The material presented so far shows that the study team has failed to take an overview of the impact of the road on the park as a whole. We believe that when the entire park is considered as a single unit, the proposed road severely reduces the integrity of the park.
The study so far has not evaluated the large, unfragmented north shore for its present worth as a place where biological evolution is ongoing, and where gene pools of inestimable value are protected. Worse, in our estimation, is the failure of the study team to evaluate the potential of this extremely large unbroken tract in terms of changes in the ongoing evolution. Nor has it evaluated the impact the road could have by interrupting and impeding the ongoing natural processes.
The park is increasingly becoming an island in a sea of development. The edges of the park are hemmed in by commercial and residential development at Gatlinburg, Pigeon Forge and Cherokee. US 321 along the northeast boundary is being expanded to five lanes. Other roads border most of the park, either outside or just inside it. These barriers to plant and animal movement have hardened the edge. The north shore of Fontana Lake is one of the few places where the boundary still has a soft edge. Hardening this edge with a 38 mile road would nearly complete the walling-in of the park.
An important example of this growing problem exists on the Tennessee side of the park where the Tennessee Department of Transportation (TDOT) has begun the process of widening US Highway 321 along the northern boundary of the Park. That particular project has met with such widespread public opposition that TDOT is now involved in a process to improve the plan so that the road project has less adverse impacts on the park and surrounding communities. The expensive 321 debacle stands as an important lesson on how to build a road along the edge of the Park and serves to highlight the adverse impacts associated with creating a hard edge for the Park. NPS must avoid that same mistake resulting from construction of the North Shore Road
The area of the park reaching from the north shore of Fontana Lake to the ridge crest and down the north slope is the largest unfragmented tract of mountain land in the eastern United States. It will detract from the park as a whole to put a road through it. Construction of a road here will create a bad precedent that it is acceptable to slice open large habitats that it is acceptable to reduce them in size for insignificant reasons, and that such rare large tracts in the east do not have natural values worth saving. We find this to be false reasoning, and believe the study must justify beyond any question the overwhelming necessity for the destruction this road will cause.
A 1962 National Park Service study of the proposed road concluded that the construction of the road would have severe negative environmental ramifications on the landscape.
NPS recognizes that GSMNP is one of the most bio-diverse places in North America. The incredible variety of wildlife that finds sanctuary in the Park does not recognize any kind of jurisdictional boundaries. It is well documented that habitat fragmentation has many negative impacts on the diversity of wildlife.
Despite the significance of fragmentation to forest interior species, nothing in the information released by NPS suggests that the Park Service has conducted a fragmentation study for the North Shore corridor and other build alternatives. Such a study is critical to NPS' ability to evaluate the cumulative impacts of construction on interior forest species. In particular, NPS has offered no indication that it has considered the biological consequences of creating an orphan tract of land between the North Shore Road and Lake Fontana that is divided from the rest of the park on both sides. Creation of such a tract is inconsistent with MP 2001 section 4.1 requiring NPS to manage ecosystems to “preserve fundamental physical and biological processes, as well as individual species, features, and plant and animal communities.”
As a Biology, Wildlife Management and Environmental Earth Science teacher working in the public school systems of several states, for over twenty years I have been teaching students the importance of a sustainable life style. I want them to learn to live within the ecological budget of Earth. The quality of life for the present and future generations depends on keeping the life sustaining diversity of our complex life systems healthy. Although there are some impressive self-maintaining dynamics at work to stabilize these systems, there are limits to their ability to correct for continued stress. The geological record is full of evidence showing sudden drastic upheavals and ecological disasters. We have no valid reason to believe that we humans with our huge powers to alter the climate and ecosystems will not trigger another watershed shift in the world's balance that will result in condition that renders the Earth unsuitable for human life, or that degrades the quality of our existence to a much lower level. It is our duty as the most powerful species to exist on this planet to use our might to protect the integrity of our life support systems for the benefit of all living things, to do anything is the extreme in narrow minded, short sighted self indulgent stupidity.
We don't wish to make any comments re: the environmental impacts of this road, assuming there are better and more informed people and organizations that can do so. However one question persists: How does one mitigate (and at what cost) for the loss of species and the road crossings over 100+ streams, especially when your (NPS) primary mission is to preserve these natural resources.
If the road is built, it will irreversibly damage the natural environment in the massive cuts and fills by leaving scars. Wildlife and plant habitat will be disrupted. It will open up the south side of the Smokies to increased poaching. I have personally encountered hunters inside the Park near Deals Gap while hiking.
