March 31, 2020

Derek Ibarguen, Acting Forest Supervisor

Bridger-Teton National Dorest

P.O. Box 1888

340 North Cache Street

Jackson, WY 83001

Dear Derek,

On behalf of Friends of Pathways (FOP), we are submitting comments regarding the On-Mountain

Improvements Project for Snow King Mountain Resort. FOP has partnered with the Bridger-Teton

National Forest (BTNF) over the last 20 years to build and maintain sustainable trails and promote

good trail etiquette on the 130-mile front-country trail system, including the Snow King area. We

believe that Snow King Resort is an appropriate place to add new trails and improve existing trails to

provide close-to-home access to the national forest.

We support the following improvements proposed by Snow King Resort as they are in keeping with

the BTNF’s desired future conditions and align with a key component of FOP’s mission to promote

healthy recreation in Jackson Hole.

1. Vertical Staircase

FOP supports the staircase trail as a way to consolidate the multiple eroded vertical hiking trails

into one sustainable option that can be used in summer and winter (uphill bootpack). Trail users

continue to create vertical fall-line trails while looking for a more challenging athletic endeavor.

Properly built steps, utilizing rocks or railroad ties, will serve as check dams for runoff and

erosion and give trail users a sustainable option to hike straight up hill.

2. New Summit Trail

If the new Front Access Road is improved, FOP supports the creation of a new summit trail to keep

trail users off of the road where there will be increased construction traffic. This would be similar to

the Wildflower trail at Teton Village. The proposed trail would likely extend above the Shade

Monkey trail and double as the uphill skin track in winter. There are several good alignments

possible, some extending outside of the Snow King permit area into the adjacent BTNF.

3. Re-Route Sink or Swim

If the new Front Access Road is improved, FOP supports rerouting sections of the Sink or Swim trail

to avoid sharing space with a road that will have construction traffic on it. This is not expressly asked

for in the Snow King proposal but we believe it is important for trail user safety. This would likely be

a small reroute uphill of the shared section of trail and road between the current Summit trail and the

ropes course.

4. Downhill Bike Trails

FOP supports lift-served mountain bike trails at Snow King, and believes that adding trail density

within the resort boundaries will be beneficial and help minimize user conflicts on multi-use trails, as

long as mountain bikers using lift access are not allowed to leave the resort boundaries. We

suggest the best way to prevent this is to allow lift accessed mountain bike trails off of the Rafferty

Chairlift only. If this is not feasible, then there needs to be a clear plan for preventing lift-served

bikers from encroaching onto forest lands outside of the Snow King permit area.

In the alternatives of the Draft EIS there are multiple downhill bike trails proposed off the new

summit lift and the new chair lift “A” on the back side of the mountain. In 2015, the BTNF ruled that

no bikes would be allowed off of the Summit lift in the Cache-Game Trail Projects decision memo, to

avoid an increase in downhill specific bicycle use on the adjacent multi-use trail system, including

Skyline, Wilson, Ferrin’s, Summit, and Josie’s Ridge trails. It is especially important that Snow

King’s downhill bike trails do not encourage a person to ride the lift with their bike, only to exit

the resort and ride down the Ferrin’s Trail or Josie’s Ridge trail and back to the Resort. This

would overwhelm a trail system that is already well-used and has a large amount of uphill

walker/biker traffic.

The BTNF analysis of downhill biking impacts states:

Snow King projects that the proposed front-side trails and back-side mountain bike zone will attract 6,000

riders per season within 5 years of completing the proposed trails and bike zone. To ensure a conservative

analysis, we will address 10,000 downhill bikers per season, or an average of 109 per day for a June 1–

August 31 season. Grand Targhee Resort estimates that up to 20 percent of park riders may leave their

downhill trail system to ride a cross-country trail (Williams 2019). If that figure held at Snow King, it would

equate to 22 new riders per day on Cache Creek/Game Creek trails.”

