forest green peak expansion project...

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Whit

e M

ounta

in N

ati

onal Fore

st

United States Department of Agriculture

Forest

Service

Eastern

Region

Waterville Valley Ski Resort

Green Peak Expansion Project (Supplement)

Town of Waterville Valley GraftonCounty, NH

Supplemental Environmental

Assessment

30 Day Comment Report

Prepared by the White Mountain National Forest

November 2014

For Information Contact: Susan Mathison

White Mountain National Forest

71 White Mountain Drive

Campton, NH 03223

Phone: 603 536-6245

Fax: 603 536-3685

www.fs.usda.gov/whitemountain

Fax: 603-536-3685; Attn: Susan Mathison

[email protected]

http://www.fs.usda.gov/whitemountain/landmanagement/projects



Green Peak Expansion Project Supplemental Environmental Assessment

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This document is available in large print.

Contact the White Mountain National

Forest

603-536-6100

Fedrelay 11

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Whitten Building, 1400 Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-

5964 (voice and TDD). USDA is an equal opportunity provider and employer.

Printed on Recycled Paper


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Contents

Chapter 1 – Background and the Need for Action ........................................................................................ 8

Background ............................................................................................................................................... 8

Summary of the Proposed Action ........................................................................................................... 10

Purpose and Need for Action .................................................................................................................. 11

Connection to the Forest Plan ................................................................................................................ 11

Public Involvement ................................................................................................................................. 12

Issues ....................................................................................................................................................... 13

Chapter 2 - Alternatives .............................................................................................................................. 13

Alternative 1 – No Action ........................................................................................................................ 13

Alternative 2 – Proposed Action ............................................................................................................. 14

Mitigation Measures ............................................................................................................................... 16

Alternatives Considered but Eliminated from Further Study ................................................................. 18

Chapter 3 – Effects Analysis ........................................................................................................................ 18

Affected Environment ............................................................................................................................. 18

Effects Analysis........................................................................................................................................ 19


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Map 1: Vicinty map for Revised Proposal for Green Peak Expansion.


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Map 2: Location of Existing World Cup Fixed Grip Triple Chairlift and Location of Approved Route for Green Peak High Speed Detachable Quad


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Chapter 1 – Background and the Need for Action

The White Mountain National Forest (WMNF) originally analyzed the Green

Peak Explansion Project in 2011-2013. A Decision Notice and Finding of No

Significant Impact, which approved the Green Peak Expansion project as

proposed, was signed on June 21, 2013. Since then, Waterville Valley Ski Resort

has reconsidered its planned construction of the high speed detachable quad

chairlift that had been approved and has submitted a revised proposal which

would re-locate the existing 1985 World Cup fixed grip triple chair to the

approved alignment.

The revised proposal was presented to the Forest on October 17, 2014 and revised

again on October 22. The new proposal includes the removal of the World Cup

triple chair from its current location, rehabilitation of the site, transport and

staging of lift components, the addition of several lift towers and a new cable,

and re-construction of the triple chair in the previously-approved alignment. As

a related action, unchanged from the original decision, the Black and Blue Trail

Smashers Ski Club (BBTS) building will be demolished for the location of the

triple chair bottom terminal and a new BBTS building constructed in the

specified and approved location.

The removal and relocation of the triple chair was not considered or analyzed in

the Green Peak Environmental Assessment. This new proposal requires analysis

of effects of the removal and reconstruction of the triple chair. The new proposal

and its potential effects will be analyzed and disclosed as part of this

supplemental environmental analysis. Information from the 2013 project and

decision is available here:

http://www.fs.usda.gov/wps/portal/fsinternet/projects/whitemountain/landmana

gement/projects?sortby=1&archive=1

Background

The original Waterville Valley Ski Resort Green Peak Expansion Project decision

approved the following projects:

http://www.fs.usda.gov/wps/portal/fsinternet/projects/whitemountain/landmanagement/projects?sortby=1&archive=1

http://www.fs.usda.gov/wps/portal/fsinternet/projects/whitemountain/landmanagement/projects?sortby=1&archive=1


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A. create a network of skiing and snowboarding trails in the Green Peak

area. Approximately 8 new trails totaling about 44 acres would be

constructed, offering a variety of terrain ability levels;

