The north shore area is part of the largest roadless area in the Southern Appalachians and is one of the largest roadless areas in the Eastern US. This southeast quadrant of the park is generally bounded by Highway 441, Little River Road, Cades Cove Road, Parson Branch Road, and the Fontana Lake area. Along much of the Fontana Lake boundary there are no roads and the roadless area could be considered to cross Fontana Lake and include unroaded national forest and TVA lands. A few roads extend into the roadless area without dissecting it or compromising its roadless qualifications. These include the Clingman's Dome Road, the road to Elkmont, the road to Treemont, and the existing section of the North Shore Road. These roads are cherry-stemmed into the roadless area without jeopardizing its integrity. The administrative roads on the north shore side of Fontana could be considered in this light. Depending on where the boundaries of this roadless area are considered to extend, the area is close to or in excess of a quarter of a million acres.

There can be reasonable debate about where the boundaries of this roadless area should be considered. However there can be no justifiable debate that the area is roadless by any legitimate criteria. The Secretary of Interior is required by statute to recommend areas suitable for wilderness preservation. See 16 U.S.C. 1132(c). This roadless review has occurred for Great Smoky Mountains National Park and 390,500 acres were originally recommended for wilderness designation, ECR, p. 73. A revised recommendation was formulated to include the 44,000 acre north shore tract, but this recommendation was never transmitted to Congress due most recently to a lack of current NEPA documents. ECR, p. 74. Nevertheless, this area is classified and managed as Natural Environment Type 1 Subzone. See General Management Plan, GSMNP, pp. 19, 24. As disputes are resolved in this area, its use—like the other wilderness-eligible portions of the Park, will be restricted to uses and practices “of a transient nature and nonmotorized except in extreme emergencies.” Thus, the General Management Plan (GMP) recognizes the roadless and wilderness character of the north shore quadrant of the Park. Roadless inventories and wilderness are intimately connected in the 1964 Wilderness Act, with roadless recognition preceding wilderness recommendation. The attempted 1979 recommendation of the 44,000 acre tract, ECR, p. 74, and subsequent wilderness management by the Park Service demonstrate the acceptance of the area's wilderness qualities by the Park Service.

The Southern Appalachian Assessment (SAA) conducted in 1994 through 1996 and published in 1996 by several federal agencies, including the National Park Service, recognizes this quadrant of the Park as roadless in its roadless inventory. The southeast quadrant of the Park is by far the largest area in the SAA roadless inventory at 232,813 acres. We consider this inventory to conservatively delineate the roadless extent of this area.

The Forest Service publishes criteria for roadless inventories in the Eastern United States. These criteria allow up to 1/2 mile of improved road per 1,000 acres for qualifying roadless areas. By these criteria the southeast roadless quadrant could easily include all the cherry-stemmed roads around its boundary and still qualify as roadless. This includes the 15 miles of administrative roads on the north shore of Fontana . Under these criteria the roadless boundary could extend across Fontana Lake to include unroaded national forest land and TVA land. This larger roadless area would be approximately 267,248 acres.

Whichever boundaries are accepted, construction of the North Shore Road would slice a significant portion of the roadless acreage from this roadless portion of the Park and would place a new hard boundary where a more moderated boundary currently exists. This would have undeniable and significant impacts to animal and plant habitat, stream quality, and solitude. The values of roadless areas are well documented in the scientific literature as well as in National Forest and Park Service literature. For instance the Forest Service Roadless Area Conservation Rule EIS (USFS 2000) extensively documents the many ecological benefits of roadless areas. In addition a very extensive bibliography of scientific studies exists documenting the deleterious effects of roads. This roadless area is an invaluable resource for Great Smoky Mountains National Park , the region, and the nation. This resource should be properly valued and not degraded by building a road that would seriously impair this roadless area and the Great Smoky Mountains National Park.

There can be reasonable debate about where the boundaries of this roadless area should be considered. However there can be no justifiable debate that the area is roadless by any legitimate criteria.

