Great Smoky Mountains National Park BannerNorth Shore Road Banner
 
Submit Comments Great Smoky Mountains National Park Home National Park Service Home Federal Highway Administration Home
 
Prior Concepts PDF Document
" "
Purpose & Need PDF Documents
" "
Planning Process PDF Document
" "
Impact Topics PDF Document
" "
Public Involvement PDF Document
" "
Goals & Objectives PDF Documents
" "
Study Area Location Map PDF Document
 
" "
" "
Great Smoky Mountains National Park Photo
   

 




" "

IMPAIRMENT

<Back

 

Flabbergasted is the feeling we have when it is quoted by the NPS “none of the alternatives would harm the integrity of GSMNP or resources or values.”

I was absolutely appalled that the DEIS could state that no alternative would adversely impact the GSMNP. That is a scientific impossibility and completely contrary to the facts presented in the report. It is obvious that the government contractor has allowed their desire to gain favor with Representative Taylor cloud their supposedly unbiased assessment.

And yet, after pages and pages of the DEIS, this document's findings of major adverse, long-term or permanent impact to everything, from land and visitor use, to impacts on air quality, water quality, to aquatic and terrestrial wildlife, the DEIS finds that the northern corridor will not cause impairment or harm to the integrity of the GSMNP. We do not understand the logic or the rationale behind this conclusion.

Environmental laws enacted since ‘43 says a study has to be made. Well, the DEIS has been completed. It has studied every aspect imaginable from every angle very thoroughly. And for the first time ever, proper respect and credibility has been given to the cemeteries and decoration days, which are a great part of our culture. Category after category was named, from the water to the air to the sounds, the animals and so on, and over and over the DEIS states that, based on the information obtained to date, none of the alternatives would harm the integrity of the park or the Appalachian Trail.

The NPS's statement in section 4.9.2 of the DEIS that “The Northern Shore Corridor is not anticipated to cause impairment to either GSMNP or the AT based on the information obtained to date.” is absurd.

A road by definition impairs the integrity of the park. It is permanent. The proposed road alternatives will reflect a decision to damage the park and destroy the right of future generations to enjoy an unimpaired natural environment.

When reading through the DEIS, time and time again the analysis of impacts by road construction point to: “adverse, long-term impact on land use in GSMNP.” And this assessment is made in regard to a whole host of important land management considerations that would ultimately seriously impair the biological integrity of this park; a site that has been recognized as a world biosphere reserve. Listing just a few of these more important negative impacts gives one serious pause and should make it clear to all of those concerned with the viability of the Great Smoky Mountain National Park, that this road should never be built.

In the DEIS the park service states that it has been determined that major adverse impacts on the park will result from any of the construction alternatives and many of the impacts would be permanent. The corridor would open up a potential wilderness area, a 5000 acre area. In conclusion, it is stated that none of the alternatives would harm the integrity of GSMNP. This conclusion is without doubt ridiculous, inconsistent with the findings when you consider the impact analysis data in the DEIS.

There is absolutely no way to reconcile the adverse and permanent effects documented in the DEIS with the outrageous and self-impeaching conclusion that follows.

The thing that I feel is inexcusable and really irresponsible is the conclusion that the Northern Shore Corridor is not anticipated to cause impairment to either the GSMNP or the AT, based on the information obtained to date. Using the logic that seems to guide this determination, anything short of complete destruction of the park would not be interpreted as impairment, though page after page in the draft EIS of findings of major adverse long-term or permanent impacts to numerous park values. There is a very large body of law policy precedent to guide determination of impairment that seems to be ignored in this draft EIS, and it's a glaring error.

I don't think there's any question about the environmental damage. I think the studies that have been made, pursuant to this $16 million output, make that fairly clear. I don't see how they could possibly argue that the damage to the environment is not going to be severe because it will be, regardless of which option is chosen.

This study has been determined to have the most severe impacts on the park. However, the EIS also states clearly that, with the appropriate avoi dan ce, minimization and mitigation, that this does fit within the objectives of the EIS.

The document we're here to discuss today leaves no doubt as to the level of harm and impairment a 34-mile road poses to the national park. Despite the strange conclusion of no impairment, the rest of the 500-page document outlines the threat to the North Shore back country.