B. create approximately 7 acres of glades;

C. install a detachable quad chairlift to provide access to the new terrain.

This 4,000 ft lift would have an hourly capacity of 2,800 skiers and

riders and a vertical rise of ~1,000 feet;

D. remove the Black and Blue Trail Smashers (BBTS) Competition

building (Old Valley Run lift building) to accommodate the lower

terminal of the new chairlift. A new BBTS Competition building

would be constructed at the lower end of the tree island that separates

the trails Lower Periphery and The Pasture. The new structure would

be two stories, approximately 40’ X 60’ at the base, thus containing

about 4,800 sq. ft. The clearing for the new building would be

approximately 0.1 acres;

E. expand the on-mountain snowmaking system to provide coverage for

each new trail. Existing water supply sources (Mad River, Corcoran’s

Pond) would supply water for snowmaking on Green Peak. All water

withdrawals (inclusive of the needs of existing and proposed trails)

would meet currently established minimum flow requirements of 0.5

cubic feet per second per square mile (csm) of watershed.

F. amend the Forest Plan (see EA for amendment wording) to approve a

minor reduction in designated, but marginally suitable, Canada lynx

habitat.

Following the decision to approve the implementation of these projects,

Waterville Valley Ski Resort determined that it would not construct the approved

high speed detachable quad, but would propose to utilize the existing World

Cup triple chair (see Map 2). The proposal would relocate the triple chair to the

alignment on Green Peak that had been approved for the high speed quad chair.

This revised proposal was not proposed nor analyzed in the original assessment

and, therefore, requires additional analysis by the interdisciplinary team (IDT) of

resource specialists and public comment.


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All other projects approved by the Green Peak Decision Notice, above, remain

unaffected by the new proposal.

Summary of the Proposed Action

Waterville Valley Ski Resort submitted a proposal to relocate the existing World

Cup triple chairlift to the location previous approved for the Green Peak high

speed detachable quad chairlift. The proposed action would:

Dismantle the World Cup triple in its existing location. Chairs would be

removed and the cable spooled and staged in Waterville parking lots #7

and 8 during Spring 2015.

Lift towers would be disconnected from their bases and flown by

helicopter to and staged in Waterville parking lots #7 and 8 in early

Summer 2015.

Towers would be spot-sanded and painted in the parking lots.

Concrete tower bases would be broken up with an excacator and hammer

attachment and removed to the level of the surrounding ground surface;

the below-ground concrete will remain in place to minimize ground

disturbance. No blasting would be required.

Native soil from immediately adjacent to the site would be used to cover

the remaining concrete surfaces. The new surfaces would be seeded and

mulched.

The upper and lower lift terminal buildings would be dismantled and

removed via existing work roads.

The existing lift corridor would be retained as skiable terrain.

In late Summer and Fall 2015, the triple chair would be re-installed in the

location previously approved in the Green Peak Decision Notice.

As was necessary for the high speed quad, installation of the lower lift

terminal for the Triple Chair would require the demolition of the existing

BBTS building; Waterville Valley intends to construct a new building for

BBTS as described and approved in the Green Peak Decision Notice.

Additional towers as well as a longer cable are anticipated to be added to

existing triple chairlift according to final engineering specifications.

The are no plans to replace the World Cup triple chair in its current

location.


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Purpose and Need for Action

Waterville Valley submitted the purpose and need for its modified proposal:

“The repurposing of the existing World Cup Triple will allow the resort to

make better, more efficient use of their current lift inventory. Waterville

Valley Resort current has 11 lifts serving about 220 acres of skiable terrain.

This is a fairly high lift‐to‐skiable acre ratio for a resort of this size. Adding

more lifts to the current configuration simply does not make sense given the

most recent three years of skier visit data and usage reports. Currently The

World Cup Triple Lift only runs about 10 days out of the year and primarily

services the ski area’s local racing team. Given its proximity to the main

White Peak’s Quad Lift, it has become redundant and receives almost no

general public use. Typically the racers already use any number of other lifts

to access their terrain with limited impact to the general public. By removing

the World Cup Triple, Waterville Valley Resort will be able to restore the

current lift line back to its original, more natural state, and allow for a

minimal net gain in disturbed terrain after the lift is reinstalled at Green Peak.

Cost saving anticipated from this repurposing of the triple lift will be

significant, thereby making the entire project more feasible and successful for

the recreation users.”

