|How Are Ski Areas Graded?|
The Ski Area Environmental Scorecard grades western U.S. ski resorts on their environmental policies and practices. The grades of the scorecard are based on a point system of individual criterion. The criterion is grouped together into four categories: Habitat Protection, Protecting Watersheds, Addressing Global Climate Change, and Environmental Practices and Polices, which then form a overall grade.
The Ski Area Environmental Scorecard is a service of the Ski Area Citizens’ Coalition (SACC), which is comprised of The Sierra Nevada Alliance (California) and Rocky Mountain Wild (Colorado), as well as other endorsing organizations. These non-profit conservation organizations are familiar with the environmental policies of ski resorts and their impacts to the environment. Volunteers and staff of participating organizations are themselves skiers, and recognize skiing as a valid use of public lands.
Numerous surveys, and the ski industry itself, repeatedly inform us that skiers are an environmentally inclined group. Skiers consider the environment a higher policy priority than the general public. Unfortunately, the ski industry itself is not a great source of information about individual ski areas’ environmental practices and policies. In comments on the White River National Forest plan revision, the EPA noted, regarding sections of forest zoned for developed skiing, that “…no other land management prescription on the Forest directly results in more stream-water depletion, wetland impacts, air pollution, permanent vegetation change, or permanent habitat loss… more wetland impacts and stream depletions resulted from ski area expansion and improvement than from all other Forest management activities combined, including many direct and indirect impacts that are permanent (irreversible and irretrievable)”. After all, once you are outside riding up the chairlift over a snow covered mountain, who is thinking about the carbon emissions of running the chairlift, or the amount of grading and de-vegetation it took to build the ski slope or the chairlift your riding on.
In August 2004, George Washington University Professor Jorge Rivera and University of Denver Professor Peter de Leon published a study of ski industry environmental impacts and the National Ski Area Association’s Sustainable Slopes program. Not only did their results validate the criticisms that the conservation community has had of the ski industry’s voluntary environmental program for years, but the researchers didn’t have any qualms about the validity of the Ski Area Environmental Scorecard as an accurate and useful third-party tool to gauge ski resorts’ environmental policies and management. In fact, they used the Scorecard as the basis in determining the legitimate environmental performance of ski resorts.
The Ski Area Environmental Scorecard strives to differentiate between those ski areas that truly engage in environmentally sound practices versus those that merely claim to do so. While there will always be environmental impacts from creating and operating a ski resort, the intent of the Scorecard is to rate ski areas on their current environmental performance, allowing for ski areas to regain lost points over a period of five years in consideration of development and expansions. The categorical criteria, from which the scores are based, are clearly defined so that ski resorts have the chance to improve their environmental performance. The ski industry’s business thrives on mountain ecosystems, and it necessary for them to be active stewards of the land. The Scorecard will hold ski resorts accountable to preserve, maintain and improve the mountain environments that draw skiers and outdoor recreation enthusiasts in the first place.
Ski resorts concentrate on recreational use, permitting tremendous numbers of people to enjoy and learn about delicate mountain environments in a safe manner. When undertaken in an environmentally sensitive manner, ski resorts can minimize their impacts on the land, while maintaining or improving business.
Creating and maintaining developed ski areas is an intensive use of land that has significant environmental impacts. These impacts include logging, erosion from disturbances on steep slopes, damage to wetlands from construction and maintenance, etc. These actions can compromise values such as the peace, solitude and the feeling of being in touch with the natural environment in which many mountain visitors seek. Unfortunately, some ski companies choose to engage in practices that degrade the environmental integrity that brings business and visitors in the first place. There are some ski companies that are obviously putting more emphasis into their bottom line than the mountain environment, when the mountain environment is the reason they have a business at all.
Since the 1978/1979-ski season, skier numbers nationally have increased less than 2% over 23 seasons, or less than 1/10th of 1% per year. In fact, many ski areas showed a decline in the number of skier visits by between 4-6% during the 2008/2009 ski season. Yet many ski area terrain expansions are being or have been undertaken in an effort to attract the limited pool of skier dollars nationwide. The construction and expansion cycle creates pressure on other ski areas to also expand in order to retain their market share and/or lure the limited number of skiers from other resorts. Ninety percent of ski areas in the western United States are on public lands administered by the Forest Service; it is not sound public policy for the Forest Service to continue to approve terrain expansions, which feed the expansion cycle without regard to public recreation needs, or environmental impacts of doing so. In the White River NF for example, home to ski resort icons such as Vail, Aspen, Breckenridge, and Copper Mountain, skier numbers have increased 28% since 1985, yet skier acreage has more than doubled (a 107% increase).
