The costs estimates for the build alternatives do not include the $52 million (2004) for damages to Swain County . It is erroneous to assume that the 1943 Agreement can be fulfilled without the payment of these damages. The Swain County Commissioners and [organization affiliation omitted] have successfully established in the hearts and minds of all involved that Swain County is due these damages. Public statements by [name omitted], by [name omitted], and Charles Taylor confirm their belief that Swain County is entitled to this payment irrespective of whether a road is built or not. The constitution guarantees that just compensation is required. Calculations have not been performed to determine what the damages would accumulate to in 15 more years.

People everywhere are quoting the $374 million as the new costs for building this road. That is wrong. Your statements qualify this number as specifically not including most mitigation costs. Those mitigation costs will have to be paid. A sound analysis of costs vs. benefits cannot be done without a reasonable accurate estimate of mitigation especially when it can be foreseen that this could be as much as $100 million by itself.

The cost has been substantially underestimated. It is well known that the typical project is underestimated by thirty to fifty percent in the first estimate. In this case the study team acknowledges that the estimate does not include all mitigation and enhancement costs. When the two factors are combined, it becomes clear that the total cost of the project will be far higher than the initial estimate. The Corridor K project for twenty miles of four lane road through the Ocoee Gorge, through similar terrain, is estimated to cost $2 billion. Since the lanes will be terraced, the cost for half the lanes will be about $1 billion. That is the best comparable for this project, and most likely an accurate projection of the true cost. The mitigation cost alone for the pyritic material that will disturbed in the construction of the Corridor K road is $100 million. The existence of this pyritic material is know to exist throughout the corridor of the proposed north shore road but the cost for the mitigation is apparently not included in the estimated cost for this road.

NPS has chosen to include only some of the cost of mitigation in its cost estimate for the construction of the North Shore Road . As a result, it appears safe to assume that the $374 million estimate circulated to the public underestimates of the total cost of that alternative. Park Service policy requires the NPS to institute extensive mitigation for wildlife, wetlands, and unstable geologic conditions, all of which are anticipated within the North Shore Road corridor. MP 2001 also requires that the total cost of a system, facility, or other product will be considered in its planning, design, and construction. Accordingly, the NPS must calculate and include the cost of anticipated mitigation measures in its cost estimate for construction of the North Shore Road .

Given that NPS can predict the use of such techniques to mitigate some of the negative impacts of road construction, NPS must include the added cost of such mitigation in the overall cost of construction.

In addition to being exceedingly damaging to the environment, the road construction options are outrageously expensive — we, the taxpayers, would spend an exorbitant amount of money to intentionally degrade a precious and unique resource.

There are other areas where you need to spend this kind of money, my taxpayer money. Keep up the good work, but don't spend this money in this way.

NPS has underestimated the extraordinary cost of the north shore corridor alternative. In response to questions at recent public hearings, NPS disclosed that its $374 million estimate for construction of the North Shore Corridor alternative reflected mitigation costs associated with addressing acid-forming rock formations in the study area but did not include other mitigation costs, such as avoiding or mitigating impacts to sensitive species habitat or wetlands. NPS has likely underestimated the cost of addressing acid-forming rock formations. Furthermore, the additional mitigation costs not disclosed in these preliminary studies will add significantly to the final cost of constructing the North Shore corridor alternative, and must be reflected in the final DEIS for NPS to evaluate that alternative in the context of its full cost.

The NPS has underestimated the cost of constructing the North Shore Corridor alternative by excluding substantial mitigation costs. NPS has chosen to exclude the cost of mitigation measures (aside from mitigating acid-forming rock) from its costs estimate for the construction of the North Shore Corridor alternative. As a result, the $374 million estimate circulated to the public is a significant underestimate of the total cost of that alternative. This approach violates park service policy, which requires that “[the total cost of a system, facility, or other product will be considered in its planning, design, and construction.” MP at 9.1.1.1. Accordingly, the NPS must calculate and include the cost of clearly anticipated mitigation measures in its cost estimate for construction of the North Shore Corridor alternative.