Connection to the Forest Plan

This project tiers to the White Mountain National Forest’s Land and Resource

Management Plan, also known as the Forest Plan. The Plan is a programmatic

framework that documents the desired balance of multiple uses to meet society’s

needs while protecting, restoring, and enhancing our natural resources.

This supplemental environmental assessment (EA) is tiered (40 CFR 1508.28) to

the Record of Decision (ROD) and Final Environmental Impact Statement (FEIS)

for the Forest Plan (USDA Forest Service 2005a, 2005b, 2005c). Information and

analysis in those programmatic documents that applies to this project-level

analysis were incorporated by reference in the original Green Peak EA and in this

Supplement, in order to focus on site-specific issues.


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Public Involvement

Section 1.7 of the original Green Peak EA explains the public involvement

process. A Scoping Report for the Waterville Valley Green Peak Expansion

Project was posted on the WMNF website and mailed to interested and/or

potentially affected members of the public on December 23, 2011. An

informational open house was held on Wednesday, January 18, 2012. The

scoping comment period was open from December 23, 2011 to February 3, 2012.

Forty comments were received. A Scoping Content Analysis was prepared which

recognizes all of the comments received and provides more information on

specific comments and how they were categorized and addressed in the EA. This

document is part of the Project file.

The 30 Day Comment Report was distributed to the public and noticed in the

New Hampshire Union Leader on April 23, 2013. The 30-day comment period

ended on May 23, 2013. Three comments were received on the 30 Day Comment

Report, two of which were in support and one of which expressed concerns.

Responses to these comments are contained in Appendix A of the original Green

Peak EA.

This project was continually published in the White Mountain National Forest

(WMNF) Schedule of Proposed Actions (SOPA) from October 1, 2011 until the

Decision Notice was signed in June, 2013. No appeals were received and the

projects, as approved, were available for implementation 45 days after the

Decision Notice was signed on June 21, 2014.

This Supplemental Environmental Assessment is being sent to all individuals

and groups who commented or expressed interest during the 30-day comment

period on the original Green Peak EA.. This Supplemental EA is being made

available for a 30 Day comment period. Once public input has been taken into

account and the Supplement EA is finalized, a Draft Decision Notice and Finding

of No Significant Impact will be issued (if effects indicate it is appropriate). to

start a 45-day objection period under 36 CFR 218.

This Supplemental EA is listed on the quarterly White Mountain National Forest

Schedule of Proposed Actions (SOPA), and will remain on the SOPA until after a

decision is signed.


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Issues

An issue is a point of debate, dispute, or disagreement regarding anticipated

effects of implementing the proposed action, in this case, the amended proposed

action. Issues are usually identified by the interdisciplinary team based on

comments from the public or other agencies. Occasionally issues arise within the

interdisciplinary team if the concerns of all resources cannot be addressed in a

proposal.

All resource concerns were addressed in the proposed action and addressed with

appropriate mitigations, therefore no issues were identified.

Chapter 2 - Alternatives

This section describes the various ways of meeting some or all of the purpose

and need that were considered by the interdisciplinary team and responsible

official. Two of these alternatives (taking no action and implementing the

proposed action) are analyzed in detail in Chapter 3.

Alternative 1: No Action; Implement the construction of a high speed detachable

quad as part of the Green Peak Expansion as Approved in the June, 2013

Decision Notice and Finding of No Significant Impact.

Alternative 2: Proposed Action; Relocate the World Cup Triple Chairlift, rather

than the high speed detachable quad chairlift, to the same location as approved

for the Green Peak high speed quad chairlift in the Green Peak Expansion June,

2013 Decision Notice and Finding of No Significant Impact.

Alternative 1 – No Action

Under this alternative, the proposed relocation of the World Cup triple chair

would not be approved for implementation; the construction of the high speed

quad, as originally analyzed, would remain as a viable and approved alternative

for implementation by Waterville Valley Ski Area. All other actions approved in

the June, 2013 Decision Notice would similarly be unaffected by this No Action

Alternative. Under the No Action Alternative, Waterville Valley could


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implement all of the activities and projects as approved in the June, 2013 Decision

Notice, including the construction of the high speed quad chairlift.

Alternative 2 – Proposed Action

The proposed action is to relocate the World Cup fixed grip triple chair from its

current location to the alignment previously analyzed and approved for the

Green Peak High Speed quad chairlift.