You may already have prepared an environmental impact statement, so I need not detail here every unfavorable consequence. I will mention a few: An impact on a roadless area in the national park, decreased water quality and damage to fisheries, flora and fauna as a result of newly exposed acid-bearing rock--the reason construction of the road was halted in the 1960s.
I am unable to attend any of the comment workshops for the north shore road. However, I feel very strongly that this road will be a disaster for the park and the western region of North Carolina. I think it is critical for you to consider the irreparable damage that will be done to Fontana Lake as well as to the entire south boundary of the part if this road is constructed. Construction of the road will devastate the trout fishing and ruin the water quality of the lake. The construction will also increase air pollution that is spewed into the forest from the construction equipment. And of course, there will be great negative impact from the construction on the wildlife in the park. Even after construction is completed, all of these negative impacts will continue in perpetuity.
This letter is to express my opposition to the completion of the North Shore road in the Great Smoky Mountains National Park. While it is regrettable that a promise made to the people of Swain County, NC in 1943 was not kept, the environmental damage that would be caused by the completion of a “road to nowhere” today is unacceptable. The south side of the smokies is one of the largest roadless areas in eastern North America, and provides wildlife habitat, fisheries, and solitude to those willing to make a hike into the backcountry. The original purpose of the road is moot today, with NC Highway 28 providing access to Deal's Gap and the state of Tennessee. Construction of the road would cause degradation of water quality in Hazel, Eagle, Forney and other creeks it would cross, through exposure of acid-forming rocks. This occurred when the Cherohala Skyway was built between Robbinsville, NC and Tellico Plains, TN several years ago — some streams affected by that action are still devoid of fish.
The cost estimate for the full build alternative understates the true cost and environmental impacts that constructing a road in this terrain would involve. This area contains the largest roadless tract remaining in the eastern US. Building a highway corridor through this very sensitive and biologically significant publicly owned land would destroy one of the most ecologically important areas remaining on earth. It has been designated a world biosphere reserve because of the unique characteristics that result from the fact that, up until this point, it is of sufficient size to allow biological processes to occur without the intrusion of man.
That road will do more harm to the Smoky Mountains environment than we can only imagine. By opening up that area to auto traffic, I can look into the future and see the ATV tracks as poachers go after the animals and plants that will be there for the taking. The black bears need a place to roam where they are unmolested. We need to save some of the environmental diverse areas for future generations.
The environmental damage that would result from construction of this would makes this project preposterous. For example: This park is already one of the most polluted in the country. The pollution which fouls the air in the park is already the cause of severe asthma and respiratory health problems for residents of Western North Carolina, so why promote a scheme sure to increase this problem. Do we really care so little for our children and seniors most vulnerable to this air pollution?! The area which would be affected by this road should have been designated as a “wilderness area” years ago. The displacement of wildlife which would result would be tragic. We need to save some portion of our country for creatures who have been crowded out of their natural habitats and into areas set aside for them. The release of acidic runoff due to construction could poison the lake, destroying fish and causing great economic loss to those who value the lake for its recreational opportunities.
I am strongly opposed to any of the proposed alternatives that involve road construction. Such construction would irreparably harm our dwindling populations of native Southern Appalachian brook trout and destroy unique and critical wildlife habitat, violating the very purpose of the Great Smoky Mountains National Park.
This is to strongly request that you do not continue building the north shore road because of many reasons: It will be a tremendous environmental disaster for decades to come and the governor of North Carolina has informed the Department of the Interior that he would support payment in lieu of the road construction. There are several alternatives to this we understand.
As a person concerned about the environment and conservation, I am very concerned that the new road will be harmful to the plants and animals that live in that area of the park. Road kills and fracturing of habitat will effect both great and small animals. Acid runoff is highly probable from the excavations and will poison the creeks and kill fish.
NPS has identified as a goal for this project the protection of “the significant and diverse natural resources and ecosystems of the park,” PAR at 3, and has stated an objective of protecting “federally-listed threatened and endangered species and their habitats.” PAR at 4. These project goals are consistent with NPS policy which mandates that “natural resources will be managed to preserve fundamental physical and biological processes, as well as individual species, features, and plant and animal communities.” MP at 4.1. The Management Directives further provide that the Service “will not attempt to solely preserve individual species” but rather “all the components and processes of naturally evolving park ecosystems.” MP at 4.1. These policies require selection of the Monetary Settlement alternative as the preferred alternative for this project because construction of the build alternatives would cause substantial negative impacts to individual species and to park ecosystems.
There is no doubt that road traffic would destroy the pristine Landscape and forest ecology with increased amounts of vehicular emissions and human refuse - already serious problems in the Great Smokies due to extremely high human traffic.
