on p. 3-336, the DEIS states that:
"When determining whether environmental effects are disproportionately high and adverse, agencies are to consider the following three factors to the extent practicable:
Whether this is or will be an impact on the natural or physical environment that significantly and adversely affects a minority population, low- income population, or Native Americans.
2. Whether environmental effects are significant and are or may be having an adverse impact on minority populations, low-income populations, or Native Americans that appreciably exceeds or is likely to appreciably exceed those on the general population or other appropriate comparison group.
3. Whether the environmental effects occur or would occur in minority population, low-income population, or Native Americans affected by cumulative or multiple adverse exposures from environmental hazards."
This language (without an attributing citation) almost identically tracks the wording of the CEO's guidance, except that the DEIS deletes passages which are germane to the finding of a "disproportionately high/adverse human health or environmental effects" on the Native American communities. In the CEO guidance, the "disproportionately high and adverse environmental effects" are defined as follows:
"When determining whether environmental effects are disproportionately high and adverse, agencies are to consider the following three factors to the extent practicable:
1. Whether there is or will be an impact on the natural or physical environment that significantly (as employed by NEPA) and adversely affects a minority population, low-income population, or Indian Tribe. Such effects may include ecological, cultural, human health, economic, or social impacts on minority communities, low-income communities, or Indian tribes when those impacts are interrelated to impacts on the natural or physical environment, and
2. Whether environmental effects are significant (as employed by NEPA) and are or may be having an adverse impact on minority populations, low-income populations, or Indian Tribes that appreciably exceeds or is likely to appreciably exceed those on the general population or other appropriate comparison group; and
3. Whether the environmental effects occur or would occur in minority population, low-income population, or Native Americans affected by cumulative or multiple adverse exposures from environmental hazards." CEO, E.J. Guidance at 26 (emphasis added).
The DEIS inexplicably eliminates the language in the definition that details exactly what types of effects should be considered when analyzing environmental effects. This language would certainly be important in any environmental justice analysis, but is particularly essential in this case given that the deleted passage explicitly brings "cultural" and "social" impacts under the umbrella of environmental effects that the agency must consider as it determines whether those effects are "disproportionately high." In this case, the cultural and social impacts are the main and essential impacts that the affected Native American communities will suffer, so whether or not they are included in this case is a determinative factor in the Forest Service's ultimate finding. The Forest Service's elimination of the portion that would fundamentally change its analysis in this case is careless at best and deceptive at worst. The Forest Service cannot reasonably come to the conclusion that "no disproportionately high/adverse human health or environmental effects" exist when it has failed to document any consideration of the social and cultural effects that the Native American communities have suffered.
b. The DEIS Fails to Include Language From the CEO Environmental Justice Guidance That Require that Cultural and Social Effects Must be Considered Under NEPA
Aside from the glaring omission noted above, the DEIS also fails to include or consider other language from the CEO guidance that requires the consideration of cultural and/or social impacts on Native American communities. The CEO is, however, replete with such references:
"Environmental justice issues encompass a broad range of impacts covered by NEPA, including impacts on the natural or physical environment and interrelated social, cultural and economic effects. In preparing an EIS or an EA, agencies must consider both impacts on the natural or physical environment and related social, cultural, and economic impacts. Environmental justice concerns may arise from impacts on the natural and physical environment, such as human health or ecological impacts on minority populations, low-income populations, and Indian tribes or from related social or economic impacts." CEO, E.J. Guidance at 8 (emphasis added).
Footnote 23, cited in the above passage, reads, "The CEO implementing regulations define 'effects' or 'impacts' to include "ecological. .. aesthetic, historic, cultural, economic, social or health, whether direct, indirect or cumulative.' CEO, E.J. Guidance at 8, n. 23 (quoting 40 C.F.R. 1508.8) (emphasis added).