Ski resorts are evolving at an increasing rate from local or regional recreation facilities to urbanized destination resorts. Rather than concentrating on recreation needs for the public, many ski resorts are aggressively involved in very lucrative real estate development. Urban-type commercial and residential real estate developments by ski resorts compound habitat fragmentation impacts of ski runs and lifts. Such developments adversely impact roadless areas, wetlands, habitats and or other environmentally sensitive lands.
Public, federal, state, or locally owned land is meant for the benefit of all the public, as well as to protect our natural heritage for future generations. Some business corporations within the ski industry (such as sister development companies and retail chains) purchase land, or engage in land exchanges with the Forest Service to obtain parcels of land adjacent to their ski areas. They then propose ski lifts on these lands, which then increases their value for development of ski-in/ski-out condominiums, residential units, or retail outlets. An example of this kind of land trade for commercial and residential use is stated in the Vail Resorts 1997 annual report, which clearly outlines these intentions:
A growing number of ski areas have been able to develop commercial and residential real estate through land exchanges with the U.S. Forest Service or Bureau of Land Management. The Ski Area Environmental Scorecard does not analyze the potential loss or benefit to the public through land exchanges. Our primary concern is the direct and cumulative impacts from resort development on undisturbed land in alpine environments.
To determine a ski area’s score, a set of criteria are employed with each criterion worth a specified number of points proportional to the criterion’s affect on the environment. All criteria apply to every ski area, though some resorts are not capable of losing points through certain criteria. For instance, a ski area not adjacent to or near a roadless area will automatically receive these points for criterion #4c. Likewise, some ski areas do not have adjacent private land available for real-estate development, thus will receive points for criterion #2a: Real Estate Development. Consequently, ski areas in and adjacent to more environmentally sensitive mountain regions must be more responsible yet also have a greater opportunity to demonstrate care for the environment. Scores are calculated in the following manner:
A = 77.9 – 100%
Criteria used to judge ski areas’ environmental practices are weighted to give significant consideration to the preservation of natural mountain environments. Through intensive review of a wide body of pertinent documents including, scientific literature and case studies, such as Environmental Impact Statements for Master Development Plan revisions, expansion proposals, Forest Plan revisions; formal biological opinions prepared by the U.S. Fish and Wildlife Service; as well as marketing, economic, and operational studies prepared by the ski industry, it is clear that development on undisturbed forest lands is the single most damaging ecological impact a ski area can undertake.
A good score means that ski areas both demonstrate environmentally beneficial policies and practices. Simultaneously, the SACC has provided government or scientific documentation for all environmental issues that result in less than full scores being granted. To this end, surveys were mailed to each ski area in the western U.S., followed by phone calls and emails to each ski area. Freedom of Information Act requests were filed with the appropriate land manager (i.e. Forest Service, county government, etc.) to identify additional ski area policies or practices. All of the documents used to determine a ski area’s score are posted on the Ski Area Citizens’ Coalition website
A. Habitat Protection (104 Points)
1. Maintaining Ski Terrain Within the Existing Footprint (30 points)
Ski area upgrades and improvements that take place within already impacted ski area boundaries, as opposed to expansions into undisturbed terrain, have less damaging impacts on wildlife and the environment.
Every ten to fifteen years, the Forest Service is required to revise its management plan for each forest, basically zoning sections of forest for future developed skiing, logging, wildlife habitat protection, or other uses. Ski area expansion proponent’s claim they only seek to have additional sections of forest zoned for developed skiing. However, once a region of forest is zoned for ski area expansions it is practically guaranteed that those sections of forest will eventually be developed for downhill skiing were the ski area to request permission for expansion. Tellingly, no amount of scientific evidence or public opposition has ever empowered the White River NF in Colorado – home to 63% of Colorado’s skier visits – to deny an expansion request. Meanwhile, many states and/or municipalities require zoning for privately owned lands. Some ski areas on non-federal land must obtain proper zoning for ski area expansion terrain from local and/or state governments.
Ski area upgrades and improvements that take place within already impacted ski area boundaries, as opposed to expansions into undisturbed terrain, have less damaging impacts on wildlife and the environment. In a Dec. 30, 1999 letter to the White River National Forest for instance, the Colorado Department of Natural Resources noted that:
Upgrades and improvements on already impacted terrain, such as upgrading a lift from a two person chair to a high speed quad, is encouraged and therefore does not incur loss of points.