Park Service policy requires the NPS to institute extensive mitigation for wildlife when constructing a transportation system in a park, including “terrestrial and aquatic wildlife corridor crossings and other accommodations to avoid or mitigate harm to individual animals, the fragmentation of plant and animal habitats, and the disruption of natural systems.” MP at 9.2. The Park Service has recognized the need for such mitigation throughout the project area including wildlife underpasses/overpasses, landscape connectors, bridging and bot tom less arch culverts. 2005 Project Displays (“Natural Resources”). Because these structural mitigation elements are clearly anticipated throughout the corridor, NPS has a reasonable basis for creating an estimate of the additional cost attributable to these measures.

Additional mitigation will be required to avoid wetlands and streams in the project area. NPS Management Directives require the Service to “avoid direct and indirect support of new construction in wetlands unless there are no practicable alternatives,” and to “first consider relocating or redesigning facilities, rather than manipulating streams.” MP at 4.6.5, 4.6.6. Accordingly, NPS has acknowledged that the project will require minor road modifications and/or realignments, restoration/enhancements, bridging and bot tom less arch culverts, and sensitive design techniques. 2005 Project Displays (“Natural Resources”). Although NPS has acknowledged that these wetlands and stream mitigation measures will be necessary, it has declined to include them in cost estimates for construction of the North Shore Corridor alternative, as required by NPS policy.

For all these reasons, the $374 million estimate for construction of the North Shore Corridor alternative is a significant underestimate of the extraordinary magnitude of the cost to construct that alternative.

The extraordinary cost of the North Shore Corridor Alternative far exceeds the benefit of constructing a road which NPS acknowledges is not needed. Given the extraordinary magnitude of the $374 million cost estimate for construction of the North Shore Corridor alternative, a number which is likely a significant underestimate of the final cost, the North Shore Corridor alternative cannot survive the test of reasonableness identified by the NPS for this project because it is neither prudent nor feasible. In exchange for such a significant investment, NPS and the United States taxpayer would achieve only a road which serves no regional transportation purpose, serves no purpose identified by the GSMNP General Management Plan, and provides only incidental and secondary economic benefit to Swain County .

The only potential benefits identified by NPS for the North Shore Corridor alternative are that it “may generate moderate increases in the number of visitors to the study area” and “may have the potential to indirectly provide moderate economic development opportunities for Bryson City and other study area communities.” PAR at 21. As the Great Smoky Mountains National Park is already the most used park in the national park system and already suffers from a funding shortfall and maintenance backlog, increased visitorship is not a significant benefit to counterbalance the substantial cost of the project. Park Service policy underscores this point by making clear that “when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant.” MP at 1.4. In addition, any “moderate economic development opportunities” that might be provided by the project are dwarfed by the cost of the alternative. As explained below, the Monetary Settlement, if properly analyzed, has the potential to create the same or greater economic stimulus to Swain County and, at less than one seventh the costs, does so far more efficiently than the North Shore Corridor alternative.

Because the extraordinary magnitude of the cost for constructing the North Shore Corridor alternative far exceeds the benefits of construction, and because, as is discussed below, construction of the alternative would cause “community or environmental disruption of extraordinary magnitude” and the “loss of irretrievable GSMNP resources,” PAR at 5, the North Shore corridor alternative fails the test of reasonableness identified by NPS for this project and must not be selected as the preferred alternative.

A finished road would parallel the current Highway 28 to around Deals Gap and is a waste of tax payer dollars. Plus, the $300+ million dollar price tag did not include mitigation dollars and is understated. My input in sum, provide the cash settlement and build a heritage museum at the site of the tunnel.

The high estimated cost of the proposed road vs. the financial settlement solution is very high. The country should be looking for all possible ways to reduce expenses in this time of huge soaring deficit spending. The Foothills Parkway in Tennessee has never been completed primarily due to lack of federal funding. How are funds then available for a new road?

Let's talk about cost, D.O.T. is building four lane roads in Swain County and Graham County less than two miles from where the North Shore Road will be built at around Five Million a mile. In Forest Service land just across Fontana Lake in 2002 a twenty foot dustless surface road just like the 1943 agreement calls for was built for just over half million dollars for 1.3 miles. I am tired of hearing the Park Service say ---- one hundred fifty million dollars for the North Shore Road , this is another ploy against Swain County . The North Shore Road will cost around 2 million dollars a mile.