At best this sounds contradictory. How it can be said on one hand that construction of any kind would result in adverse impacts to all of the communities, ecological, cultural, aesthetic and recreational and then turn around and say that construction is not anticipated to cause impairment to either GSMNP or the AT. If you turn over a shovel of dirt, move a rock, divert a stream or cut down a tree you have impacted and impaired the GSMNP. The decision to build this road should not come down to semantics, it is to important and when built it, can not be un-done.

But the way I read this environmental impact thing, if I read right, it says on the environment analysis none of the alternatives would harm the integrity of the GSMNP or the Appalachian Trail .

But as I read the DEIS summary, all 40 pages of it, I was struck by how many times adverse effects were found for the build alternative. And so, I was trying to sort it out and I went to the table and I know it's hard to see, but on the monetary settlement there is one adverse effect listed. I'm very visual, so if you can look, all of this pink highlighting is the adverse effects under each one of the road alternatives. All you have to do is look and see what the conclusion should have been for nothing.

We're also concerned with the conclusion of the DEIS that says that all of this would have no long-lasting environmental damage to the park, and yet there is page after page that documents the environmental impact, piece by piece, of what will transpire if we build this road. The illogical inconsistency between the data contained in the statement and the conclusion need some investigation.

The conclusion of the DEIS is irrational… The disconnect between the admitted impacts of road construction and no impairment is a wide gulf. It leads one to believe that no scientific study of the connection was made, or that the science used was flawed. No reasonable person could make such a leap of analysis. Thus the conclusion appears to be arbitrary and capricious. The conclusion is not based on facts or the application of good science, or the application of logic.

The impairment standard is not met in the DEIS. The bold faced conclusion that there will be no impairment is not articulated by any analysis or attempt at logic. It is pulled out of thin air.

The north side of Lake Fontana is not a pristine wilderness but it has been virtually untouched for the last 60 years. The forest has grown back, the houses once in the area are gone, and the old roads now serve as hiking trails. A variety of animals live in the area and have uninterrupted access to the lake and the streams flowing into it. The DEIS lists a number of effects from building a road across the area and then maintains there would be no environmental effect. This conclusion seems wrong: there will be an effect. Sensitive wildlife and plant communities will be disturbed, access to the lake will be cut, Anakeesta rock formations will be disturbed, and there will the inevitable noise, pollution, heavy vehicle traffic and disruption of construction. And for what? So that a few families can drive a little closer to cemeteries? It hardly seems worth the environmental cost.

As stated in the DEIS, “the Northern Shore Corridor would have major, adverse, long-term impact” on land-use, visitor use (including hiking and fishing), visitor experience, terrestrial and aquatic wildlife, archeological and historical resources, wetlands, air quality, and, in fact, every one of the values and resources that were studied. These conclusions apply to “construction of any of the partial-build or build alternatives.” Most of these impacts would be unavoidable, irreversible, and incapable of mitigation. [In view of these well-founded conclusions, based on careful studies, it boggles the mind to find a statement elsewhere in the DEIS that “none of the alternatives would harm the integrity of the GSMNP or AT resources or values ...” whoever wrote this must have failed to read the factual findings of the DEIS.

The DEIS is basically a failed document, ordered up to make a case for the road that, by any fair reading, does just the opposite in spite of the efforts of the writers. The failure to pick a preferred alternative, when everyone agreed that the cash settlement was the preferred environmental alternative, is very telling. The DEIS should not be used as a basis for building the road. The DEIS goes to great lengths to show just how ecologically destructive the project would be. The adverse, major, long-term impacts just listed are only a fraction of the multitude of impacts that would affect the park and its priceless resources. Any reasonable person equipped with commonsense and a capacity to understand the basic definition of words like adverse, major, long-term, permanent, etcetera would most likely conclude the North Shore Road would, at the very least, impair the park. Yet despite this simple exercise in logic, the DEIS, in a bold and submissive conclusion, declares, and I quote, “None of the alternatives will harm the integrity of the park. The Northern Shore corridor is not anticipated to cause impairment.” Well, considering the breadth of environmental impacts, one would expect a conclusion that at least added up. And, frankly, the conclusion reached in the DEIS comes nowhere close. Those of us who value a natural environment and the resources of our parks have reached a very different conclusion. The project will destroy the ecological integrity of a global treasure, considered by many as the crown jewel of the Southern Appalachians.



<Back

" "
" "" "