Figure 1: Base Terminal of World Cup Fixed Grip triple Chairlift in its current location.

The Proposed Action would:

Dismantle the World Cup fixed grip triple chairlift in its existing location.

The chairs would be removed and the cable spooled and staged in

Waterville parking lots #7 and 8 during Spring 2015. This work would

begin during winter season operations and continue into the late spring.

Public safety would be insured via fencing and signing of the

deconstruction area.

In late Spring/early Summer 2015, the existing cross arms and lift towers

would be disconnected from their bases and flown by helicopter to and


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staged in Waterville parking lots #7 and 8.

During de-construction and based on digital surveying and on-the-

ground review, lift engineers would specify modifications to the triple

chair that would be required for its new location on Green Peak. This

would likely include several new towers and a longer cable.

The triple chair towers would be spot-sanded and painted while staged in

the parking lots #7 and 8. Site protection would be in place to prevent

sanding debris from entering soil or water courses. Painting would be

done with ground protection in place. Primer would be applied with

paint rollers and brushes; paint would be sprayed during low wind

conditions.

Tower bases would be broken up and removed to the level of the

surrounding ground surface. No blasting would be required.

Native soil would be used to cover the remaining concrete surfaces. The

new surfaces would be seeded and mulched.

The Lift Terminal buildings would be dismantled and removed via

existing work roads.

The existing lift corridor would be retained as skiable terrain.

In late Summer and Fall 2015, the triple chair would be re-installed in the

location previously approved in the June, 2013 Green Peak Decision

Notice. Installation of the Triple Chair would require the demolition of

the existing BBTS building; Waterville Valley intends to construct a new

building for BBTS as described and approved in the June, 2013 Green

Peak Decision Notice.

There are no plans to replace the World Cup triple chair in its current

location.

The high speed quad would have had a capacity of 2,800 skiers per hour;

the relocated triple chair would have a capacity of approximately 1,630

skiers per hour.


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A comparison of the existing lift specifications and the proposed

specifications is displayed below:

Table 1: Comparison of Lift Specification for World Cup Triple, Current Location vs. Proposed Location

Mitigation Measures

In addition to Forest Plan Standards and Guides, all Ski Area Best Management

Practices would be implemented throughout this project. Additional mitigation

measures would include:

Ensure public safety throughout implementation. During the winter

operating season, all work areas would be fenced and/or signed to

preclude public access.

All heavy equipment would be visibly free of seeds and plant parts prior

to entering the project area. Cleaning should take place off-Forest unless

an on-Forest cleaning site has been approved by a Forest Officer in

advance.

Soil or fill would come from weed-free sources. The Forest Service would

be available to identify local gravel sources that containweed-free borrow

material in their pits.

If any new cultural sites are found during project implementation, all

activity in the area would stop, and WMNF archaeologists would be

informed so that they can be assessed and protected.

World Cup Triple Chairlift

Current Specifications

(before mod/relocation)

Proposed Specifications (after

mod/relocation)

Slope Length (ft): 3974 4380

Vertical (ft): 1073 1011

Speed (ft/min): 475 475

Capacity (pph): 1800 1630

Rope Diameter (in/mm): 1 ½”xxips 1 ½”xxips

Number of Carriers: 169 169

Number of Towers: 15 17

Drive Location (top/bottom): Bottom Bottom

Tension Location (top/bottom): Bottom Bottom


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Temporary erosion control measures such as silt fence, hay bales, straw

wattles or other appropriate materials would be in place to protect water

bodies from ground disturbance until site is permanently stabilized. All

applicable Forest Plan Standards and Guidelines and all ski area Best

Management Practices would be implemented.

Disturbed soil within 100 feet of surface water, on stream crossing

approaches, on steep slopes draining into surface waters, and where soil

erosion potential exists would be seeded with a native seed mix and

mulched to provide temporary stabilization.

All sanding and welding debris would be contained and removed from

the site. Painting would be completed only during no/very low wind

conditions.

Best Management Practices (BMPs) for spill prevention and containment

would be used when transporting or using potentially hazardous

substances such as fuel.

Forest Service personnel would approve in writing the color and

reflectivity of all paint and finish materials.

Helicopters would not fly over Bicknell’s thrush habitat during nesting

season, May 1 to August 15.

Off-road vehicle access and tower foundation removal would be

conducted according to an approved erosion control plan, and under

sufficiently dry ground conditions to prevent erosion and sedimentation.

