5.15

5.15 Agency Comments and Responses on the DEIS
The DEIS was distributed to local, state, and federal resource and regulatory agencies and the public for
comment as detailed above in Section 5.14. The following is a list of agencies that provided comments on
the DEIS, along with the date of each correspondence:
■ Eastern Band of Cherokee Indians, Tribal Historic Preservation Office — April 7, 2006
■ Federal Highway Administration, Eastern Federal Lands Highway Division — April 5, 2006
■ NC Department of Administration (cover/transmittal letter for state agencies) — April 6, 2006
■ NC Department of Environment and Natural Resources (NCDENR), Secretary — Apri16, 2006
■ NCDENR, Environmental Review Coordinator — March 28, 2006 (cover/transmittal letter for NCDENR
agencies)
■ NCDENR, Division of Environmental Health, Public Water Supply Section — February 13, 2006
■ NCDENR, Division of Land Resources, Land Quality Section — March 2, 2006
■ NCDENR, Division of Water Qualiry, Transportation Permitting Unit — March 1, 2006
■ NCDENR, Natural Heritage Program — March 3, 2006
■ NC Wildlife Resources Commission, Mountain Region Coordinator, Habitat Conservation Program —
February 20, 2006
■ Tennessee Valley Authority — March 10, 2006 and April 13, 2006
■ US Department of the Army, Corps of Engineers, Wilmington District — March 27, 2006
■ US Environmental Protection Agency, Region 4— March 27, 2006
■ US Fish and Wildlife Service — April 6, 2006
Agency comments received during the comment period were reviewed and analyzed by the study team in
review sessions with input from NPS staff and members of the Management Team. Public comments are
provided in Section 6.
5.15.1 Agency Comments on the DEIS
The following is a copy of each of the agency comments received on the North Shore Road DEIS. Specific
comments that required a study team response are indicated within each letter by boxing the comment and
labeling each comment with an attribute which: (1) identifies the agency providing the comment and (2)
provides a number that corresponds to the response. For example, "TVA-1" is the first point requiring a
response within a letter submitted by the Tennessee Valley Autharity. Study team responses to each of the
agency comments are included following the actual comments. If a response required a change to the
document, additions or revisions to the text were made in the appropriate section.
Agency Consultation and Coordination — 5-8
North Shore Road Final Environmental Impact Statement

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DATE: 7 — April - 06
TO: Nodh Sfiore Road Project
Great Smoky Mountains National Park
P.O. Box 30185
Raleigh, NC 27622
Eastern Band of Cherokee Indians
Tribal Historic Preservation O�ce
P.O. Box �}55
Cherokee, NC 28719
Ph:828-488-0237 Fax [phone]
PRO7ECT: Vorth 5hore Boad Draft Environmentat Impact Statement, (DETS).
To Whom lt May Concern:
The Tribal Historic Preservation Office of the Eastem Band of Cherokee Indians (EBCI)
is in receipt of the above-referenced projact information and appreciates the invitation to
participate as a consulting party in compliance with 36 C,F.R. 800.
We offer the following comment:
According to the information provided by the National Park Service on page S-l6, �here
are potentially four types of cultural resources present in the North Shore Road corridor.
There may be the potential to adversely affect archeological sites, historic structures,
Traditional Cultural Pro erties and the A alachian Trail. We have alwa s ur ed that
more eultural resource investigation be conducted. The Eastern Band of Cherokee
[ndians Tribal Historic Presecvation Ofiice is entering into tha formal record that the
archeological and cultural resources data included in the draff Environmental Impact
Statement i, insu�cient to make a decision rer3arding potential alternatives. This utiice
questions if a"10 perceni" survey of the project comdor can sufficiently enable [he
Eastem Band of Cherokee Indians Tribal Historic Preservation Office to reflect upon
ro osed altematives? However, it was further stated that the intensive investigation
amounted to only "7.8 percent of the approximately 10,260 acres .. within the study
corridors ....° We could not make such a decision on our Qualla Boundary with this
level of survey, and we quastion how the National Park Service can make such a decision
regarding the proposed project corridor with this amount of effort?
