(photo by Sam Minkler)
Protect the Peaks Comment Regarding Proposal for Arizona Snowbowl “Chondola”
Arizona Snowbowl ski area has proposed “upgrading” the Agassiz chairlift with a detachable combination chairlift and gondola referred to as a chondola or telemix. This proposed action furthers desecration of the San Francisco Peaks, which are held holy by more than thirteen Indigenous Nations.
Project proposal: https://www.fs.usda.gov/project/?project=53153
Re: Comments – Agassiz Chairlift Replacement Environmental Assessment
We reject both alternatives for the proposed “Agassiz chondola” in the Environmental Analysis (EA).
The only acceptable action that could begin to restore and uphold the spiritual integrity of the holy San Francisco Peaks would be immediate termination of Snowbowl’s existing special use permit.
The allowance of further development on the holy San Francisco Peaks, regardless of scale, entrenches the totality of extreme spiritual disruption which directly interferes with our prayers and ceremonial practices.
We further offer the following additional comments:
The EA states that “new disturbance associated with the currently proposed project is approximately 4.10 acres.” This includes associated grading and tree clearing, trench digging, pouring of new concrete, installation of new lift towers by helicopter and a crane, approximately 1.89 acres of tree clearing.
Comment: The scope and scale of the proposed development presents a significant act of desecration beyond a mere “upgrade.” Particularly the proposed gondola cabin storage and maintenance building which would comprise “approximately 4,800 square feet.” [2.2.2 Alternative 2 – Proposed Action] Comparatively, this proposed development is larger than the existing Hart Prairie Lodge which is 4,488 sq.ft.
All associated expansion activities will exacerbate the ongoing disruption and interference with our religious beliefs and practices. From the noise of heavy machinery operation and helicopters, to destruction of sacred medicines and the totality of the sacred offering shrine that comprises the entirety of the holy San Francisco Peaks, we oppose every aspect of this proposed development.
The EA states [1.6.1 The Human Environment, page 4] that, “Proposed projects have the potential to affect cultural resources within SUP area. The project has potential to affect the tribal cultural uses and practices in the Traditional Cultural Property (TCP) on San Francisco Peaks.”
Comments: The EA diminishes Indigenous Peoples’ traditional cultural knowledge and religious beliefs by attempting to narrowly identify specific cultural resources. The EA disregards that the entirety of the San Francisco Peaks are a single living entity that comprises a singular cultural resource.
The EA contains no substantive assessment of potential affect to cultural uses and practices.
No mitigation measures to address adverse cultural impacts are outlined in the EA.
The EA [3.2.2 Affected Environment, page 23] states that a “cultural resource report will be released that includes the following: results of the inventory and site eligibility recommendations; an evaluation of the effects of proposed project activities on historic properties as well as TCPs; management recommendations for site protection and/or mitigation if warranted; and the results of tribal consultation, as conducted by the Forest Service. The cultural resource report will be utilized in the final EA to confirm and address the degree of impacts to cultural resources associated with implementation of the Proposed Action Alternative.”
Comment: This is disingenuous as we cannot comment on the evaluation, mitigation recommendations, or tribal consultation process. As cultural stakeholders, we are being shut out of commenting on this significant part of the EA process. This information may be necessary for us to have further substantive comments regarding our overall cultural concerns.
The EA states [3.2.3 Environmental Consequences of the Proposed Action, page 24, “…the Proposed Action Alternative has potential to affect tribal cultural values and practices in the San Francisco Peaks TCP. The NHPA compliance process requires that mitigation measures are implemented in order to address tribal concerns associated with effects to the TCP. Based on the results of consultation, mitigation measures may be added to the project’s requisite PDC.”
Comment: The EA disregards previous EISs that document Snowbowl’s adverse cultural impacts. It also disregards previous failed mitigation. We have no way to comment on any potential affects as those have not been disclosed in the EA and are expected to rely on results of consultation that “may” result in mitigation measures.
The EA states [3.2.4 Cumulative Effects, page 25, “While the project may result in an environment farther away from the desired condition of the mountain for tribal nations, it does not change use or capacity in any way and thus would not realistically result in cumulative effects to an extent that would affect tribal religious or cultural practices and beliefs in a tangible manner.”
Comment: How did the FS reach this conclusion? Without any meaningful cultural analysis and while the consultation process is still seemingly underway, this section makes baseless and irresponsible assertions. The EA is irresponsibly addressing cultural impacts by stating, “the project may result in an environment farther away from the desired condition of the mountain…”
The terms “farther away” and “desired condition” are loose and necessitate qualification, they also display a bias that diminishes our deeply held religious beliefs and practices.
The EA further states, “…and thus would not realistically result in cumulative effects to an extent that would affect tribal religious or cultural practices and beliefs in a tangible manner.” This conclusion is disingenuous and demonstrates a foregone conclusion considering that previous sections 3.2.2 and 3.2.3 assure that a cultural resource report is pending.
The EA states that the only media contact listed is for the “Arizona Daily Sun,” [4.2 Tribal Governments, Government Agencies, Organizations and Persons Contacted].
Comment: There are significant news papers and other media channels that directly serve the larger Indigenous stakeholder communities. That the FS failed to reach out to Tribal news papers and other Tribal media channels demonstrates a clear lack on meaningful outreach.
Klee Benally, Diné, Protect the Peaks coordinator.