In estimating costs, no estimates have been made for incremental maintenance costs that will be incurred during construction. Yet, during the estimated 15 year construction period, there will be annual maintenance costs, and the costs will increase each year as more mileage is completed and requires maintenance.

It would be the height of hypocrisy for the Park Service to consider construction of a new and unnecessary road when it is struggling with a well-publicized backlog of maintenance needs.

A significant portion of the NPS road, bridge and tunnel infrastructure has deteriorated to only fair or poor condition, and is deteriorating at an increasing rate. Particularly because of this deterioration, the NPS and FHWA concur that the PRP program must become more responsive in directing funds to where they are most needed and will be the most effective Federal Lands Highway Program Park Roads and Parkways Revised Funding and Prioritization Procedures, p. 1 (Jan. 1998)(available at http ://www.nps. gov/transportation!roads/manuallbigdoc.pdf). The Park Service's official policy recognizes that the correct priority is to maintain the existing roadway system, before taking on high cost work such as widening or realigning roads, building new roads or addressing other transportation needs. This priority is carried out by dedicating the majority of the FLHP funds towards lower cost rehabilitation projects on existing roads in order to reverse the rate of deterioration of the overall NPS road system.

The budget for construction of the North Shore Road would be greater than the Park Service's entire national annual budget for road construction and maintenance. “Operating in a constrained budget environment, the National Park Service (NPS) has evaluated programs, made difficult management decisions.... $320 million will be used to improve road conditions in parks (assuming enactment of new Federal Highway Act).” FY 2006 President's Budget [for the National Park Service] Executive Summary, p. 3 (Feb. 7, 2005)(available at http ://data2 .itc.nps.gov/budgetweb/fy2006/fy 06 execsumrn.pdf). How do you propose justifying to Congress the need to double the road construction budget of the National Park Service to benefit only one Park? The GSMNP currently has a $182 million maintenance backlog, of which $117 is a road maintenance backlog.

Make no mistake, the North Shore Road will be an expensive road to maintain. Where tunnels are used, “future wedge failures and other mass wasting events” could threaten the road surface (no mention is made of road users), requiring expensive repairs and closing the road. EC, p. 90. This was one of the primary reasons original construction efforts were halted.

One of the most discouraging serious points is that it is doubtful whether these cut slopes can ever be made completely stable. The Park is subjected to tremendous rainfall at times. . . and the thin layer of saturated soil above the cut slopes could continue to slide indefinitely. Therefore, maintenance can be expected to be excessively costly and to continue over a very long period.

Report of the Technical Committee for the Completion of the Bryson-Fontana Road Construction Great Smoky Mountains, Exhibit A. Landslides and rockfall occur frequently on the Blue Ridge Parkway, and even on 1-40 between Knoxville and Asheville, so it is important that the Park consider these events in the cost of maintaining the road. On 1-40, bolts, chain-link fencing and barriers all hold back the mountains. These will not be options in the Park where aesthetics must be given high priority. In addition to keeping the mountains off the road, the acid-rock problem discussed above will require monitoring and possible re-treatment in the future. For example, lime may have to be applied at intervals atop blended fill materials. EC, p. 89. Considerable employee time will have to be dedicated to this Road. The costs to other programs must not be ignored.

That same policy recognizes that the correct priority is to: maintain the existing roadway system, before taking on high cost work such as widening or realigning roads, building new roads or addressing other transportation needs. This priority is carried out by dedicating the majority of the FLHP funds towards lower cost rehabilitation projects on existing roads in order to reverse the rate of deterioration of the overall NPS road system.

The Park is dealing with the cumulative effect of years of absorbing fixed cost increases and across-the-board reductions. This resulted in 19 essential positions going unfilled in 2004, which means fewer educational programs, facilities that are cleaned less often, grounds maintained on extended cycles, ineffective monitoring of archeological sites and insufficient curatorial storage. Additionally, the funding shortfall has resulted in a serious backlog in repair and rehabilitation of Park structures. Major Park programs have been forced to cut back and rely heavily on project funding to maintain their basic levels of operation. GSMNP Strategic Plan 2005-2008, p. 5.

We also note with interest the impact for building the road of 475 cars per day on Bryson City. It was indicated in the February North Shore meeting (by ARCADIS) that NC State would assume the responsibility for road improvements to accommodate increased traffic. The NCDOT is currently suffering from a $50+ Billion shortfall for statewide transportation projects over the next 25 years. We learned this from a regional NCDOT conference held in Cullowhee , NC, in 2004. The prospects of NCDOT assuming this project in the near future are not good. Is it in the best interests of “unhurried, unspoiled,” and un-pretentious Bryson City to become another congested Gatlinburg? Let Cherokee assume that burden.

We are currently in a time of fiscal deficit for the National Park Service. According to a recent study by the National Parks Conservation Association (www.npca.org), managers throughout the National Park System are struggling to keep their parks running on barely two-thirds of the funds they actually need. In this very stressful period, it is certainly not in the best interest of Great Smoky Mountains National Park to be faced with devoting personnel and funds to yet another evaluation of a project that has already been found to be ecologically unsound.

The construction of this road will also put an additional and tremendous burden on the Park Service which already does not have enough money to deal with the many demands that are already facing the GSMNP.

The enormous cost of this road — and I highly question the $370 million estimate as being way too conservative — is an unconscionable expenditure when the Bush administration is proposing cuts in the Park Service budget, to say nothing of starving other programs to serve education, child welfare and assistance to seniors. We are staring at $450-$500 Billion annual deficits as far as the eye can see and we're going to waste money on this abomination! The Park Service is already underfunded and this road would only increase the annual cost of maintenance and policing this area.

I think the cost to the Park Service to maintain and patrol any new road in perpetuity is a cost is significant and should be considered as part of any benefit of the project.

I am concerned about the impact the road will have on the Park Service. They do not get sufficient revenue now to do everything that has to be done, and too much of their budget goes to policing areas and that's what will happen there. There will be more trash. There will be -- someone mentioned poaching, traffic accidents, lost - lost hikers in an area where you wouldn't expect it otherwise.

One of my main concerns too is that I have been in this area for 23 years and I feel that the government hasn't been taking care of the roads within the Smoky Mountains , but I'm, you know, right here in the Greenbriar area, different areas that I've been. They just don't look as good as they used to and they need maintenance of the national park. So if they can't do it with what's existing, how are they going to spend this money and maintain whatever they're going to be creating? I think they need to first maintain what they have. If there's a problem with -- they have to utilize this money, I think the No Action would give the county their money and then do whatever they need to do would be a nice thing.

The same thing will be done if we have a little extension. Park rangers will be in charge of it. I'm a Friend, I belong to the Friends of the Smokies. I go out to Deep Creek and pick up trash, I will still be a friend of the rangers when the road is built because I love the mountains and I love my country. I'm more impartial politically. I'm for the issues, not against certain people. But that's what we get into at this thing, is for and against certain people, trying to get people against people, and this is why I'm looking forward to a conclusion. I hope a conclusion comes soon.

The increased cost to the Park Service of road maintenance, trash collection and crime prevention along this remote section would place an added burden on the park's budget, which is already woefully inadequate.