Geotechnical Costs

Since the Park Service is studying whether or not to build a road, an accurate cost estimate is dependent on the results of geotechnical investigations, and so these studies should be completed before a decision is made, not afterward as the Existing Conditions report indicates is planned. P. 82. The presence of acid-producing rocks could substantially affect cost estimates as well as environmental effects analyses in several ways: Acid-producing “rocks, when excavated, would require special handling during all phases of construction, especially if used for fill material.”

Where such rocks are present, “the use of bridging, cantilevered roadways, and ‘top-down' construction techniques in areas where minimal disturbance is necessary” (EC, p. 88) will greatly increase the cost, may alter the preferred route, and may have different effects on the human and natural environment than the route chosen without this information.

The Existing Conditions report lists five techniques that may be used to mitigate the effects of exposing acid-producing rock during construction. See EC, p. 89. It is unclear from the information provided at the public hearings what method of mitigation is preferred or what elements of mitigation are included in the initial cost estimate. The Park's non-impairment mandate would seem to prevent the storage of hazardous material in the Park, so it seems that complete removal offsite would generally be the preferred mitigation technique. The cost estimate seems too low to include this kind of mitigation. In addition, no satisfactory answer was given at the Asheville public meeting when the Park Service was questioned about the environmental effects of this material at the site of landfilling.

The geologic structure of the area must be determined before an accurate cost estimate can be made. Much of the area is in unconsolidated mixtures of clay, sands, gravels, cobbles and boulders. EC 83-84. The unconsolidated substrate will be difficult to build on. “Areas requiring cut and fill designs will require detailed studies of the geologic structures and characteristics to minimize stability issues.” EC, p. 88. Indeed, this unconsolidated material is what led to the abandonment of the original construction attempt. See Report of the Technical Committee for the Completion of the Bryson Fontana Road Construction Great Smoky Mountains , Exhibit A.

NPS has likely underestimated the cost of mitigating acid-forming rock for the North Shore Corridor Alternative. As noted in the Existing Conditions Report, 99% of rock formations in the project area, “have acid-producing potential with an extremely low acid-buffering capacity.” ECR at 86. The Copperhill Formation, in particular, which “dominates the study area,” is a “serious acid-producing formation.” ECR at 87. Rock formations west of Hazel Creek , which would be disturbed under the North Shore Corridor alternative, “have the highest potential for acid production and are likely to contain higher concentrations of metallic minerals than the surrounding rocks.” PAR at App. B. Even in their current undisturbed condition, these rock formations are having detrimental impact on water quality in the study area. Sediments along the mouth of Hazel Creek show an elevated increase in copper content and stream and spring samples in the Wehutty Formation contained pH values as low as 2.7.ECR at 86.

The Existing Conditions Report identified a range of options that would be employed to mitigate the impacts of excavating acid-forming rock formations including removal offsite, blending, treatment, encapsulation, and implementation of an engineered drainage system. ECR at 89. Although the NPS asserts that the cost of these mitigation measures is reflected in the cost estimate for construction of the North Shore Corridor alternative, no information has been provided as to the relative cost of the respective mitigation measures or the extent to which each will be employed throughout the study area. Depending on the assumptions applied, NPS may have dramatically underestimated of the final cost of construction. Furthermore, although information released reveals that construction will generate 400,000 cubic yards of material in excess of the fill capacity for the project, it is not clear that the cost of hauling away and properly disposing of that acid-forming rock has been reflected in the project costs. Neither is it clear whether NPS has considered the future cost of continuous liming of streams and exposed rock surfaces, ECR at 89, as required by NPS policy. MP at 9.1.1.1 (total cost of new facility must be “computed over a product's or system's useful life”).

Nor has the NPS released any information suggesting that it has considered the additional construction and mitigation costs associated with unstable geological conditions in the project area. The NPS has identified quaternary deposits, which can cause mass-wasting events, in the Eagle Creek area. ECR at 83. NPS management directives require the Service to site facilities “where they will not be damaged or destroyed by natural physical processes” including “unstable soils and geologic conditions.” MP at 9.1.1.6. Again, although mitigation measures to address unstable soils have been identified by NPS and are required by NPS policy, NPS has failed to reflect such measures in the cost estimate for construction of the North Shore Corridor alternative.