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Re: OT: Ski Area Scorecard

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  • Patrick
    Response from Kirkwood Read the previous post and the following, and make your own descision.
    Message 1 of 2 , Dec 14, 2006
      Response from Kirkwood

      Read the previous post and the following, and make your own descision.

      December 11, 2006

      Thank you for your letter regarding the recent environmental scorecard
      rating we received from the Ski Area Citizens Coalition. While the
      SACC does an excellent job highlighting environmental issues facing
      our industry, the blanket methodology applied against individual
      resorts is highly subjective and the underlying information is
      frequently inaccurate or incomplete. While we understand how hard it
      would be to audit all 77 resorts in the survey, we often find
      ourselves wishing that we had an opportunity to review the material
      before it was published for public consumption.

      The report itself is inherently biased against resorts in the planning
      phases of growth projects. The fact that we want to improve our
      mountain experience by adding new high speed quad chairlifts and a
      mountaintop restaurant puts us in the position where we cannot achieve
      a desirable report on the scorecard. That says nothing about our
      environmental record in terms of planning, protection and mitigation
      efforts. We feel very strongly that those individuals who take the
      time to explore how Kirkwood compares on category elements of the
      rating system recognize that we are within the top half of resorts
      overall, and in a class by ourselves when it comes to resorts actively
      supporting mitigation efforts such as land conservation and wetlands

      For your information I am attaching a copy of our communication to the
      SACC. We expect the issues in our response will result in a better
      rating and we appreciate any efforts you might make to spread our


      David Likins

      CEO, Kirkwood Mountain Resort


      December 7, 2006

      Via email: ben@...

      Mr. Ben Doon
      Ski Area Citizens' Coalition
      P.O. Box 762
      San Luis, CO 81152

      Dear Mr. Doon:

      On behalf of the employees of Kirkwood Mountain Resort and the
      residents in the Kirkwood Valley, I appreciate the offer to review the
      recent environmental scorecard rating given to our resort by the Ski
      Area Citizens Coalition. While we understand that the review is highly
      subjective and inherently biased against resorts that have ongoing or
      proposed development, we feel that there are a number of computation
      errors and or omissions that should be surfaced to tell the complete
      story of what we are doing here at Kirkwood to protect the environment
      in which we live and operate. Kirkwood is unique in that we are not
      connected to the regional power grid and we are isolated from many of
      the services available to our competitors. This remoteness creates
      both significant challenges and opportunities for environmental
      stewardship and we feel that our efforts and track record should
      reflect a much higher level of achievement than your organization has
      represented. In an effort to simplify the story, I will attempt to
      review the material as structured in your rating criteria:

      1. Maintaining Ski Terrain within the Existing Footprint: 15 of 30
      points. We would note that while we are pursuing a revised Mountain
      Master Development Plan with the USFS, 100% of the proposed
      improvements are located within our existing permitted boundary area
      and thus all of the impacted terrain is currently disturbed by ski
      traffic. We believe this should be commensurate with your criteria
      that "Ski area upgrades and improvements that take place within
      already impacted ski area boundaries… have less damaging impacts on
      wildlife and the environment…" We think that this conscious decision
      to maintain our impacts within our permit area should not result in a
      loss of points under your rating system.

      You correctly noted that we requested approval from the USFS to guide
      skiers in the Thunder Bowl area adjacent to Kirkwood. We would like to
      point out that this is an area already permitted for use under the
      USFS for grazing and other events and that our permit does not request
      or suggest the use of any mechanical equipment. This is purely a ski
      in and hike out operation that we feel improves overall environmental
      stewardship rather than reducing it.

      I would also like to note that our Specific Plan requires that
      Kirkwood plant 5 trees for each tree removed for improvements. KMR has
      stuck to this program, purchasing over 250 trees in 2005 alone to
      compensate for trees felled in conjunction with both its Lift 7 high
      speed quad upgrade and its dead tree maintenance.

      2. Preserving Undisturbed Lands from Development – 4 of 31 points.
      While we completed a EIR and Specific Plan in 2003 that will have some
      impact on undisturbed lands and terrain, your criteria does not take
      into consideration that as part of this proposal we have set aside 133
      acres of private land into permanent conservation easements and have
      pulled nearly 100% of the approved development under the 1988 Master
      Plan into infill projects located in already disturbed locations. Our
      calculations of the undisturbed acreage that will be impacted by
      future development of the 2002 Specific Plan include roughly 6.5 acres
      in Martin Point, 5.0 acres in Palisades VI, 5.0 acres in East Village,
      10.0 acres north of Highway 88 and 2.0 acres in Timber Creek. We are
      also in Year 2 of 3.7 acres of disturbance in Palisades V which
      translates to 3.0 acres. These developments total to 31.5 acres
      including all roadway and building envelope disturbance in zoned
      development areas. Your prior figures did not consider redevelopment
      of existing lodge and parking locations where there is no new net
      disturbance. You also cited disturbance in East Meadows, Juniper Ridge
      and the early phases of the Palisades which were completed and
      disturbed more than 5 years ago. Under criteria 2a, this should
      improve our score from 0 to 10 points.