There are si�niPicant Eastern Band of Cherokee Tndians cultural and historical resources
throughout the project's area With the lack of archeoiogical and cultural resource data
provided there appears to be a bias against cultural resources because we have such a lack
of knowledge regarding Tribal historical, [raditional, and cultural resources patentially
present. We believe that archeological and Tribal cuttural resources have not been given
an appropriate wei�ht in the furmation of an alternative select[oa it is beca!ise the
eft'ects on cultural resources wiI( only be partially understood that it is unlikely a
qualified judgment can be made by anyone.
According to page 3— 12, section 32.4, l. .9rcheo/ogiccrl Site,s, "Additional data on �ite
occurrence were gathered during a preliminary reconnaissance in 2003 and an intensive
sample survey in 2004. Finally, information on potential site locations was gathered
ir�formation sysiem —(GIS) based landform analysis," Accordm� to the intormano❑
prorided, eight sites were determined eliy,ible for inclusion on the I�'ational Register
under Criterion D. Moreover, twenty-three additional sites are "considered significant �
potentiafly signiEcant resources and must be considered in the EIS process." Ho�vever,
no intormation regarding these "potentially significant" sites is included in the section
PnrrtiaA ? 9 R 4 hxnnrtc tn I'vlfrrrnl Resrnrrce.s heeinnine on oaee 4-88.
The information provided indicated "it is evident that numerous additional prehistonc
AmPriran fndian�iisioric Cherokee and Euro-American archaeological sites are
probably present there [within the project corridorJ." The rich cultural and traditional
aftiliation with the river valleys ofwestern North Carolina obiigates the EBCI THPO to
protect our Tribal cultural resources. We would ask that the National Park Service, as the
lead federal agency, and atso as stewards of this regional, state, national; and mere
importankly Tribal history, work in concert with the Eastem Band of Cherokee [ndians to
oroteci this rich culturat reeioa
At this time, the Eastem Band of Cherokee Indians Tribal Hisioric Preservation Ofiice
can not make ajudgment pertaining to an altemative selection where cultural resources
are concemed. Additionally, we are not satisfied that the Nationat Park Service can
choose an alternative based on the data presented in draft EIS. Table 4-f 2, pages 4-86
and 4-87 are inconclusive v,�ith onty 7.8 percent of the proposed project investigated.
Furthermora, we can not be confident that any selection of an altemative +vould
appropriately consider the impact to cultural resources.
[f you have any questions or comments, please do not hesitate to cuntact Russell
To�ansend, the �fibal Historic Preservation Ofticer at 8wS-488-023�, zxt, I Xou can
also contact;kyler B. Howe, the Tribal Historic Presenation Specialist at 328-438-0237,
zxt. 2. /
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� Sincerely, ,�-'
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.'� 7vler�. Howe
Tribal Historic Preservation Specialist
Eastern Band of Cherokee Indiars
C c: Erik Scoc Kreusch
Agency Consultation and Coordination - 5-9
North Shore Road Final Environmental Impact Statement

L�
U S. Deparrner�, i
o�Trcn;portanon
Federpl Highway
Admirrisfration
Mr. llale Ditmanson
Superintendent
Greai Smoky Vfountains Nation�l Park
]07 Pazk Hcadquartcrs Roaci
Gatlinbur�, TN3773R
SubjccL North Shore Raud, Great Smoky MounWins Nauoital Pazk
Commencs on DraB fnvironmental lmpact Statement
Dc:u� Ivu. Ditmanson:
ziaoo ��uyd��v c;��:it:
Ste�ng. VA 2016G�'i511
Refer to: HFQP-1.5
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North Carolina
Department of Administration
1lichael F. Easle��; Guve;no, Britt Cobb. SecreCary�
�oril 6, 2006
l��j � 5 2� �4s. inelda We�?we:di
��stional Park Service
Great Smokv Nadcnnl Park
P.O. Box 30(SS
Ralei�zL. �C 2�622
Thc Feder�l Highway Administmtion's Eastcrn Federal Lands Highway Divisioa (EFZHDj has
wnrked very closely with your staff and the cousultnnt to prepare die referenced draft
envimnmen4�1 impact statement (DLI5}. EFL�ID tv�s bccn an activc ta�un participant in Utc
prcparation oi thc D�IS, is involvc^icat commcncir.g bc,orc projcct sccping and continuir,g
Cltrou�li :o conpilation mid relcase of this DEIS. Comnents �md concems 8iat thSs a�;ency �,nzy
havc had, have b��en :�d�irestic;c3 an�l incorpvraCeJ into d�e relea.eed :I�:H TS.