Mineral soil disturbance related to these activities would be mitigated

with temporary erosion control until permanent measures such as

revegetation have become fully effective.

Tower base debris removal would occur in dry conditions.

Site rehabilitation and stabilization would be established, seeded and

mulched prior to September 15 in order to assure germination prior to

winter season.


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Alternatives Considered but Eliminated from Further Study

In developing this Supplemental Environmental Assessment for the revised

proposed action, the interdisciplinary team and responsible official discussed the

project and determined that there were no additional alternatives that addressed

the Purpose and Need for the relocation of the triple chair

Chapter 3 – Effects Analysis

This is a supplemental analysis which tiers to the original environmental

assessmentcompleted in 2013, as referenced in the Background section of this.

Consequently, the analysis completed in the original document is not repeated

here in detail.

The Interdisciplinary Team for this supplemental analysis consisted of specialists

in recreation, soil and water, lift engineering, wildlife, botany and heritage

resources. Those specialists reviewed the project and considered the best

available information to evaluate potential impacts from the two alternatives on

their resources. Input from each specialist is available in the project record.

This section describes the direct, indirect, and cumulative effects on resources

that would result from implementation of Alternatives 1 and 2.

Affected Environment

Each section below describes the affected environment for each resource and

discuss effects in more detail. The rationale for identified analysis areas and

timeframes, and all literature cited also are located in the project record.

Direct and indirect effects are those impacts that result from implementation of

the project. Cumulative effects are the combined impacts of the direct and

indirect effects with impacts from past, ongoing, and known future actions in the

identified timeframe and analysis area. All past, ongoing, and future actions


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within the various analysis areas used by specialists are listed in the project

record.

Effects Analysis

3.1 Water Resources

Direct and Indirect Effects

Alternative 1: No Action;

The direct and indirect effects are identical to those analyzed under Alternative

1 in the original Green Peak Expansion Project Environmental Assessment

(original EA).

Alternative 2

With the implementation of Mitigation Measures, above, Forest Plan Standard

and Guides and Best Management Practices, the relocation of the World Cup

Triple would have no effects to Water Resources.

Cummulative Effects

Alternative 1

Cummulative effects would be identical to those analyzed in the original Green

Peak Expansion Project Environmental Assessment (original EA).

Alternative 2


and Guidelines and Best Management Practices, the relocation of the World Cup

Triple will have no cumulative effects to Water Resources.

3.2 Soil Resources




1 in the original Green Peak Expansion Project Environmental Assessment

(original EA).


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Alternative 2



Triple will have no adverse direct or indirect effects to Soil Resources.

Cummulative Effects

Alternative 1

Cummulative effects would be identical to those analyzed in the original Green

Peak Expansion Project Environmental Assessment (original EA).

Alternative 2

With the implementation of Mitigation Measures, above, Forest Plan Standards


Triple will have no cumulative effects to Soil Resources.

3.3 Fisheries and Aquatic Resources




1 in the original original EA.

Alternative 2



Triple would have no effects to Fisheries and Aquatic Resources.

Cummulative Effects

Alternative 1


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Cummulative effects would be identical to those analyzed in the original EA.

Alternative 2



Triple will have no cumulative effects to Fisheries and Resources.

3.4 Vegetation Resources and Non-Native Invasive Species




1 in the original EA.

Alternative 2



Triple will have no adverse effects to VegetationResources; mitigation measures

will be used to limit any spread of non-native invasive species.

Cummulative Effects

Alternative 1


Alternative 2



Triple will have no adverse cumulative effects to Vegetation Resources;

mitigation measures will be used to limit any spread of non-native invasive

species.


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3.5 Wildlife Resources



The direct and indirect effects on wildlife and their habitat from activities

associated with relocation of the World Cup triple chair lift would be similar to

the effects analyzed under Alternative 1 in the original EA.

Alternative 2

Dismanteling, relocating, and reconstructing the World Cup triple chair lift

would affect more wildife habitat area then the amount that was originally

analyzed. However, the direct and indirect effects on wildife and their habitat

from relocation of the World Cup triple chair lift does not introduce any new

effects beyond what was already analyzed in Alternative 2 of the original EA.

Cummulative Effects

Alternative 1 and 2

There would be no additional cummulative effects beyond those analyzed in the

original EA.