The Secretary of Interior is required by statute to recommend areas suitable for wilderness preservation. 16 USCS 1132 states:(c) Review by Secretary of the Interior of roadless areas of national park system and national wildlife refuges and game ranges and suitability of areas for preservation as wilderness; authority of Secretary of the Interior to maintain roadless areas in national park system unaffected. Within ten years after the effective date of this Act the Secretary of the Interior shall review every roadless area of five thousand contiguous acres or more in the national parks, monuments and other units of the national park system and every such area of and every roadless island within, the national wildlife refuges and game ranges, under his jurisdiction on the effective date of this Act and shall report to the President his recommendation as to the suitability or nonsuitabiity of each such area or island for preservation as wilderness. The President shall advise the President of the Senate and the Speaker of the House of Representatives of his recommendation with respect to the designation as wilderness of each such area or island on which review has been completed, together with a map thereof and a definition of its boundaries. Such advice shall be given with respect to not less than one-third of the areas and islands to be reviewed under this subsection within three years after enactment of this Act [enacted Sept. 3, 1964], not less than two-thirds within seven years of enactment of this Act [enacted Sept. 3, 1964], and the remainder within ten years of enactment of this Act [enacted Sept. 3, 1964]. A recommendation of the President for designation as wilderness shall become effective only if so provided by an Act of Congress. Nothing contained herein shall, by implication or otherwise, be construed to lessen the present statutory authority of the Secretary of the Interior with respect to the maintenance of roadless areas within units of the national park system.

This roadless review has occurred for Great Smoky Mountains National Park (1974 and revised in 1979) and 390,500 acres were originally recommended for wilderness designation, Existing Condition Report, p. 73. A revised recommendation of 425,384 was formulated to include the 44,000 acre north shore tract, but this recommendation was never transmitted to Congress due most recently to a lack of current NEPA documents. ECR, p. 74. Nevertheless, this area is classified and managed as Natural Environment Type 1 Subzone. See General Management Plan, GSMNP, pp. 19, 24. As disputes are resolved in this area, its use—like the other wilderness-eligible portions of the Park, will be restricted to uses and practices of a transient nature and nonmotorized except in extreme emergencies.

The General Management Plan (GMP) recognizes the roadless and wilderness character of the north shore quadrant of the Park. Roadless inventories and wilderness are intimately connected in the 1964 Wilderness Act, with roadless recognition preceding wilderness recommendation. The attempted 1979 recommendation of the 44,000 acre tract, ECR, p. 74, and subsequent wilderness management by the Park Service demonstrate the acceptance of the area's wilderness qualities by the Park Service.

The further supported by the Existing Conditions Report (p.28) which states:

A large tract of land within GSMNP (44,170 acres [17,875 ha]), and almost completely within the study area boundary, was transferred to the NPS from the TVA in 1949. This tract is also part of a larger area (425,384 acres [172,147 ha]) that has been recommended by the NPS for designation as a “Wilderness” area. The 44,170-acre (17,875-ha) tract is considered a “ Reserved Rights Subzone ” within the “Special Use” management zone. Rights-of-way, water rights, burial rights, and other reserved rights limit NPS jurisdiction and management of this area. However, NPS maintains this area as f it were part of the “Natural” management zone to the fullest extent possible (GMP 1982).

North Shore is Largest Unfragmented Tract of Mountains Terrain in the Eastern U.S.

According to NPS briefing statements the north shore of Fontana Lake in the GSMNP is the largest roadless area in the in the Eastern U.S. The GMP classifies the North Shore Road study area within the park as Natural Environment Type 1 Subzone. In this subzone “visitor uses and park management practices are to be of a transient nature and nonmotorized.” NPS does not address how construction of the North Shore Road is consistent with its current GMP.

Construction of the North Shore Road would slice through a significant portion of the roadless acreage in this portion of the Park and would place a new hard boundary where a more moderated boundary currently exists. This would have undeniable and significant impacts to animal and plant habitat, stream quality, and solitude. NPS has yet to address these facts in the ElS process.

Hard Edge vs. Soft Edge — Habitat Fragmentation and Roadkill

Don't destroy this American gem! I have visited the Smoky Mountains before and would gladly do it again. Let it remain clean and undeveloped.

This is truly one of the last wild places on the east coast and we need to protect it. I urge you to save this area for future generations and support not building another road. Building a road would greatly increase the risk and spread of invasive species which is an incredible problem in the southeast.

This destructive and illegal road building project harms the Great Smokey Mountains National Park and therefore it is a disgrace to our nation. Please consider this an official comment in opposition to any plan alternative that includes the building of a road into one of the best roadless areas that I have found this side of the Mississippi.