The El?ii3D Uierefore has no commcnt or. tl�c cuacnt DG1S. lf you havc :uiy qucstions rcgr:rding
this correspondcncc p!casc contact mc at ?Q3-404-62fi2 or al jnck.j,vandop�c�-dfhwa,ciof.gov
Sinccroly youi�,
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Jac Van Dop
En ironmcnt�l Spcci�list
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R,e: SCEI Pile �' 06-�-0000-0214�, pE1S; [�raft E�vironmen�al !n�:pact StnrcmcE�t (DFISj for inp�.it for
the Norh Shore Road; (ea!led ior in a! 943 :ALree:nen�j ra� erses the north.rn shore of Foctana
Lake trom �ce;, oFBr.'son Citv
The above refe;en�ed environrner.t�l ir.�pact inform, tion has been submi;t.d tu the Stute C��arin,ltoc;a
ueder tl�e provisions oI the tiatior.al Enviro:u��en[�I Polic;: .�,e[ _�.cco:d;m� :o G.). '. 1=A-lp. �ch�n a
s�a[e a�_eny is required to prepare an environmer.tal doci�.ment ucder t:��e provisions oF Federul (av;. d1e
er.ti�i.omnanta; document meets the provisioris of the State Eei��ironmeetal Policy Ac?. _atrached to tiiis
(e�rar f��r ��our eo�uidemtlon a�c die eommen�s made bv tl�,e \.C. Deaanment of En��irvnme�it urid
?;atur�! Rasow�ces. Alsu; r,�ere tiill oe addi;ion�i com�ilci;ts fe:�hcumirnr scparo[el� 1'rom d�a Govcrnia; s
6'iIC2.
If anc furd��r e:ivirenmentai revie�v d�cumetits sre pren�arz�: fo, diis project. �iiep� si°,ou�d ba fci�varded to
chis of�ice for int�reovernn•:en��l ;e� ie�v.
S:noulu you aa�,�e am: q�.ie,tions; pla�se de not ha;ita�e to eall.
Sii:ccr.!y.
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Agency Consultation and Coordination - 5-10
North Shore Road Final Environmental Impact Statement

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NCDENR
North Carolina Department of Environment and Naturai Resources
Michael r. Easley, Govemcr ill`am G. Ross Jr., 5e�retary
Apnl b, 2006 �; j?�
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Ms. Fran P. MaineL'a, Director �' ��- `°.-o
National Parks Service ;�, GJ,q"G':�
1849 C Street, ?�1W �-�f,
Washington, DC 20240 �����,,, , ,,, ��''
D�ar Director Mainella:
On behalf of the North Czrolina Department of Environment and Vatural
Resources I am wri�n� to express concerns related ro the Draft Environmental Impact
Statement developed by the Nationa] Pazks Service for che proposed North Shore Road in
Swain County.
T::e at?ached agency com.ments raise sSgniiic�nt issues arising from �ne p:oposal
To build a public rozd throu�h the Great Smoky'_vlountains National Park. ln summary
these comments conclude that the road construc�ion alternatives would result in far
reaching and long term advarse environmental impac[s on America's favonte park.
Thesz conur,ents also confirm North Carolina's positioa in support of the monetary
settlement expressed in Governor Michael F. Easley's comments on the Draft EIS and in
his previous correspondence to the Department of In[erior.
The adverse impacts ouUined in detaii ir the agency comments range from
de,�radation of streams and we;lands, loss of hien quality habitat, impacts on drinking
vrate: supuly arid increasad stormwater runoff. �Asency cornments have i,ientif:�u a
number of negative water qua;iry impac[s, includiag increr:sed sedimentar'on in trout
sL�ezms ar.-d the exposure of acid-producing rock formations that v.�ill result in [he
degradation of wate: quaJity dunng road construction. Ur,der r.ormal circums[ances the
likely adtierse impacts to water quality tha: have been ider.cified would be of concern, bu_
given the uniqce namre of :he proposed area these c�ncems are even greater.