      Under our specific plan agreement, 100% of the proposed road
      construction is within the disturbance zones cited above for
      residential construction. We have no plans for additional ground
      disturbance for road construction at this time and believe that we
      should, therefore, qualify for all 8 points rather than the 4 we were
      granted in criteria 2b.

      Under criteria 2c we have no parking lot expansion plans into
      undisturbed areas other than those parking spaces located on the
      development properties accounted for in criteria 2a. Our existing
      parking lots have been in place for over 5 years and while we
      continually improve them, we do not pursue additional ground
      disturbance in those locations. We think that we should be granted all
      3 points in this category.

      3. Protecting or Maintaining Threatened Species and Their Habitat – 6
      of 22 points. While the Environmental Impact Statement does identify
      certain species of plants and animals that may be impacted by
      potential development in the identified areas, we are one of the few
      resorts in the country that we know of that have an active flora and
      fauna identification program in place. Our program includes a full
      time staff member that is trained in horticulture and a third party
      consultant who evaluates the impacted area several times per year. The
      report does identify three plant species located within our project
      area but it is worth noting that these species are sensitive rather
      than threatened or endangered. Of the 8 animal species, again none are
      on the threatened or endangered list while 6 are on the sensitive list
      and 2 are on the candidate list. Importantly, our studies indicate
      that only the American Martin has been observed on our property while
      the Mountain Yellow Legged Frog and the Red Fox have been identified
      near our property. The other 5 species have not been found on or near
      our property. We believe this would translate into 6 sensitive species
      where we may have an impact which would imply 11 points rather than
      the 6 we were granted.

      4. Preserving Environmentally Sensitive Areas – 21 out of 30 points.
      Under criteria 4a we have submitted a plan to disturb 1.4 acres of low
      factor value wetlands which represents virtually all of our proposed
      residential development in Kirkwood. We have been working with the EPA
      and the US Army Corps of Engineers to develop a mitigation plan that
      replaces those 1.4 acres with 2.8 acres of additional wetlands that
      have significantly higher factor values. The 2.01 acres of wetlands on
      USFS lands would have no disturbance or remediation requirements. We
      think that we are making significant wetland improvements that provide
      us with 9 points. If the scorecard chooses to dock the company for
      improving the wetland space and features then it should be using 1.4
      acres and provide us with 3 points. The balance of the criteria of 4b
      to 4d correctly identify that we are not impacting old growth forests,
      preserving unique geological formations and protecting roadless areas.
      I would point out that we are participating in a program with the
      Sugar Pine Foundation to help identify white pine and white bark pine
      trees resistant to the blister rust infection that has killed
      thousands of five-needle pines in California since 1930. The goal is
      to plant disease resistant seedlings throughout the Eldorado National

      5. Conserving Water and Energy by Avoiding New Snowmaking – 5 out of
      20 points. Your scoring docks the resort 15 points for its proposed
      snowmaking expansion under the EIS associated with the USFS MMDP. We
      would point out that our proposed snow making expansion was modified
      to reduce the snowmaking territory to +/-100 acres and that our
      snowmaking water rights draw from the dammed Caples Lake. Under your
      criteria, "new snowmaking utilizing reservoirs that recharge during
      high flow time are not counted toward this criterion. Given that the
      El Dorado Irrigation District maintains Caples Lake above pool level
      every year (essentially drained every year for hydro purposes and
      filled in the spring) our proposed expansion should not be included in
      the calculation and we should receive 20 of 20 points.

      6. Opposing / Supporting Environmentally Sound Policy Positions – 3
      out of 10 points. Under criteria 7a Mountain Utilities has no
      outstanding fines associated with any violations with the Great Basin
      Air Pollution Control District or any other agencies. While we did
      contest a 2004 fine for heat stack reporting, the fine in question in
      your report was eventually reduced by over 50% and put into a program
      to reduce emissions from wood burning fireplaces. The balance of the
      fine has since been paid. We should be granted the 2 additional points.

      Under criteria 7b we feel our political stance has supported
      progressive government and legislative policies. We actively supported
      the 2006 Alpine County legislation to impose traffic impact fees on
      developers within Kirkwood to create funds for regional traffic safety
      improvements. We have actively supported and drafted legislation to
      create requirements for employee housing in Kirkwood. We are the only
      ski resort developer that we know of in California that supports a
      County ordinance to house 30% of our peak season employees in on- site
      housing. We have supported the adoption of the limited growth general
      plans in Alpine, Amador and El Dorado Counties and our Specific Plan
      did not seek an increase in the total development units allowed in
      Kirkwood since inception in the 1970s. We believe this activity
      warrants some point activity in these criteria.