3.6 Threatened, Endangered and Proposed Species and

Regional Forester’s Sensitive Species



The direct and indirect effects would be the same as those analyzed under

Alternative 1 in the original BE and disclosed in the EA.

Alternative 2

Bicknell’s Thrush (Catharus bicknelli):

The original Green Peak Expansion Project Biological Evaluation (BE)

determined that the proposed Project Area was located outside of Bicknell’s

thrush habitat (defined as dense thickets of stunted red spruce, balsam fir, birch,


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and krummholz communities of high elevation > 2,900 feet at Waterville Valley).

Based on the following mitigation measure, the activities associated with

relocation of the World Cup triple chair lift would not change the determination

of “no probability of occurrence of Bicknell’s thrush”, and therefore would cause

“no impact” to the population or species of Bicknell’s thrush. Alternative 2

would be consistent with the WMNF Forest Plan standard of no net decrease in

Bicknell’s thrush habitat.

Helicopters would not fly over Bicknell’s thrush habitat during the

breeding/nesting season, May 1 to August 15.

Canada Lynx (Lynx canadensis):

The activities accociated with relocation of the World Cup triple chair lift would

not change the determination of “no effect” on Canada lynx (see the USFWS

concurrence letter for the original BE in the Project file).

Northern Long-eared bat (Myotis septentrionalis), and Other Woodland Bats:

Since completion of the original BE, the Northern long-eared bat became

Federally-listed proposed endangered. The change in listing status did not

introduce any new effects beyond what was already analyzed in the original BE.

Pending the final outcome of the US Fish and Wildlife Service (USFWS) listing

process, Alternative 2 will comply with all applicable USFWS terms and

conditions and/or conservation measures for the Northern long-eared bat. The

activities associated with relocation of the World Cup triple chair lift would not

change the determinations for the other Regional Forester listed Sensitive Species

of woodland bats considered in the original BE (little brown myotis, tri-colored

bat, Eastern small-footed myotis).

Cummulative Effects

Alternative 1 and 2

There would be no additional cummulative effects beyond those analyzed in the

original BE.


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Cummulative Effects

Alternative 1 and 2


3.7 Visuals


Alternative 1

Direct and indirect effects of the construction of the high speed quad chairlift

would be identical to those analyzed in the original EA.

Alternative 2

Alternative 2 would not construct the high speed quad lift; but instead would

relocate the triple chair, resulting in a net reduction in approved lifts. Alternative

2 would have incremental positive visual effects at Waterville Valley because it

would result in reducing the total number of lifts approved within the ski area

boundary.

Cummulative Effects

Alternative 1


Alternative 2

There would be no additional or cumulative effects on Visual Resources

from the implementation of Alternative 2.

3.8 Winter Recreation Resources


Alternative 1


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Direct and indirect effects of the construction of the high speed quad chairlift

would be identical to those analyzed in the original EA.

Alternative 2

The Proposed Action would allow Waterville Valley to install the triple chair lift

on Green Peak. Moving the Triple Chair would facilitate the ski area’s operations

by re-purposing a lift that had limited use, yet required routine maintenance,

inspection, and staffing.

Cummulative Effects

Alternative 1

If the quad was constructed as originally proposed, recreation cumulative effects

would be identical to those analyzed in the original Green Peak Expansion

Project Environmental Assessment (original EA).

Waterville Valley does not intend to construct a high speed detachable quad on

Green Peak in the foreseeable future. Cumulative effects on Recreation would be

the indefinite delay of the Green Peak Expansion.

Alternative 2

The relocation of the triple chair would allow Waterville Valley to construct two

to three trails, and associated snowmaking systems, in Summer 2015 and two to

three trails in each of the following two summer construction seasons (2016 and

2017).

3.9 Heritage Resources


Alternative 1

Direct and indirect effects would be identical to those analyzed in the original

Green Peak Expansion Project Environmental Assessment (original EA).

Alternative 2


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Since the lift is less than 50 years old, ground disturbance is minimal, and

previous surveys have determined that the project area is not archaeologically

sensitive, this alternative has no potential to affect cultural resources.

Cummulative Effects

Alternative 1

Cummulative effects would be identical to those analyzed in the original original

EA.

Alternative 2

There would be no additional or cumulative effectson Heritage Resources

expected from the implementation of Alternative 2.

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