Geology

The study blithely rejects that any damage will be caused by the pyritic rock that will be encountered throughout the construction. However, they rely on a technology that was only recently developed, and for which only 10 year studies are available. They cannot assure us that the proposed means of dealing with pyritic rock will be effective for any longer than 10 years.

“Excavation of acid-producing rock should be avoided where possible and always minimized.” EC, p. 88. Considering the extent of acid-producing rocks in the study area (as many as 99% of the rocks within the study area, EC, p. 87), and the Park Service's obligation to serve as an example of conservation and stewardship-minded land management, no new road should be constructed. In addition, the climate and terrain of the area make construction of an unnecessary road particularly ill-advised:

The design of traditional cut-and-fill roads in mountainous terrain generally requires that very large volumes of material be disturbed while excavating cut slopes and building road embankments. When the surface area of acid-producing material is increased during excavation, natural weathering processes are accelerated and the potential for acid drainage is increased (Byerly 1990). When dealing with acid-producing rock units, Byerly (1996) believes that mountainous terrains in humid, warm environments present the greatest challenge. In these situations, substantial volumes of excavated acid- producing material can be disturbed and exposed, and the fresh, in-situ rocks of the cuts are permanently exposed to weathering elements. Also, the warm and wet climate greatly increases the rate at which oxidation of the exposed material occurs (1996). EC, p. 88.

Environmental concerns center on the strong probability that road construction would expose extremely acidic Anakeesta rock, which produces acids and heavy metals that are leached by rainfall into streams and kill aquatic life. While recent road construction has occurred on nearby Forest Service lands, concerns remain regarding road construction through Anakeesta formations.

I am still opposed to the North Shore Road no matter what. I don't believe that the EIS will tackle all of the species that could be affected by another road through the wilderness... and the Anakeesta rock blasting will definitely harm the environment no matter what precautions are taken to avoid it.

Let's talk about Anakeesta Rock. This was a Park ploy to stop the road. North Carolina D.O.T. has built roads on the other side of the lake. They have come up with ways to neutralize the acid in the rock which does not harm the water or Fish.

November 8, 1997, a statement was made by Bob Miller of the National Park that the Anakeesta Rock used to stop the North Shore Road was just a ploy the Park used. This statement was made at a meeting sponsored by Duke University, and the National Park Service at Swain County.

Floodplains and Floodways

The design standard used is for a 25 year flood. The study team admits that Interstate Highways are designed to withstand a 100 year flood. The 25 year standard is inadequate for the terrain and for the sensitive nature of the environment being crossed. It fails to reckon with average rainfall of over 80 inches a year on the high ridges, which causes frequent floods and “freshets.” Using far too low a standard exposes this part of the park to catastrophic damage from floods. Only one culvert has to collapse to send thousands of cubic yards of silt and rock from a fill into streams and covering a vast area of surface with sludge. Sensitivity to the danger to the delicate nature of the endangered habitats from a storm related incident requires a much higher standard of design. Flood destruction of bridges in the park on the Parsons Branch Road and on Hazel Creek illustrate that flood danger has not been realistically assessed. The low 25 year flood design virtually guarantees severe flood damage on this road, repeatedly, and always with enormous environmental destruction. No mention is made to provide for known, severe, torrential, seasonal downpours that happen every year.

The methods described to contain and neutralize acid runoff assume rather mundane weather changes. Just one of these events, in the construction zone, would have tragic consequences for the bass, walleye, steelhead and crappie populations in Fontana Lake as well as the trout in the streams downstream of the construction. The effect of runoff on the Shad population in Fontana Lake also requires specific attention as Shad are the major food source of the other fish populations. These weather events can be so severe as to render the containment methods addressed to date as superficial.

An assessment of the frequency and severity of these weather phenomena as well as the resulting changes in engineering to safeguard against this damage is required. An assessment as to whether existing construction requirements are sufficient for this protection is needed. It is not adequate simply to meet current construction standards if the standards are weak. It has been proven during the last year with all the slides and flood damage in Western North Carolina that either the construction standards are lacking or that such damage is to be acceptable. A study of the recent damage is required to determine if construction standards can be revised to prevent these catastrophes and if not what are the now predictable consequences. All the slides in WNC require tabulation, referenced with construction design used, and analyzed so that some assessment of the frequency and enormity of slides can be predicted. The danger to human life, as well as environmental consequences make this paramount. An EIS that does not specifically address this is fatally flawed. Costs will have to be revised to include subsequent engineering changes.

Construction within floodplains is also overseen by COB. Executive Order No.11988 requires that the Department of Interior must “provide leadership and shall take action to reduce the risk of flood loss” when carrying out its responsibilities for “acquiring, managing and disposing of Federal lands and facilities.” Director's Order 77-2 requires NPS to “preserve floodplain values and minimize potentially hazardous conditions associated with flooding.”

Specifically NPS must:

• Protect and preserve the natural resources and functions of floodplains;

• Avoid the long-and short-term environmental effects associated with the occupancy and modification of floodplains; and

• Avoid direct and indirect support of floodplain development and actions that could adversely affect the natural resources and functions of floodplains or increase flood risks.

Given these directives, and the presence of 141 streams within the corridor, NPS must fully analyze the impacts of road construction on floodplains within the study area.

In addition, NPS must explain its use of a 25-year flood design standard for the road. That standard is inadequate to protect the proposed road from storm water damage and the consequent damage to the ecosystems within the Park from the collapse of fills, washout, and culvert blowouts. Construction in floodplains will worsen, not improve, flood conditions in the Park.

Upon questioning at public meetings ARCADIS representatives disclosed that culverts specified in cost estimates were for a 25-year flood design standard. That standard is inadequate to protect the proposed road from storm water damage and the consequent damage to the ecosystems within the park from the collapse of fills, washout, and culvert blowouts. Cost estimates should be conducted with standards sufficient to adequately protect park values.

NPS policy also requires NPS to “preserve floodplain values and minimize potentially hazardous conditions associated with flooding” by avoiding “the long and short-term environmental effects associated with the occupancy and modification of floodplains.” Director's Order 77-2. Finally, NPS must “avoid direct and indirect support of new construction in wetlands unless there are no practicable alternatives.” MP at 4.6.5. These policies prohibit NPS from selecting the full build alternative or partial build to Bushnell alternative as its preferred alternative.

Air Quality

We are told air quality studies are incomplete at this time. We do know that all of the North Shore Corridor Alternative is in a non-attainment zone for ozone. The yet- to-be-completed study must consider how the road will impact the present poor air quality, especially during construction. We find alarming the unscientific conclusion of the study team that the increase of traffic on the completed road will be an insignificant additional contribution to air pollution.

Air pollution in smokies is bad enough, I cannot even go in July-Aug because of my asthma.

One of my main concerns is the air quality, you know, if the road is built, because I've seen -- I've been here for 23 years and I'm originally from Los Angeles and I've seen what, you know, traffic congestion can do to the tree population. And then -- but they were talking also showing that they weren't expecting that many cars on this road. I mean, if there's a lot of cars on the road, there's an air quality problem. If there's not that many cars, it's like, what's the point spending that much money on the road.

Hazardous Waste