The Great Smoky hiountains Nationa! Park is a nauor,a] treasure provi�ing
habi[at [o a diverse �oup oi p;ar.[s, ar,imals and aqu2[ic species. The Park a]so pro� ides
a backco�ntry area hat attracts hikers and anglers to this a:ea oi North Carolina. Whiie
this a:ea is critica! fur tourism, the streams, wetlar,ds and np2riaa areas provide both a
vital ecological function and a publ;c health value. First, tne streams aleng the north
s'hore oT For.ana L�'�ce are in the process o.` being ciassified as Outstanding Resource
Waters (ORW). Th'_�s classificaron indicates rha[ the,e streams are some of �he mos:
pristine ir. fl:e �[u�e ��d include the presenc� of rare and di��erse benthic comm�!nities.
04e
"601 Mail Se��vice re���±er, R2laich, No�th Caroiina 27099-160' �jOI�1CaiO�lriB
F� c�ne �19 - 3{-�48� � PX � ��?16-��0� �!n�ern�i ,v tiv� er� ce(e.r�c un�cNR/ �►?j�tlit'�/�„
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E^ua �Ov n„ �./ � SNm �.�.�1 G�:.er � SO ��o N,1�... �� 10'i st .,r_�.,��a ��_er
Secondlv, Lake Fontana is a source of the drinkins water supply for parts of this ares.
Our agency staff wi[h the Division of Environmental Health indicate chat at least one or
the alterna�ives could create po[ential impacts to the water quaiity in close proxirnity to
the water supply inEake.
In zddition to che environmental problems identified in the agency commer.ts, the
comments also note that in some instances the Draf� Environmental Impact Sta[emen�
does not provide enough information to make an informed decision on whether certain
activities related to the construction will cause even further environmental degradation.
For example, the environmental document references the large amount of excavated
material that would be produced by one of the buiid ahematives. However, the document
does not discuss a cEisposal plan for this materiai.
Nonh Carolina values the Great Smoky Mountains National Park, not oniy for
our citizens but for the over 10 million visitors wno have made it one of [he nacion's most
beloved places. As I nave summarized and as the cemments illustrate in detaii, i[ is
abundantly clear that the buiid alternatives would eesul� in severe environmental impacts
to this area. In ligh[ of these environmental impac[s, I ur;e [he Nationa] Park Service to
pursue the monetary settlement altemative p:oposed in the Draft Environmencal Impact
S ta[emer.t.
Thank you :`or the epportunity to comment and for your cansideratien of :hese
commencs. If you need any further ir,format+.on from the �Jeoartment or have any
questions, please do not hesitate [o cantact me.
Attachm�n.s
Agency Consultation and Coordination - 5-11
North Shore Road Final Environmental Impact Statement
5ir.cere!y,
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Secre[ary

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NCDENR
North Carolina Department of Environment and Natural Resources
P�licnael F Easley, Govemor
William G. Ross Jr., Secretary
March ? 8, 2006 �'L��� qp� "� �c��
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StateClearir.ghouse ��' _,�='��
116 West Jones SSee[ �`��% `�'''
Ralei �, ?].C. �,�� �, �� �` �
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RE: Draft Entiironmer.ta'. Impac[ Statemert :or .he Aoposed \orth Shore Road Project, liS
Department of the Intenor, Nationzl Park Service, Swain County
De2r ChivS:
This letter with attachmen[s is in response [o the Draf Enviionmental Impaet Statemen*.
ceveloped by the Va�io^al Park Service :o analyzes altenadves for:esolving tF.e iss�es rela[ed to
[:�:z tio!-th Shore Road ia Swain i ounty.
�lhe e��.tensive land c:earing, 5Il acd gradi�g required to eors�ruct a puolSc h:ghway f:irough
the Great Smoky Mountain Nationcl Park, �vould resu'.t i� ma�or short and loag term 3dver;e
emironmen;al impac:; ;o this largely untragmentzd ecosystem. Based on the chararer and
nat�:-a1 fu�c:io.^.s of tiz ecosystems and [he potentiat Tor signif:car,t, adverse effects, :he
dzpanment feels that che envirozmental ooncems that :zd +.o the adop[ion of the agreement
cun;inue co be cumpeLing.