To me, it is incredible that this issue is even being studied. When the road building would take place, the anakeesta will leach into the lake and kill all aquatic life. This lovely area has such a rich biodiversity, probably the most pristine area in the east. How could we possibly think of putting a road in it to devastate it? I hiked the area today and saw such deep ravines that it is impossible to imagine the cost of various bridges across them and to think of the beautiful rhododendron, mountain laurel, conifers, and hard woods that would be sacrificed.
What right do you have to change Mother Earth in what and how she does what she does? Are you that much bigger and badder? Remember this, we are only borrowing our Mother Earth from our grandchildren, it is our responsibility to return her in better condition than we received her.
I am a recently retired Forest Service worker. I know how roads can and will devastate the forested landscape and the fish/wildlife that live there.
The road would not damage a thing in the park. It would not hurt the bugs, lizards, spiders, birds, plants, or owls. It will not hurt the fish in the creeks, because the park service has already been putting poison in the streams to kill the rainbow and brown trout.
It will be a tremendous environmental disaster for decades to come and the governor of North Carolina has informed the Dept. of the Interior that he would support payment in lieu of the road construction. There are several alternatives to this we understand. We support a cash settlement for Swain County, rather than impinging upon wild lands.
I am opposed to any further construction of the proposed " North Shore Road " project in the Great Smoky Mountains National Park. This road would be extremely detrimental to the National Park and would decrease the immediate and long-term value of the area. Construction in the proposed area would cause great environmental damage, regardless of attempts at mitigation, through exposure of acid containing soils and rock, through erosion and siltation of streams, and through destruction of the wilderness character of this relatively remote region. The Great Smoky Mountains National Park is our most heavily visited National Park and desperately needs and deserves protection to maintain the intended characteristics.
The proposed road is pointless and will only have negative effects. One such negative effect: the Appalachian strain of brook trout makes its home in the streams of the park. A road will create more runoff which could raise the water temperature from the heated water running off from the pavement in the summer, and also putting more sediment into the streams. In addition, old tree growth will be taken away. I urge you to instead negotiate a cash settlement with Swain County. This is what the overwhelming majority of people want. Do not take away from the beauty of the best National Park on the East Coast.
With the impact of construction affecting so many "new" species, I think it would be unreasonable to disturb that habitat.
There is also concern on my part as to what effect another road will have on the ecosystem in the area. Wildlife is extremely fragile in some parts of temperate forests.
The construction of the North Shore Corridor has already been documented to be incredibly environmentally damaging to the natural resources of that area of GSMNP. Area wildlife and plants would suffer tremendous damage. GSMNP is the largest unfragmented forested area left in the Eastern US. Opening the area up with any new roads will only encourage more future development of the area, introduce pollution, increased crime, etc.
The two sons my wife and I have produced are the most important things in my world. We have done everything to raise them to be strong and healthy. We have tried to equip them to enjoy their lives to the fullest extent while making a substantial contribution to the quality of life of others. They are sons to make us proud. Now it is my job to do my part to see that they, and their future children, and all their children's children have a quality existence as well. The love I feel for my sons demands that I do nothing less than give this effort my full persistent attention. I am asking you to consider, do you have people in your life that mean this much to you? Will you do your part to make sure that all our children will have a future full of interesting creatures, clean water and pure air? Please help me for the sake of all of our children.
Threatened and Endangered Species
The Park is one of the most biologically diverse regions in the world and contains the richest flora and fauna of any temperate area of comparable size anywhere on earth. This is evident in the Park's status as the core unit of one of America's few International Biosphere Reserves and its designation as a World Heritage Site in 1983.
GSMNP, p. 4. Strategic Plan for 2005-2008. The Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.) requires that the Department of Interior “insure that any action authorized, funded, or carried out by [it]. . . is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species.” 16 U.S.C. 1536(a)(2). In addition, the Department must “seek to conserve endangered species and threatened species and shall utilize [its] authorities in furtherance of the purposes of [the Endangered Species Act].” 16 U.S.C. 1531 (c)(1).
NPS has not conducted an adequate survey of the project area to identify species that will be adversely affected by a build alternative. NPS has stated at recent public hearings that its entire biological resources inventory was conducted over a period of several months. Such a survey is inadequate to identify species that could be adversely affected by construction in the project area. At the most recent project meetings, NPS identified 2 federal species of concern identified in the project area and 3 species listed as rare in North Carolina. This survey identified substantially fewer federal species of concern than would be expected from previously reports described in the Existing Conditions Report. In the Existing Conditions Report, NPS identified 13 federal species of concern that had been identified in or near the project area. ECR at 158-61. The Existing Conditions report also identified 11 species listed as rare by the state of North Carolina that previously had been identified in or near the project area.2 ECR at 165-66. Most alarmingly, the Existing Condition Report identified three species listed as endangered or threatened that previously had been identified in or near the project area but were not identified by the biological survey. ECR at 148.