CEO is explicit and detailed in describing the Executive Order's expectation that agencies include social and cultural impacts in an environmental justice analysis. Moreover, because the guidance has used the imperative "must consider" as part of its language, this expectation is not merely a request but a demand. Under the guidance, an agency is given no discretion as to whether or not it may consider social and cultural effects, but is required to do so when making a determination of whether those effects are disproportionately high and adverse. Furthermore, footnote 23, clearly links the CEO implementing regulations to the environmental justice analysis. Again, this highlights that the Environmental Justice and Cultural Heritage analyses need to be linked by more than just the bald cross-reference provided on p. 3-339. By ignoring this imperative the Forest Service fails its obligations under NEPA. By failing to include this explicit language the Forest Service also fails to follow through on the analysis that the language explicitly demands.
The CEO guidance also includes at least two other references to the importance of social and cultural values in an environmental justice analysis.
"Agencies should recognize the interrelated cultural, social, occupations, historical, or economic factors that may amplify the natural and physical environmental effects of the proposed agency action. These factors should include the physical sensitivity of the community or population to particular impacts; the effect of any disruption on the community structure associated with the proposed action; and the nature and degree of impact on the physical and social structure of the community." CEO, E.J. Guidance at 9 (emphasis added).
"Agencies should recognize that the impacts within minority populations, low income populations, or Indian tribes may be different from impacts on the general population due to a community's distinct cultural practices." Id. at 14 (emphasis added).
The DEIS fails to make any mention of this language included within the CEO guidance. The Forest Service makes no indication that it has "recognized the interrelated cultural, social" or other factors that may "amplify" the natural and physical environmental effects that the Snowbowl expansion may have. It does not analyze within the environmental justice context how the snowmaking, the scarring of landscape or the increases in human traffic may "disrupt the community structure" of Native Americans groups whose fundamental spiritual identity may be profoundly effected by the Snowbowl project. Furthermore, the DEIS makes no mention, within the environmental justice context, of how each community's "distinct cultural practices" may be particularly effected. By ignoring these issues the Forest Service fails its obligations under NEPA guidance. By failing to include this explicit language the Forest Service also fails to follow through on the analysis that the language explicitly demands.
c. The DEIS Fails to Apply Its Own Guidance Document That Requires that Cultural and Social Effects Must be Considered Under NEPA
Along with the conclusory finding that "no disproportionately high/adverse human health or environmental effects" exist in this case, the DEIS also states on p. 3-339 in the "Environmental Consequences" subsection that "no environmental justice issues have been identified ... as per USDA Departmental Regulations #5600-2". USDA guidance is particularly applicable in this case, because the Forest Service, as a USDA unit, must pay particular attention to its own agency's regulations. This conclusion in the Environmental Consequences subsection does not provide a citation for the particular part of the regulation on which it relies.
In the earlier subsection of the Environmental Justice section entitled "U.S. Department of Agriculture Departmental Regulations," the DE IS provides a general overview of Reg. #5600-2, quoting impotent language from the "Goals" section of the regulations. The DEIS fails, however, to quote any passages from the sections on scope, definitions, implementation policy or the discussion of NEPA, all seemingly important and applicable considerations for an agency attempting to determine exactly how those regulations should be applied. Again, the Forest Service culls only language that does not mention the necessity of including social and cultural impacts.
However, like CEO guidance, Reg. #5600-2 explicitly includes social effects within the definition of environmental effects. In the definitions section it says:
"ENVIRONMENTAL JUSTICE means that, to the greatest extent practicable and permitted by law, all populations are provided the opportunity to comment before decisions are rendered on, are allowed to share in the benefits of, are not excluded from, and are not affected in disproportionately high and adverse manner by, government programs and activities affecting human health or the environment." ....
"HUMAN HEALTH AND/OR ENVIRONMENTAL EFFECTS as used in this Departmental Regulation includes interrelated social and economic effects." USDA, EJ Reg. at 3 (emphasis added).