�Je eeao,!rage cne �'ationsl t'ark �er�ice to concinue [c coordmate ��ith our resources azer.eies
as add'.tiona' inFurm::uun is r.eeded.
S i nce� e'�}',
�`1����, ,�1��_
Melba McGee
Bnvironmentzi Review
���.�..,; e�r=
,���1 S4al Serri�e Cents� r�ale r,-� Non!� Csrolina 27699-'�001 .�OI't�l1���i'O;l(Il�
,,,� ��,a e .,�Ga1 nr.�. C . �.F-�J� .�.. f"E�� i�V �E1.5 .c...C. ��.'i`r��:",i �l11bkA�TLLSL4.�
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lYlemorandum
Division of Fnvironmental Healih
7erry L Pierce, Director
Public WaferSupptySection
Jessica G. Miles, Saction Chief
Dota�, Febr�nry� 13, 2C06
To: Iim hlcRighi, E�vironmencal Engineer
Technical Services Branch
Fron�.: Ruy hlcCal!, �VaterTre�[rnenc Plant Consu;ta�°,�
Public �Vater Supply Sectien, Asheville Regicn
Sub;ec�: Envirocmeni,d Assessm.en[ Review Commenu
i�ban Shora Road P:oject, Swair, R Graham Cou�[ie>
Greut Snoky Yfauntains �'utio�im! Park
srare c,Narn cam,��z
M._�ae' F.Exzle��,Gtr.arn�r
oayaam,enrore��ro�neniana
w�ii.ar. G. Rozs, Sec eiary
CVe na�e comnle[ed a review of the above� North �hure Road Pru�,ee� w I�ich, will v�vecse :he shoreline of i.a,e
Fon�ara. F:om o�.:r revi�w •.ac ofier;he following cumr��ents:
..4s proposed �his major road �rojec: u�ill impne; wa[er qualit}' plono ,he shoreline uod inro Luke Fontsn2,
wtich is � soarce o€ dnni;3ng wacer supply for the Fon�ans V illsge ResoiT cemmunity.
_. Al�:�ough ihis Envlronme;nt�l .4ssessmznt docs �dd:'ess s:�orce u�a[er fmp�c[s, [tis assess,�e,�t does not
uddress d��.recc impaets ro thi� dr.nkin�. wa:er soerce. Should ehe "Souihem-Fontana D2m" uption be
chosen, tnerc is a chance thz; direa w;:ter quality impac[s coul�i ucour vzry near this water suppiy
intake.
� 3. it �s ro[ �.pnrer -ta: dl:�ec' i-rpn::[s may c, cu: ro[h . F� nt_na Vi.laoa Reson +a r sour�e� wi;h euch
op io� that is p�opased and ��hct a;t�o�s -nay bc t�ker to bc.:ter pr�tect the drirtirg u�ater source.
Shc�alc you havz quesdors conc:m�mg [hzse womments a; nzed �ur.her expla;�,ations or in.`or.natlor. please feel
free [o cor:tact us at (8?8) 296-450C_ ,
Agency Consultation and Coordination - 5-12
North Shore Road Final Environmental Impact Statement
2C9C uS -i .� ��ay 70 Sw rnonoa, or'� C crtn . 2 77�-8211 j �.
el.,?h ne 82a 295 450G ♦ ax 8 8'99-7004 1�OIYhC61L011I7.3
r,np:i���.3nnki�ywai s.ate.n�.�s� ��?l7�IlClI��!!
z�.�z ��FCO . t. �i. �a... n_.,,r.cr.�F���.