2a. Maintaining Real Estate Development Within Currently Disturbed Lands. The ski area is not proposing, undertaking, nor has undertaken residential development, commercial ventures, or other construction (excluding employee housing) on undisturbed lands, by year
on the progressive basis outlined under criterion #1.
Construction denudes an area of vegetation, exposes excessive soil for sediment run-off in streams and requires associated sewer lines, power lines, etc. Parking lot construction denudes an area of vegetation, exposes excessive soil for sediment run-off in streams and creates oil and anti-freeze concentrations that can affect water quality. Similarly, the ski area has not sought zoning for such development. Remodeling, expanding existing facilities, or construction on previously disturbed lands are granted full credit. Zoning requests are worth 25% of point values.
2b. The ski area is not proposing, undertaking, nor has undertaken road construction on previously undisturbed lands, by year on the progressive basis outlined under criterion #1. Road construction denudes an area of vegetation, exposes excessive soil for sediment run-off in streams and creates oil and anti-freeze concentrations that can affect water quality. 8 points based on mileage of request.
2c. The ski area is not proposing, undertaking, nor has undertaken parking lot construction on previously undisturbed lands, by year on the progressive basis outlined under criterion #1. Parking lot construction denudes an area of vegetation, exposes excessive soil for sediment run-off in streams and creates oil and anti-freeze concentrations that can affect water quality. 3 points based acreage of request.
3. Protecting or Maintaining T&E Species and Their Habitat (22 points)
“Protecting or Maintaining Sensitive, Candidate, Threatened or Endangered Species and Their Habitat (The following determinations are found in government agency analysis documents.)
4. Preserving Environmentally Sensitive Areas (30 points)
The Ski Area Environmental Scorecard does not compensate the destruction of wildlife habitat or wetlands for the implementation of mitigation measures. Sacrificing known quality wildlife habitat or a functioning wetland for development in return for questionably viable habitat through mitigation is unacceptable to the Ski Area Citizens Coalition. References to historic failures of mitigation measures include:
In cases where significant scientific controversy exists as to the extent of impacts resulting from actions proposed, approved, or undertaken by the ski area, protection of natural resources is granted the benefit of the doubt. The ski area is not proposing, undertaking, nor has undertaken an expansion, land alteration, or development in known environmentally sensitive areas, by year on the progressive basis outlined under criterion #1. Similarly, the ski area has not sought National Forest management prescriptions or local zoning for terrain alteration in environmentally sensitive areas. The ski area receives points for not disturbing:
4a. Protecting/Preserving Old Growth
4b. Protecting/Preserving Unique Geological Formations
4c. Protecting/Preserving Roadless Areas
B. Protecting Watersheds (27 Points)
5. Protecting/Preserving Wetlands(9 Points)
The ski area will receive points if it is not engaged in activities that have resulted in water quality violations, by year on the progressive basis outlined under criterion #1.
Construction activities create large areas of exposed soil in the mountain environment, which create the potential for large sediment movements during spring run-off and rain events, in addition on-site storage of gas, oil, anti-freeze, solvents, etc. can leak and can contaminate surface and ground water. These activities as well as others can lead to water quality violations as cited by a state water board, the EPA or Army Corp of Engineers. Mountain streams can often be tainted with heavy metals pollution from historic mining operations. Snowmaking utilizing water of lower quality than the ambient downstream receiving waters including that from treated sewer systems, can have a negative affect on the watershed, its aquatic habitats and downstream users. Polluted snow melting into drainages undisturbed from mining can spread heavy metals pollution to clean creeks. In other cases, drawing water from clean streams that serve as a dilution source for other joining streams with mining pollution can worsen water pollution problems downstream.
7. Water Conservation (6 points)
C. Addressing Global Climate Change (64 Points)
8. Climate Change Policies (10pts)
11c. Replacement of old and/or energy inefficient snowmaking guns with automated systems, systems that minimize the use of compressed air, utilizing newer 3 stage centrifugal compressors and mounting guns on towers. 1 – 5% of guns: 1 point, 6 – 20% of guns: 2 points, 21 – 40%: 3 points, 41 – 60%: 4 points, 61 – 80%: 5 points, 81 – 100%: 6 points (Full credit for ski areas that do not have snowmaking.)
D. Environmental policies and practices (35 points)
13. Environmental Policy Positions and Advocacy (12 points)
16b. Environmental Education – prominently displaying sustainability and stewardship practices and programs, environmental education within the local community: 2 points