After the 1943 Agreement, wise conservationists associated with The Wilderness Society pointed out the ecological damage that a North Shore Road would create, and the project was halted. In the 1960s when the North Shore Road proposal was revived, members of the Smoky Mountains Hiking Club and many other ecologically aware individuals joined with The Wilderness Society to implore authorities to protect this remote area along the north shore of Fontana Lake. Once again, the project was tabled.

Please do not destroy this roadless area. There is already a road to Bryson City: A road less traveled. The area is beautiful, but I have traveled this road from Tellico to Bryson City and not met a single au tom obile, but I have heard the dogs. Can't we leave something in this country of ours untarnished by ribbons of roads and parking lots.

As a longtime backpacker I value highly the protection of wilderness lands. "In wilderness is the preservation of the world!" H.D. Thoreau.

Destruction of this area cannot be reversed, once the violation has occurred. Our citizens deserve to have our few remaining wilderness areas be conserved for posterity!! Please!!!!

As a frequent visitor to the Smokies, and resident of the Great State of Tennessee, I voice my strong opposition to this unnecessary road which would cut through one of the few remaining sizeable vestiges of undeveloped land in the Park. On behalf of my 10 year-old daughter, please do not do this to one of America 's most beautiful places.

I am a North Carolina resident and preserving our wilderness matters to me and my family.

The North Shore Corridor would segment one of the largest, unfragmented tracts of mountain terrain in the eastern United States . The General Management Plan recognizes the core nature of the GSMNP as a “sanctuary” from human intrusion and safeguards that element of the GSMNP from degradation. GMP at 5. NPS recognized in 1979 that a large segment of the Park, which included the North Shore Corridor, satisfies the standards for designation under the Wilderness Act. Existing Conditions Report (ECR) at 3.4.1.1. That conclusion reflects a finding that the area retains “its primeval character and‘ influence, without permanent improvements or human habitation.” 16 U.S.C. 1131(c). NPS policy requires that backcountry, like the North Shore Corridor, that is “under study, proposed, or recommended for wilderness designation will be managed as wilderness.” MP at 8.2.2.4. Consistent with this policy, NPS manages the North Shore Corridor to comply with the standards of the Natural Environment Type 1 zone, ECR at 3.1.1, in which “visitor uses and park management practices are to be of a transient nature and nonmotorized except in extreme emergencies.” GMP at 19. Thus, construction of a road through this area is entirely inconsistent with NPS policy and the standards of the General Management Plan and would significantly impair the wilderness character that is key to the integrity of the Park.

My late son and I made a backpacking trip before he died into the heart of the Smokies. This road would blight the very land he cherished and forever disrespect his memory. Preserve the Great Smokies National Park , don't destroy it!

Why scrap more of our beautiful Smoky mtns park?

Only persons who want the road are big business that reside outside of the area. A few that have been fooled by the hype or brain washed, but most enjoy having what is left of the wilderness. A lot of descendants of those remove realize the value of the park and do not want the road. Stop the road.

Don't tear through [the] smokeys! Has had enough trouble with acid rain, beetles, etc. Preservation should be our priority.

Stay out of building from this area.

Hope road never continues into our park; access to area already in place via hiking.

Roads to Nowhere - A Perspective The Blue Ridge Parkway continuation through the heart of the Great Smoky Mountains National Park, from Soco Gap via Heintooga Overlook to Tricorner Knob, and onto Newfound Gap, Clingmans Dome, and Deals Gap, was a road project of early park days. It would have been a disastrous desecration of the mountains had it been executed. With the exception of the Clingmans Dome spur road, it was stopped at Heintooga Overlook more than half a century ago, when it was realized that the time for building such landscape destroying “pleasure roadways” had run out. Similarly, a trans-mountain road from Townsend via Spence Field down Eagle Creek was a hot item for some time, and it was finally laid to rest.

We all understand this proposed road would pierce the largest cohesive tract of mountain terrain in the eastern US, threaten the streams draining to Fontana Lake due to acidic rock, and be yet another red-tape useless project damaging a public resource—an international treasure. Are there not enough roads in the Blue Ridge, in western North Carolina, in this country? I want there to be places without asphalt and what better place the largest, wildest tract thats left? We should be talking road removal, not construction in the Park anyway. In addition to the enormous environmental damage the estimated $400 million in project cost is also an economic boondoggle to taxpayers.