Also, in its discussion of how the regulations fit within the scope of NEPA, Reg. #5600-2, states:
"E.O. 12898 requires that in complying with NEPA agencies shall-
(1) Analyze the environmental effects of proposed Federal actions, including
human health, economic, and social effects on minority and low-income populations.
(4) When reviewing NEPA documents, ensure that the agency preparing the
NEPA analysis and documentation has appropriately analyzed environmental effects on minority and low-income populations, including human health, social and economic effects." USDA, EJ Reg. at 6 (emphasis added).
Appendix E of the regulations further "illustrates how environmental justice considerations can be integrated into the steps of the NEPA process." Id.
Like the CEQ guidance, Reg #5600-2 explicitly includes social effects as an important environmental justice consideration. The policy makers at USDA wisely built off of the CEQ guidance, employing language that is widely used among federal agency guidance documents to insure consistency among its programs. The Forest Service has no latitude to ignore such explicit agency language. Again, the Forest Service's omission of language that includes social effects is irresponsible at the least and suspect at worst. By ignoring this language the Forest Service fails its obligations under USDA regulation #5600-2. And, by failing to include interrelated social effects in its consideration, the Forest Service fails to follow through on the analysis that the regulation demands.
d. The DEIS Fails to Include Language From the Executive Order 12898 Memo That Requires Cultural and Social Effects to Be Considered Under NEPA
The Memo accompanying Executive Order 12898, states that when doing a NEPA analysis "Each Federal agency shall analyze the environmental effects, including human health, economic and social effects on minority communities and low-income communities." Memorandum for the Heads of All Departments and Agencies:
Executive Order on Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, 30 Weekly Compo Pres. Doc 279,280 (Feb.
11 1994) (hereinafter E.O. Memo). This Memo was created by the Executive for the express purpose of spelling out to government agencies what was expected of them. The Forest Service's failure to undertake any analysis of cultural and social effects is therefore a direct breach of the Order itself.
e. The Social and Cultural Effects on the Affected Native American Communities are Disproportionately High and Adverse
The failure of the Forest Service to conduct an adequate environmental justice analysis regarding impacts of the Snowbowl expansion is not a harmless error, because an analysis that includes social and cultural impacts would certainly render a different conclusion. In this case, the Proposed Actions would have adverse impacts to the central social and traditional cultures of the thirteen tribes recognized by the Coconino National Forest. These comments do not endeavor to conduct the complete analysis of social and cultural impacts, since that is the duty of the Forest Service, but does highlight a few obvious social and cultural impacts that should provide a minimum basis for consideration.
i. The installation and operation of snowmaking infrastructure as described in the Proposed Action, and the use of reclaimed wastewater as a water source, will impact cultural and spiritual values and practices associated with the San Francisco Peaks.
The DE IS acknowledges on p. 3-28 the importance of the San Francisco Peaks to thirteen Native American tribes and admits of snowmaking that "based on the belief systems of many of the tribes we must consider at least a portion of these impacts as a potentially irreversible impact to these tribes' religions." Tribal spiritual leaders have indicated that the use of reclaimed water, including water used to wash corpses at local mortuaries, will bring irreparable disruption to their traditional culture. DE IS 3-16. Similar concerns exist regarding reclaimed water that contains sewage remnants, albeit treated and screened three times, that would break certain cultural taboos in some tribes. Id. Tribal members are concerned that reclaimed water will contain contaminants to medicinal plants thus interrupting their ability to gather ceremonial or domestic plants for use. Tribal members are concerned that allowing snowmaking with reclaimed water will cause less snow to fall on the Peaks in years to come.
Therefore, the Forest Service's environmental justice analysis must, at a minimum consider the serious impacts of snow-making on affected Native American communities.
ii. The alterations to the landscape as described in the Proposed Action will impact cultural and spiritual values and practices associated with the San Francisco Peaks.
