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Comment letter on Teton West Resort and RV Park

Comment letter on Teton West Resort and RV Park

November 4, 2019

Teton County Planning & Zoning Commission

150 Courthouse Drive

Driggs, Idaho 83422

Re:  Teton West Resort & RV Park Conditional Use Permit Permit (CUP) Application

Dear Commissioners:

We find that the application, as proposed, does not comply with Section 8-6-1-B-7 Criteria for Approval of the Teton County Code.

To illustrate some of the reasons behind our findings, we present the following maps detailing the subject property’s location within the Teton County Wildlife Habitat Overlay and the Waterway Corridor designation in the Teton County Comprehensive Plan:

The property lies entirely within protected wildlife areas, including Indicator Species habitat, specifically Big Game Migration Corridors and Seasonal Range, Songbird/Raptor Breeding and Wintering Habitat, and Priority Wetland Habitat – South Leigh: Wetlands/Rare Plants.

The majority of the subject property clearly lies within the Waterway Corridor designation in the Comprehensive Plan.

We find as follows:

a. The location of the proposed use is compatible to other uses in the general neighborhood. The neighborhood is characterized by low-density rural housing, agricultural lands, and critical wildlife habitat. The proposed use is located in the Teton County Wildlife Habitat Overlay, which includes specific Indicator Species habitat, specifically Big Game Migration Corridors and Seasonal Range, Songbird/Raptor Breeding and Wintering Habitat, and Priority Wetland Habitat – South Leigh: Wetlands/Rare Plants. The South Leigh Creek Corridor is key habitat in the overall Greater Yellowstone Ecosystem (GYE), the only intact ecosystem in the Lower 48.  This 107-unit facility, as proposed, will drastically increase human presence and impacts, and the level of intensity proposed far exceeds that of surrounding lands.

b. The proposed use will not place undue burden on existing public services and facilities in the vicinity. We find that this finding cannot be made until a Natural Resource Analysis, Nutrient-Pathogen Study, and Traffic Impact Study are submitted, and the findings thereof clearly indicate there is no undue burden on existing public services and facilities. Failure to provide this information will deprive the P&Z Commission of the factual basis necessary in order to make this finding, and would thus be grounds for denial.

c. The site is large enough to accommodate the proposed use and other features as required by this title. 107 camping units are proposed on 37 acres. These figures are excessive not only by rural county standards, but also due to the fact that the subject property lies within a county-designated wildlife overlay. There is not enough site area to accommodate the proposed intensity at this location.

d. The proposed use is in compliance with and supports the goals, policies, and objectives of the comprehensive plan. The Teton County Comprehensive Plan designates the subject property as “Agricultural Rural Neighborhood” and is within the “Waterway Corridors.”  Appropriate development in the Agricultural Rural Neighborhood is described as “Medium density single family neighborhoods with large open spaces and provisions for clustering,” “amenity-based (residential) neighborhoods,” “well-defined open space areas that connect to provide corridors,” and “clear distinction between residential development and open space/agricultural areas.” This commercial development fails to embrace these characteristics. Furthermore, the subject property lies within the  “Waterway Corridors” designation in the Comp Plan – the desired features of which are “agriculture,” “low tolowest residential density in the county,”  “conservation and wildlife habitat enhancement,” “scenic quality preservation,” and “little to no (or very limited) commercial activity.” The application narrative seems to gloss over the ecology of the site and its surroundings, even going so far as to state that the subject property  “is clear of Waterway Corridors.” This statement is false, and ignores the importance of upland habitat along Teton Valley’s river, creek, and stream corridors.

Given the lack of conformance with the above stated standards, we believe the Commission should recommend denial of the application, or continue this item until the following information is provided:

  • A Natural Resource Analysis prepared in accordance with the processes and standards found in Section 9-3-2-C-2-b Natural Resources Analysis of the Teton County Code.
  • A traffic study prepared in accordance with the processes and standards found in 9-3-2-C-3-d Traffic Impact Study of the Teton County Code. In addition to the standards in 9-3-2-C-3-d, the applicant shall also calculate total Vehicle Miles Traveled (VMT) generated by the development.
  • A Nutrient-Pathogen (NP) Evaluation prepared in accordance with the processes and standards found in Section 9-3-2-C-3-b Nutrient-Pathogen ( NP) Evaluation of the Teton County Code.
  • Application revisions in response to the above.

Please note these studies will simply provide the necessary information in order to make the findings for CUP approval or denial. Simply providing the studies will not make the application more appropriate, as it is significantly challenged by the fact that it proposes city-level intensity in the rural county.

Though the above-mentioned studies are found in Title 9 Subdivisions of the Teton County Code, we find that Teton County may require them for a Title 8 Zoning Regulations Conditional Use Permit pursuant to Section 8-6-1-B-9 Studies; Transferability.

Respectfully Submitted,

Shawn W. Hill

Executive Director

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