The disparity between species identified by previous reports and species identified by the biological resources inventory calls into question the adequacy of the biological resources inventory conducted for this project. At a minimum, a full year-round survey must be conducted to ensure that NPS has identified all rare species in the project corridor and adequately identified potential impacts to those species that would result from construction of a build alternative.
Terrestrial Resources
The theoretical provision of culverts with natural floors, and animal culverts and overpasses is not adequate, and does little to mitigate the effect of severance on this habitat. There has been no design of these mitigation measures into the plans. Nor has there been any study of or recognition of the fact that channeling animals into narrow corridors itself is a damaging impact on them. There has been no recognition or evaluation of the limitations on use of overpasses and underpasses by reptiles, amphibians and invertebrates.
Roads are generally dangerous to wildlife. According to [organization affiliation omitted] a million vertebrates a day are killed on roads. Many species avoid roads, which in turn reduces their habitat. Many smaller animals, such as salamanders, are incapable of crossing roads. This road would cause much needless death to species which now inhabit the space in peace. This effect has not been fully considered in the study.
I'm concerned about the effect on the animal population because I've experienced that by helping in the park with the deer population and the fact that now they kill more bears because they're coming down -- because of, you know, they're building in there in their terrain around here, and so they're coming into places with people and -- so they're letting them kill off a lot of the bears. There's roadkill a lot of places and I'd be concerned about that. Somebody was talking about the birds, you know, the noise quality with nesting birds and how they can, you know, communicate and do their thing. What else? I don't know. I can't think of anything else.
It is also well documented that road construction directly impairs wildlife populations as animals are hit and killed by vehicles. Vehicles traveling on Americas 3.9 million miles of roadways kill a million vertebrates every day, according to [organization affiliation omitted]. That list includes bear, elk, bobcat, dear, turtles, snakes, salamanders and even birds such as bald eagles and owls not to mention the countless insects that are killed. A road would cut across the migratory routes of these animals which have to move through their territory to satisfy biological needs. NPS must conduct a comprehensive analysis of the negative impacts to park resources that will occur as a result of this wildlife death.
Of course road engineers are beginning to design roads utilizing techniques such as wildlife underpasses to cutdown on roadkills. Of course these techniques are useful only to roving mammals such as bear and deer and are useless to most reptiles, amphibians, and invertebrates, or plants dispersing seeds. NPS must address how impaired movement of these other types of wildlife will be mitigated if the road is constructed.
Plants, of course, cannot travel by overpass or underpass. They require the unbroken habitat they now have.
Road building invariably causes a reduction in wildlife and its habitat, most notably the regions' black bear and elk populations, which require large blocks of non-fragmented, undeveloped wilderness to survive.
Neotropical Migratory Birds
Road construction inside the park will seriously degrade the habitat for neotropical migratory birds. It is well known that these birds avoid the edges created by roads, and will nest only deep within the forest. A road will reduce critical habitat for these birds by a strip much wider than the road footprint. In addition, the road will open a corridor through neotropical migratory bird habitat that is attractive to predators and parasites, especially Crows and Brown-headed Cowbirds. Neotropical migratory birds are declining in numbers and are in need of extra protection, not attack by habitat fragmentation. The potential for this damage has been noted, but neither adequately studied nor quantified.
It is well documented that the health of certain neotropical migratory bird populations that exist in the Park are impaired as predators and nest parasites which are common in the study area such as cowbirds are provided access to the interior of the forest. Opening forest for road construction increases forest edge habitat, which is the favored habitat for cowbirds.
Invasive Exotics
Any road will result in increased spread of exotic species and will increase the danger from introduction of new exotic species. These dangers have not been adequately studied.
Agencies must not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.
Executive Order 13112. In the Existing Conditions report the Park Service lists the invasive exotic species likely to occur in the project area, see EC, pgs.146-147, but does not indicate a plan to study how the proposed alternatives will affect the introduction or spread of exotic invasive species in the project area. This is unacceptable.
With an inadequate budget the NPS now spends several thousand dollars each year in an unsuccessful attempt to control exotic plant species.
NPS has yet to fully analyze the impact of road construction on many aspects of forest health. It has been well documented by the U.S. Forest Service that increased human access resulting from road construction is a factor that greatly increases the chances of both accidental and
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