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Comment letter on Moose Creek Ranch Expansion

Comment letter on Moose Creek Ranch Expansion

August 6, 2019

Teton County Planning & Zoning Commission

150 Courthouse Drive

Driggs, Idaho 83422

Re: Moose Creek Conditional Use 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. We find as follows:

  • The location of the proposed use is compatible to other uses in the general neighborhood. The neighborhood is characterized by low-density rural housing, public lands, and critical wildlife habitat. The facility as proposed will drastically increase human presence and impacts. The existing Moose Creek Ranch facility is ample, and uses with the intensity proposed should be located away from critical wildlife habitat in the rural areas of the county. 
  • 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. 
  • The site is large enough to accommodate the proposed use and other features as required by this title. The 20-acre site is proposed to accommodate up to 207 guests and nearly 100 structures. 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. It is also a stone’s throw from the Jedediah Smith Wilderness boundary. There is not enough site area to accommodate the proposed intensity at this location. 
  • 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 “Foothills” the desired features of which include “Low residential densities with provision for clustering/conservation development,” and “conservation and wildlife habitat enhancement.” It is also included in the “Waterway Corridor,” the desired features of which include “low to lowest residential density in the County,” “conservation and wildlife habitat enhancement,” “overlays and development guidelines to protect natural resources, and “little to no (or very limited) commercial activity.” In our view, the Comp Plan is abundantly clear that the use is inappropriate at the level of intensity proposed.

Given the lack of conformance with the above stated standards, we believe that 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.

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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