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Comment letter on the Highlands Campground & Event Center

June 6, 2017

Teton County Planning & Zoning Commission
150 Courthouse Drive
Driggs, ID 83422

Re: Highlands CUP Application

Dear Planning & Zoning Commission

Thank you for the opportunity to comment on the Highlands CUP permit application. As you may know, Valley Advocates has been supportive of recreational uses as a means to promote economic development that is environmentally sensitive and otherwise meets Comprehensive Plan goals. Examples include the Taylor Family Campground and the National Outdoor Leadership Facility in Darby. However, this application does give us some pause in regard to the nature and intensity of the use. Our reasons are as follows:

1.  The application is ineligible to be considered as “Dude Ranch.” Among other standards, dude ranches are only permitted if a) they occupy a parcel of at least 20 acres and b) there is a maximum guest density of .5 guests per acre. This proposal proposes up to 28 guest rooms/camping sites on 13.75 acres. Thus, the use as proposed cannot be considered under the Dude Ranch criteria.

2.  When considered as a “Campground, RV Park, Travel Trailer Camp,” it is unclear how eight (8) executive suites can be permitted within the proposed “Barn Lodge” structure. Title 8 defines “Campground, RV Park, Travel Trailer Camp” as “a parcel of land…within which spaces are rented or used by the ownership for occupancy by two (2) or more recreational vehicles and may include tent sites, cabin sites, or travel trailer sites for nightly or short-term rental.” There is no mention of lodging suites or rooms within a structure. In our opinion, lodging rooms or suites can only be considered as “Bed and Breakfast” or “Hotel/Motel.” Bed and Breakfasts in the A-2.5 zoning district are allowed a maximum of 3 guest units, and Hotels and Motels are prohibited entirely.

3.  The proposed use does not likely meet Conditional Use Permit standards, which are as follows:

A.  The location of the proposed use is compatible to other uses in the general neighborhood. Neighborhood character is well-established as a rural residential/agricultural neighborhood with significant environmental features (as has been documented in the 2007 Natural Resource Inventory submitted with the original Highlands Subdivision plat). A cursory glance of the surrounding area indicates that it is dominated by agriculture and very low density residential uses. Permitted and conditional uses, the latter of which have been partially listed above, clearly indicate that only low-intensity residential uses are allowed, and that any non-residential use must tread lightly. This application proposes up to 28 lodging units and 4000 SF of commercial event space – a level of intensity that, in our view, is appropriate only in the valley’s cities and not the far reaches of the rural county.

B.  The proposed use will not place undue burden on existing public services and facilities in the vicinity. At the time of writing, no comments have been published from the Department of Environmental Quality (DEQ). This is crucial to determine sewer/septic capacity. However, because the application contains no details about the frequency of events, the number of persons persons permitted at events, the total number of potential lodging guests, or other fundamental project components, DEQ and other reviewing agencies are likely not in a position to comment. This information is also necessary to determine impacts to area roads, and a use of this intensity warrants a traffic study to determine road impacts.

C.  The site is large enough to accommodate the proposed use and other features as required by [TItle 8]. Given the parameters set by similar use standards in Title 8 (i.e. bed and breakfast, dude ranch), it is clear the site is not large enough to accommodate the proposed use.

D.  The proposed use is in compliance with and supports the goals, policies, and objectives of the comprehensive plan. We note that the Comprehensive Plan supports recreation-based economic development – but not to the detriment of our cherished rural character or globally-significant natural environment. Economic Goal 3 of the comprehensive plan states that Teton County should “recognize that tourism and lifestyle are fundamental components of our economy and are dependent on healthy natural resources,” which is undergirded by Policy 3.2, stating we should “conserve Teton County’s natural resources in order to enhance economic development.” It is worth noting these are economic development goals and policies; the Comp Plan otherwise speaks volumes on the need to preserve and protect our natural environment. Moreover, the Comp Plan strongly supports development of this intensity being placed in the cities not only to promote vibrant downtowns, but to protect the rural character that defines the Teton Valley community.

We also would like to note that Teton County has had ongoing issues with another event facility in the rural county, the BYU-Idaho Outdoor Learning Center (OLC) in Badger Creek. Though we acknowledge the OLC is a legal nonconforming use, it has been the subject of ongoing neighbor complaints and code enforcement inquiries by Teton County. It should be a stark reminder that opening the door these types of intense, non-residential uses in the rural county will likely have deleterious impacts – and will likely create headaches for all involved.

Finally, we note that the applicant’s site plan is labelled as a “Concept Master Plan Worksheet.” We appreciate the applicant’s creativity in exploring the economic benefits of this stunning location, but the “worksheet” seems endemic of the entire application: a fleeting idea that does not withstand the due social, environmental, and cultural considerations of the neighborhood and the larger Teton Valley community.

Given the reasons stated above, we urge you to deny the Conditional Use Permit application.



Shawn W. Hill

Executive Director

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