This commentary is by Galina Chernaya, a resident of Goshen.
The submission window for formal public comments regarding the Moosalamoo Association and Vermont Huts Association proposal to construct and operate, under a special use permit, a year-round, propane-powered overnight hut for 10 people by Silver Lake closed on July 11.
More than 400 comments were received by the Forest Service Rochester/Middlebury ranger office.
Opposition letters from individuals and organizations — including Vermonters for a Clean Environment, Standing Trees, Vermont chapter of Backcountry Hunters and Anglers, to name a few — outnumbered pro-hut by over 50% (242 vs. 158, respectively).
Chris Mattrick, the Rochester/Middlebury district ranger, was expected to make a decision on the proposal by the end of September. However, due to “higher priority projects,” the decision has been delayed to the beginning of 2023.
The delay allowed for a more in-depth look into the Green Mountain National Forest policies guiding screening, processing and authorization of special use permit applications such as the Moosalamoo and Vermont Huts proposal. In addition to shortcuts that have been already revealed (see, for example, Annette Smith’s commentary on behalf of Vermonters for a Clean Environment), additional shortcomings have become clear.
The proposed use violates a number of the policies established in the Forest Service Manual under “privately provided recreation opportunities.”
Just to give one clear example of the violation is policy 2343.03:
“[a]uthorize concession development only where there is a demonstrated need. Do not permit concession development either solely for the purpose of establishing a profit-making commercial enterprise or where satisfactory public service is or could be provided on nearby private or other public lands.”
There is no demonstrated need for a profit-making lodging in the Silver Lake area, which is located within the Green Mountain National Forest’s Moosalamoo National Recreation Area. The forest service has not completed and documented a needs assessment, in consultation with interested members of the public, as required by the manual.
Moreover, the 2006 Green Mountain Forest Plan also does not identify any need, or desired condition or objective, to provide a profit-making lodging in the Silver Lake area or anywhere else in the Moosalamoo National Recreation Area.
The plan clearly states: “Special use authorizations should be issued only when there are no private land alternatives, or when the use has a clear and significant public benefit.”
Instead of demanding the applicants, Vermont Huts and Moosalamoo associations, evaluate alternatives and provide clear rationale for proposing a profit-generating lodging on unspoiled-by-development Silver Lake, the forest service readily accepted the Vermont Huts dismissive answer to a permit application question:
“C. Give explanation as to why it is necessary to cross federal lands.”
“Because Silver Lake Hut would be on federal lands, the hut, by default, would be located on federal lands at this location.”
In another document submitted as part of the application package, Vermont Huts and Moosalamoo provide the following reason for selecting Silver Lake: The board members also visited the Moosalamoo Campground to evaluate an old log landing on the north side FR24 B (road to Voter Brook) as a potential hut site. While the site itself could likely host a hut, the location did not feel right in our minds … “(G)iven the alternative at Silver Lake, this site pales in comparison.
It’s clear that Silver Lake fell victim to its own beauty. There are 16,000 acres in the Moosalamoo National Recreation Area with plenty of potential sites that could meet the proposal’s purpose and need. The forest service should deny the proposal that lacks a fair and unbiased evaluation of alternatives.
As a side but relevant note, I would mention that projected “hut” construction cost of $290,000 continues to shock the public. Depending on a source, median house value in Addison County ranges between $219,000 and $257,000 in 2022, meaning that over 50% of Addison County residents live in houses valued lower than the proposed “hut.”
Everyone who has recently visited the Grout Pond in Stratton has noticed a huge “hut” being constructed there by the Vermont Huts Association. Almost the exact same design is being proposed for the Silver Lake location. Once again, a need for such an expensive luxurious lodging is not justifiable.
I would like to conclude by stating yet another forest service regulation governing special use authorizations, 36 CFR 251.51:
“Major category — a processing or monitoring category requiring more than 50 hours of agency time to process an application for a special use authorization … . Major categories usually require documentation of environmental and associated impacts in an environmental assessment and may require an environmental impact statement.”
It is obvious that Rochester/Middlebury District Forest Service employees have spent much more than 50 hours of agency time processing the Vermont Huts/Moosalamoo proposal, just since the public learned about it on March 28, 2022.
If the forest service insists on further wasting taxpayer funds and human resources on the Vermont Huts/Moosalamoo proposal by conducting additional planning and analyses, the forest service must prepare an environmental assessment or and environmental impact statement, as required by the Code of Federal Regulations.