      7. Promoting and Implementing Recycling and Water, Land and Energy
      Conservation Strategies – 11 out of 41 points. Under criteria 8a we
      have received zero points for the purchase of offsite energy credits.
      As one of the only resorts in North America not connected to a
      regional power grid, this is an area of particular challenge. While we
      have not been able to purchase credits from the grid, we were able to
      acquire new tier II generation assets for our power plant that have
      resulted in a 20% reduction in emissions and fossil fuel consumption
      for all of Kirkwood over the past two years. This is an extremely
      important improvement for the area as our investment results in a 20%
      conservation for everyone in Kirkwood. Owning a utility off the grid
      creates other opportunities - we are the only resort we know of that
      is attempting to use net solar metering to meet some of its resort
      utility demands. We have a house in our utility company service area
      being completed in January that will be equipped with a solar net
      metering solution that will push electricity onto our local power grid
      that we can use in our distribution system for the resort or other
      purposes. This has been a significant project to identify the metering
      solution to this opportunity and should ultimately qualify us for
      points under the generation criteria in 8b. We also use solar assist
      in our ski patrol facilities on mountain.

      Under criteria 8c, we now use recycled products on over 67% of our
      office and food service paper products, having switched suppliers to a
      sugar cane based biodegradable packaging material in 100% of our food
      service locations this year. This would add 2 points.

      Under criteria 8f we used recycled wood products in our recent
      reopening of one of our restaurants and recycled portions of the
      Timber Creek facility that was torn down this summer. Certainly this
      qualifies for 1% to 50% and a point.

      Under criteria 8g we have moved over 67% of our public restroom
      facilities to low flow toilets, just recently tearing down 26 toilets
      installed in the 1970s for modern urinal systems. I would think this
      qualifies us for the third point.
      Under 8i we have undergone an energy conservation campaign in nearly
      100% of our facilities. Improvements include replacing 100% of our
      snowmaking guns with 28 new high efficiency air/water guns that use
      25% less electricity. In fact this year we eliminated 20% of our air
      compressor capacity in our snowmaking operations and have been
      operating on less than 40% of our prior capacity on most nights. We
      have also improved insulation and or siding in our employee housing
      units, placed motion sensors in older lodge buildings where lighting
      had previously been hard wired, replaced doors and windows in
      locations where heat had escaped, installed ceiling fans in mixed use
      facilities and designed buildings with superior ventilation systems so
      that we could eliminate the air conditioning systems. We believe these
      changes should qualify us for 9 additional points in this section.

      In summary our conservation efforts should result in an additional 13
      to 15 points.

      8. Minimizing Traffic, Emissions and Vehicular Pollution – 4 out of 26
      points. Under criteria 9b you credit the resort with subsidizing the
      two public busses that run the 35 miles from South Lake Tahoe to
      Kirkwood during the ski season. Under our group sales plan in criteria
      9c we provide a free bus pick-up to South Lake Tahoe guests to
      minimize parking impacts and car travel.

      Under criteria 9e, over 50% of our snowmobiles are 4-stroke and we
      have eliminated over 6 vehicles from our fleet in favor of four-stroke
      all terrain vehicles. This change should result in two additional points.

      Clearly there were a number of policy areas where our more recent
      efforts to operate and plan in an environmentally conscious manner
      were not being reflected in your most recent scorecard. As a growing
      resort we will likely not qualify for your higher marks for some time,
      but there is a considerable difference between support and
      recklessness when it comes to environmental issues. We trust that
      these responses and additional information will be taken into careful
      consideration and that your organization will make efforts to
      incorporate this data into your published material. We welcome
      whatever input you might have and would be more than happy to respond
      to any concerns. Please feel free to contact me at (209) 258-7443 or
      to speak with Michael Richter, our Director of Environmental Affairs
      at (209) 258-7418.

      We look forward to your response.


      David P. Likins
      CEO, Kirkwood Mountain Resort

      --- In skiingfanatics@yahoogroups.com, "Patrick" <proe01@...> wrote:
      > In the annual Ski Area Environmental Scorecard, Alpine Meadows and
      > Sierra at Tahoe ranked best in Tahoe.
      > The Worst in Tahoe: Kirkwood
      > Very dissapointing. I just bought a pass. Next year I'll go
      > somewhere else.
      > You can see all the scores and send an email to a good/bad resort on
      > this page.
      > http://www.skiareacitizens.com/index.html#best
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