The DEIS notes on p 3-7 that "The concept of landscape should be considered when discussing Native American relationships to the land." "Many groups consider the
landscape to be part of a living cultural system, which encompasses both the people and the land together." DEIS p. 3-7. The issue is clearly not about access to particular sites but about the effects of alterations to the natural landscape. Any development that affects the Peaks natural environment damages the "continuing cultural identity" of the region's Native American tribes.
Therefore, the Forest Service's environmental justice analysis must, at a minimum consider the serious impacts of altering the landscape on affected Native American communities.
3. The Forest Service Has Failed to Meet Its Obligations Under Environmental Justice Regulations and Guidance Documents to Effectively Communicate with Native American Communities.
Logically, the more input and information an agency seeks and receives from affected communities, the more informed and effective that agency's environmental justice analysis with regard to a proposed action will be. In the case of the Snowbowl expansion NEPA process thus far, the Forest Service has sought very little input from affected Native American communities.
As noted above, the Environmental Justice section within the DEIS is cursory and makes hardly any mention of community input within what little analysis it does provide. Furthermore, the Cultural Heritage analysis of Section A is based almost entirely on studies and documents produced by scholars of Native American culture and spirituality. While such materials can provide supportive factual data, they cannot replace the invaluable first hand input available from community members themselves. Environmental justice requires that agencies go above and beyond the 'normal' course of business to receive such input. Here, the Forest Service has failed to do so.
a. The Forest Service Failed to Conduct Adequate Outreach
Both the Environmental Justice and Cultural Heritage Sections of the DEIS mention that a formalleUer was sent to each of the thirteen tribes which hold the San Francisco Peaks sacred. Several follow-up phone calls were made and two formal meetings were held in December of 2002. This level of outreach is inadequate under the Forest Service's environmental justice obligations.
i. The Forest Service has failed to meet its outreach obligation under Executive Order 12898.
Under NEPA's implementing regulations, the Forest Service is required by law to "[m]ake diligent efforts to involve the public in preparing and implementing their NEPA procedures." 40 C.F.R. 1506.6(a). Executive Order 12898 further requires that the Forest Service involve potentially disadvantaged communities concerning proposed actions. E.O. 12898 requires that:
"[E]ach federal agency shall conduct its programs, policies, and activities that substantially affect human health or the environment in a manner that ensures that such programs, policies, and activities do not have the effect of excluding persons (including populations) from participation in, denying persons (including populations) the benefit of, or subjecting persons (including populations) to discrimination under, such programs, policies, and activities, because of their race, color, or national origin." Exec. Order No. 12,898,59 Fed. Reg. 7629, 7630 (1994).
The DEIS acknowledges that the proposed Snowbowl expansion will have permanent impacts on central cultural and religious sites of affected Native American Communities. Therefore, the Forest Service must make every effort to include input from those adversely effected communities. However, the Forest Service has failed to adequately garner participation from potentially impacted persons, holding only two meetings in Native American Communities and soliciting input only via letters to community leaders, at least one of which was never actually delivered by the United States Postal Service. The Forest Service's failure to do more excludes, denies, and subjects Native American populations to discrimination, because the communities that will be most affected by the expansion have not been adequately included.
ii. The Forest Service has failed to meet its outreach obligation under CEQ guidance.
The Council on Environmental Quality provides additional guidance on E.O. 12898 that specifies approaches that the Forest Service should implement in order to garner adequate input from effected communities. CEQ's guidance states that "[i]f an agency identifies any potentially affected minority populations, low-income populations, or Indian tribes, the agency should develop a strategy for effective public involvement in the agency's determination of the scope of the NEPA analysis," and that "customary agency practices for notifying the public of a proposed action and subsequent scoping and public events may be enhanced ... " CEQ, E.J. Guidance at 11 (emphasis added). In order to fully assure the meaningful participation of such groups, the Forest Service's NEPA process "may require adaptive or innovative approaches to overcome linguistic, institutional, cultural, economic, historical, or other potential barriers to effective participation." Id. at 13 (emphasis added). The guidance goes on to provide several examples of such adaptive or innovative approaches, including:
-Translation of major documents, provision of translators, and provision of opportunities for limited English speaking or non English speaking people to provide input during the NEPA process. Id.