I strongly oppose the construction of a road along the north shore. In the 60 years since the original agreement the US has lost too much of it's natural areas. We need to keep areas that are minimally accessible in order to further protect vegetation and wildlife.

Means currently exist for relatives to visit family graces. They are not making any more wilderness. Please don't ruin this area with a road.

My family visits Great Smoky Mountains National Park . The last thing we want to see is an unnecessary road through this precious wilderness.

I'm a senior citizen. I came to this area 50 years ago and I've enjoyed the Smokies very much. But I no longer can get into every area and I believe that we should keep the area --what areas we have wild, wild. Once you get into them, you cannot undo it, those roads you're talking about.

I oppose the North Shore Road because it cuts through a large tract of wilderness area and does not allow the animals access to the water without crossing the road. I believe it would kill the animals. And the building of the road has -- there's a large environmental impact because they have to cut through dangerous rock to build the road. So I'm very much opposed to the road and I am for the cash settlement.

Construction of such a road through one of the last remaining roadless areas in the southeast will clearly have a devastating impact on the wilderness character of the area that has emerged in the past 60 years.

A parkway like roadway build outside the park in the National Forest Area similar to the Foothills Parkway such as an extension of the Blue Ridge Parkway would have a similar cost and traverse a similar area but would not have the impact that the Northshore road project would have on the quasi-wilderness area.

Please consider these comments in support of not building a northshore road and preserving our national treasure- the Great Smoky Mountains as pristine and wilderness area!

I am totally opposed to this road. I am frankly just dumbfounded that our government would consider spending $304 million on a road through the largest unroaded -- un-public -- roaded area in the Eastern United States , you know, a wonderful area for recreation, wildlife, and all of the things that go with the wilderness. And I am hoping that the Park Service will see their way to not going along with this road, for the reason that it's too expensive, it will be an environmental tragedy in terms of cutting up a huge wilderness area, and also for the wildlife and the water quality, and so forth. So I'm very hopeful that they won't build the road.

I am commenting on the North Shore Road proposal through the Great Smoky Mountains National Park . And I just wanted to say that I am very much opposed to this road. It runs through -- would be built through the largest unbroken tract of wilderness remaining east of the Mississippi River in all of the United States. So I'm definitely opposed to it for that, due to the environmental destruction and the tremendous loss of life that would be caused by building this road. And I'm also against this road for the exorbitant price to taxpayers. There's very little economic benefit to building this road, tremendous environmental damage as a consequence, and all at a gigantic cost to taxpayers. So I'm very, very much against this road.

Building a road through the roadless area on the north shore of the lake in the Smokey Mountains National Park is a terrible idea. The Smokey Mountain National Park is a national treasure. To build a road along the north shore and destroy the roadless nature of this area is criminal. Citizens are used to other agencies attempting to build roads into roadless areas, but we expect more environmental stewardship from our National Park Service. Even branches of the Department of Agriculture have some rules and regulations that show respect for the value of roadless areas.

This pocket of the Smoky Mountain National Park is important to protect also because it is the largest roadless area of wild lands east of the Mississippi River . The North Shore Road would allow increased access and development in this pristine area.

Each year I travel from Maryland to the Southern Appalachians and specifically Great Smokey Mountains National Park (GSMNP) to experience one of nature's most breathtaking events. Springtime in the Southern Mountains. I also like to backpack and have done so extensively in the Southern Appalachian, including GSMNP. Perhaps no where else but GSMNP do we have the opportunity to restore the balance of nature on a larger scale, since so few large unfragmented mountainous areas remain in the eastern United States. It seems insane to develop this part of the park when a simple resolution, perhaps the only resolution that will settle this issue, is at hand. To find a solution so simple without any impact to the environment would surely make Alternative #2 the preferred alternative for the benefit of the American people and future generations. This park is truly unique. We have plenty of roads in our fragmented landscape, including our parks and this road will do nothing to enhance such a pristine place.

I believe that completion of the North Shore Road would severely undermine the wilderness quality of the Smokies by opening up a large part of its southern flank to motorized vehicles. There are more than enough roads to get people to the perimeter of the park. We shouldn't forget that one of the main reasons for visiting the park is to get away from motorized-vehicles and to use the trails to see what nature has to offer.

Please accept this as my comments on the North Shore Road EIS. I support Alternative No. 2, the $52 million cash settlement for Swain County. The need to preserve this beautiful area far exceeds any potential benefits of constructing the road.