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NCDENR
North Carolina Department of Environment 2nd Natural Resources
Division of Land Resources
James D. Simons, F.G., P.E. L2nd Quality Section Michael F. Easley, Gove:
Director 2nd Sfafe Geologisi Wilfiam G. Ross Jr., Secra
D4aro1�: 2. 200ti
ti[EMOR�NDU�I ��'� �,
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T0: �telba VIcGe� p�� -��"�'� .>,, Z��`��
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FRO�?� T. Gray� Hau>�r, Jc���.c� �,
State Sedimentetion Speci�list �`�`���,,
SL1iJECT: �orC'u Shore Road
Draft Environmzn�al Imp�ct Statement
Great Smokev 2vieur.:ains Nztional Park
I nave reviewed hvo porions Qf th� DET�, the Surr,marY ar.d Sectior. �1.4._, Water Quality. The
documea� does r.ot �de�uately address Cha >nvironniental impacts of tf:� Buiid and Partial B�.ii;d
Alternativea. Sedimcniation pollution is dte mosc prevalent cause of stream impairn2en: ir. \orth
Carolina. The t�or.!1 S'I:ore Road c�nnot be built �vi[hoet causins hiah leveEs of sedimer.[a;ion
and turbidiry in tro�.it streans. All :hc st:e::m; il�at would be impacted are ciassified by the
Enviro�nnental �4an�i�e�i.ent Con�imission as Class C, Trout, �vith po�tions ot"some ;treams also
classitied as ���5-IV. NCG�,�-�.'k1.3A-�7 nllows lancl disiurbanea �vit;iiii 2� feei oP�the top ot die
bank ot" tteu[ �va[ers unly �vh�n "Ch� durn�ion oE said disturbance wo��ld 'oe temp�rairy and Lie
estent of said disnirbance .voulcl be minimai" Bndvin� the s[rezm crossings �vouic ua
recessary, �vitli e.<[ensive provisior.s for sediraentation and erosion control. Tha best av�itable
technol�'s"`l �cotit��i no! rrevent vioia�::ons oi tha wa:e; q!:¢ility star�,dard fcr turbids[v ir: tro::t
�cafers.
P°Rnanen[ impac[s �could result from boU: tl�e pa��ed or gravei roa�. Coetinuzd sedin-enta:ion
iruni gravel ru :ds is a weli-documented problerri. 7he imperctous surfac� oFa ra�.�ed road �vou!1
result in incrc��;ed sronmvatcr rino:f volu�r,c and pcak disehare�, resul�in� in str�amb.ink
erosion o[ rcc�ivine wat-c,courses.
A�tealpts to estaoiish groun�+. cover on acidi� soil; e[tcn iaii, �.s evider.ced by hi�-h>vay projects in
V`or[h C2rolina tki:o��.�gh B12ck Creek Clay <oils. No coi:fidence shouid be placed ;n p:oposal.s to n,�r=r,q-o�
- •,�, �,a
IIiLU�:i' � ��I
,, .c �r neutralize �cidic ar�..naee. Notaole are the f�.ed aftemp's to provide �rou.�� cove: �
and control acid mine drair,age i;un� Ore Knob in Ashe Cour,t • Exoosina acidic soil� in Great
5�nekev ylounta�:n �vauona� P..r� .vaii� he �o ceoloeieal d!ssstcr. Tne Ura.`: cnvircn-:ier.tc�i
Gnpact S!ate�u°n[ has no basfs fer concludin� th�t :he Build or Par!i�:l Bui!d Altei?�ia�ivas ui<,uld ��c'F�'`�-D�
r�et "unoair" tlte nark. I? �s .n �rroiti:ou� : oncl��ision baced �2n inadeau��:e eeaeerch.
�6 i L ���ail S_n�ee Ger� �_ .i�;n 'Vc�tr, C� olin� 2; 699� o ; � ° �9 , ..3 4�'-' I �„'� J ., i., __„ .
, � Ncr� � �a.�_b�ry S: . t, -.a � y�i . .,�rol ��. ?'sg�t
O�y �G
O �c
�rErtoa�.nnumt
�evu���am �. noss �r., neCre�ary
Nor,h Caro'���.na pecar.rem pi Emironment and Natural FiaSOUrcaS
A7an W. Klimek, R.E. Di: ector
Civision of N,'ater Cua!'�,.y
ivlarch l. 2006
, Tu: kfelba bicGee, Envi;onmencal Coordinator, Otfice of Legislative and Intergevemmer.tal
' Affairs
' g �t✓
Frort: Briar. L. 1V;znn, Transportation Permictin� Unic, NC D�VQ
Thrcuefr 7ehn Hennusy, Supzrvisor, Transponation Permi[dne Unit, NC D`'�'Q9�
Sub;ec!: Draft Er.vironmzntal Impac[ Scatemen� for Nor[h Shorz Road ic S�vain Ccunty, S[ate
Clearin�house No. C6-0214.