-Provision of opportunities for public participation through means other than written communication, including personal interviews or use of audio or visual equipment to capture oral communications. Id.
-Use of different meeting sizes or formats, or variation on the type and number of media used, so that communications are tailored to the particular community or population. Id.
Use of locations and facilities that are local, convenient, and accessible to the disabled, low-income and minority communities, and Indian tribes. Id.
While CEQ's guidance does not necessarily require that federal agencies adopt all of these methods to achieve NEPA's goals or to meet executive guidance concerning environmental justice considerations, federal agencies must clearly redouble their efforts during NEPA processes for proposed actions that implicate environmental justice. In the case of Snowbowl, such efforts are especially critical, given the large number of Indian tribes that will be affected by the proposal, the central role the Peaks play in the religious and cultural existence of these tribes, and the affront the proposed Snowbowl expansion poses on these beliefs. Yet, the Forest Service has attempted no "adaptive or innovative" measures to inform and educate tribal members, or to solicit their input on the proposed expansion.
The Forest Service makes no indication that it "developed a strategy," "enhanced" its scoping procedures or used "adaptive or innovative approaches." One meeting in two different locations on the same day is certainly not a use of "different meeting sizes and formats." The Forest Service did not encourage or even allow for meaningful participation from a majority of affected communities. There is no indication that translators or translated documents were available. There has been little opportunity for oral testimony or use of audio or visual equipment. By failing to consider even a few innovative measures that would provide meaningful opportunities for broader community input, the Forest Service has failed in its obligation under NEPA.
iii. The Forest Service has failed to meet its outreach obligations under its own USDA regulations
As part of USDA, the Forest Service is required to pay special attention to adherence of that agency's regulations. USDA Reg #5600-2 states that:
"Notification should be accomplished by such means as publishing notices in local newspapers, including those read by potentially impacted low-income and minority groups ..... Announcements should also be made through such vehicles as local radio and television stations and newspapers. Broadcasts and publications made in languages other than English can be particularly helpful in communicating with non-English speakers."
"USDA agencies should find creative and meaningful ways to facilitate access to information about the proposed action and the NEPA process to potentially affected minority and low income populations. Outreach possibilities would include organizing public meetings at a time and place that is convenient for the potentially affected communities, scheduling meetings with elected officials and/or community organizations, and publishing a newsletter to keep people informed."
"The participation of interested or affected parties should be encouraged during scoping as well as throughout the entire NEPA process. Documents, meetings, personal contacts, and written correspondence should be translated to
facilitate participation by persons who do not speak or understand English. Such translations pertain to each of the steps that follow." USDA, EJ Reg, Appendix E at E-1, E-2 (emphasis added).
Again, in this case, "creative and meaningful" efforts are especially critical, given the large number of Indian Tribes that will be affected by the proposal, the central role the Peaks play in the religious and cultural existence of these tribes, and the clear affront the proposed Snowbowl expansion poses to these beliefs. The Forest Service has refused to use many of the adaptive measures suggested by its own agency regulations. No notices have been published in Native American publications or newsletters. No public service announcements have been made on Indian radio stations. No "newsletter" to keep affected communities informed has been developed. By failing to consider these and other innovative measures mentioned above that would provide meaningful opportunities for broader community input, the Forest Service has failed in its obligation under its own agency regulations.
b. The Forest Service Has Failed to Translate NEPA Documents So That All Affected Members of the Public Can Understand the Proposed Snowbowl Expansion.
In addition to the translation requirements included in the various environmental justice guidance documents cited above, NEPA also requires that documents be translated to facilitate public participation. NEPA's dual purposes are to "help public officials make decisions that are based on understanding of environmental consequences," and to "insure that environmental information is made available to public officials and citizens before decisions are made and before actions are taken." 40 C.F.R. 1500.1 (b),(c). To this end, "accurate scientific analysis, expert agency comments, and public scrutiny are essential." Id.