BTNF assumptions are based on two figures which FOP believes are underestimated or need

further evaluation: (1) the daily average number of people using the Snow King lift-service

trails; and (2) the average number of laps or rides that a person will make on those trails.

To get the best estimate for how many daily riders will use Snow King facilities, it would be prudent

to get data from Jackson Hole Mountain Resort before assuming a daily average of 109 riders.

Arguably, Snow King could have superior downhill trails, with more vertical loss than JHMR, so

daily riders may be equal to or greater than JHMR.

To get the best estimate for how many lift-access riders will leave the downhill system, it is critical to

have a more precise daily average figure and to assume that each rider is capable of making multiple

laps per day. Rather than assuming that one rider equates to one ride, the analysis should assume that

one rider could equate to 1-5 rides. This will change the potential impacts to the adjacent trail system


Based on the stated time that a ride on the new Summit lift would take and the average downhill

times on Strava for Ferrin’s and Josie’s Ridge, a conservative estimate for a Snow King/Ferrin’s or

Snow King/Josie’s lap would be 30 minutes. This would allow for numerous laps per rider during a

typical day in the summer and more than double, conceivably, triple, the number of downhill trips on

these trails. Currently the Ferrin’s trail sees an average of 68 people/day and Josie’s Ridge an average

of 158 people/day. If an additional 22 riders per day each make 5 extra laps on the Ferrin’s trail, it

will overwhelm the trail and pose a significant threat to uphill traffic.

While the Cache/Game trail system could absorb a limited number of new riders a day, the

Bridger-Teton analysis fails to consider that each rider could take multiple laps via the


In addition to the user conflicts that will result if lift-serviced bikers leak onto the adjacent BTNF trail

system, there will also be a need for increased trail maintenance caused by this increased use. FOP

continues to commit over $200,000 annually to trail building, maintenance, and ambassador outreach

on the BTNF. We are concerned that lift-serviced riders accessing the Cache-Game trail system will

put excessive pressure on our capacity to keep up with trail maintenance and education along this

very popular and well-used portion of the BTNF system.

If the BTNF chooses to abandon the 2015 Cache-Game decision regarding lift-service mountain

bike use on the Summit lift, we ask that enforceable strategies be in place for deterring

“poaching” of adjacent trails BEFORE the downhill trails are built. Snow King will need to

invest the necessary funds to build the physical infrastructure and retain sufficient staff to ensure that

lift riders are cognizant and compliant of the rules. Snow King has said they would implement a plan

to pull passes if people left the resort area on bikes. This can very difficult to enforce without

sufficient on-the-ground resources, similar to how skiers continued to leave the Jackson Hole

Mountain Resort boundaries until finally an open gate policy was implemented.

5. Rehabilitation and Weed Mitigation

Please require proper rehabilitation of trails and roads slated for closure. There is a network of usercreated

and Snow King-created trails that need to be properly rehabilitated before new trails are

constructed. This is a vital part of keeping trail users on the legal and sustainable trails and integral to

the overall health of the forest. Snow King must be held to a high standard of compliance with

invasive species mitigation. Past projects on Snow King have resulted in infestations of noxious

weeds which have quickly spread up the popular Summit and Shade Monkey trails onto the national


Friends of Pathways whole heartedly supports adding new hiking and biking trails to Snow King

Mountain. This aligns with the USFS desires to provide close to home access to the national forest

and concentrate future trail development in places where a high level of impact has been established.

We hope that the BTNF will choose aspects of this plan that improve both Snow King and the front

country trail system while not adversely affecting the overall trail community.

We have included a map of a trail development scenario for Snow King that we believe is best suited

for approval. This was initially prepared as an alternative that was in keeping with the 2015 Cache-

Game Decision Memo but was altered into the current Alternative 4.

Thank you for your support over the years and for your consideration of our comments.


Chris Owen Katherine Dowson

Trails Program Manager Executive Director

Friends of Pathways Friends of Pathways

FOP Proposed Trail Development Map for Snow King Resort