In order to encourage full public scrutiny and participation, information contained in EISs and other NEPA documents must be plain and accessible to general members of the public. To this end, the CEQ's implementing regulations for NEPA state that:
"Environmental impact statements shall be written in plain language and may use appropriate graphics so that decision makers and the public can readily understand them. Agencies should employ writers of clear prose or editors to write, review, or edit statements, which will be based upon the analysis and supporting data from the natural and social sciences and the environmental design arts." 40 C.F.R. 1502.8.
According to the 9th Circuit, this section "imposes a requirement that an EIS must be organized and written so as to be readily understandable by governmental decision makers and by interested non-professional lay persons likely to be affected by actions taken under the EIS." Oregon Environmental Council v. Kunzman, 817 F.2d 484,494 (9th Cir. 1987).
?&
In this case, the class of "interested non-professional lay persons likely to be affected by actions taken under the EIS" clearly includes members of Southwestern tribes for whom the Peaks have central religious and cultural significance. This includes, of course, not only tribal members who may happen to live in the vicinity of the San Francisco Peaks, but members who presently reside on Reservation land and either do not speak English, or do not speak English as a primary language. Where a substantial portion of the affected public speaks a language other than English, the requirement to provide impact statement written in "plain language" and "clear prose" clearly entails translation of the document into additional language or languages. For example, the Environmental Protection Agency, in implementing NEPA, "has prepared versions of documents in Spanish when public interest has warranted the action." 53 Fed. Reg. 18579, 18580 (May 24, 1988). NEPA clearly requires a translation of the DEIS for the proposed action and all subsequent NEPA analysis to similarly be translated into Navajo, Hopi, Apache and all other tribal languages so to be "readily understandable" by the many Indian people clearly affected by the proposed expansion of the Snowbowl facilities. By failing to translate these and other documents, the Forest Service has doubly failed in its obligation under NEPA and environmental justice guidance documents.
3. The Forest Service Has Failed Under Its Environmental Justice Obligations to Provide Appropriate Alternatives
In the case of the Snowbowl expansion, the DEIS proposes three alternatives: no action, expansion of the facilities with added artificial snow production and expansion of the facilities without added artificial snow production. Beyond the usual considerations of NEPA alternatives analysis as discussed (supra/infra) in these comments, the Forest Service, in this case, is also obligated to considered alternatives developed by communities particularly affected by environmental justice considerations. The CEO guidance states:
"In cases where a proposed action might have a disproportionately high and adverse impact on minority or low income populations, agencies should make strong effort to encourage members of those communities to help develop and comment on possible alternatives. Efforts would include organizing meetings to facilitate public input on the alternatives." CEO, E.J. Guidance at 3 (emphasis added).
Along with a general failure to conduct appropriate outreach, as noted above, the Forest Service has particularly failed to "encourage" input as to the development of various alternatives. If the Forest Service seriously considered alternatives proposed by community members it would likely be looking at such measures as downsizing current Snowbowl operations, minimizing current impacts by other means or re-siting the facility altogether. However, the Forest Service has failed to encourage the input for development of such alternatives, thereby also failing to make such alternatives available for consideration.
At a minimum, however, the Forest Service needs to incorporate community input into the analysis of each alternative. The CEO requires that such analysis "should include potential impacts to subsistence consumption and human health as well as the related economic and social effects of each alternative." CEO, E.J. Guidance at 4 (emphasis added).
This is a compilation of the complaints against the Forest Service NEPA decision on the San Francisco Peaks as it was entered into the legal record. Like many technical documents it may appear somewhat pasted together and contain various shortcuts and unusual technical terms or acronyms. It is meant to convey the gist of the arguements against each of the technical reasons given for the decision to permit the Snowbowl expansion.
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