Thi; offica has reti'ie�.��ed th>_ referenced documen[. The Divi;ion o€ Water Qu�liry (DGVQ) is responsible
fer [he issuance of cha Section d01 \Va[zr Qu,ility Cer;ifca[ion for activicizs that imp�ct �V�cers �E �ne
U.S., incicdina wedands. Tha Division of Water Qualiry oFfers the following commenu:
Dac�uneru S��cifc Comna�nts:
1. In �er.eral, d1a Drai[ Environmental `.mpaa S[atement (DEISj repor.s that the proposed Par:iai
Build and ��otthern Shore Corridor nitamz�ives would huva mujor adverse impacu to ti��etlands,
rrzams. ]zkes. ��.acer qua!ip�, aquatic ecolog; ar.d vege:a[ian communicies. Thes� al�ernacives
wo�ld r,ut nieet �he stated eoal<_ of [he pmposed project. A: dlis tima, DWQ does noc fe�I th3r the
potential 6encfits ot [he Puroo�� and Naad jus�ity the !ee�el of adcerse impae�s te these resources.
2. The document sia�es inat the Pirt!al Build and North�m Shore Corrido; altenativas �veuld
provide access for some cemeteries and remuve xcess for others. Based on remova] of acccss oi
� s`eme cemeteries, it is 4ncler.r "o�v the P:�rtial Build arrd North Shore Road al[ema:iv;s �vould
� n:eec tfye goal oi pr�tec�irc [nc tangible a;pects oE cultural reseurces. Pleuse provide addit!onal
in*ocmauen tu clar'.fv this issue.
3. 1a section <F?.S, cnz decumene sea:es thae adverse impact; !o czme;erias would oec.ir as a result c
the P�rtiaf Build und Nenh Sho2 A!ternatives due to "a�[tiag cur;znt NPS-Provid_d vzhicular
access." lt is unclear �.vhat t�ie A'pS-prcvid�d vehicular aecess co,^.sists oi. Pleasa descr.be the
?. DWQ is axLen.ely co��cerned about [he lon�-term impacts .o wa[er qu �liry resu!ting from die
expo�ure of acid-proil��cing �A°) ;oc'.t for.mations doring ro2d cons[ruc[ion. Ccnst vction ef
p; zvious p:o}zc[s ir. a:ws �aich AP rocF: has rasuited in de;r�dauen of �� ater qu�iity �,vith no
pr�cricat solu�ior,s available to re��er>e tne impairrnen:. The DcIS indicates similar rock.
Eorm��u�ns are p�esent throL,hou� th� siady area, u�d the Nortrzem Shcre Corndor wov! i i� �ofvc
;,cn;[ructi�n in rie area ,�ith the hi;hes potential fur acid produc;ion. P1Case p•ovid=_ a
di>our�on ut [he sca[egres ma: wou:d F. �T:plemertea to pr�v,n, wa�a; q�aLty:moa�rm�n� aue �o
runofEfrom AP rock.
T`":�`''�;,rc.�ro:,a�
an Nor� c 5 � iY g�J I � ti f?I'i7ilf
. ^!la ce .er„r,'3e.jh.!om4Caol �c
.; l;n�u e ow,�._var0, i:le 25q �ala�h . Cam��mz��
:-_. �3�,,,o,-.__-_.__6?53� .� I:nt,_!i�2� �r��a;?.n u�..�ei�e.itls
�_», .�y-� ,i_. ,..�Em; ,.,,:. , .?oslC . �.rPapa!
Agency Consultation and Coordination - 5-13
North Shore Road Final Environmental Impact Statement

P�;e 2 of 5 -
_. In seccien 43.I?, the DEIS sta;es thac up to 29 million cubic yards of excavated material woWd
be prodeced by the Vorthem Shore Comdor atternaci�e. Ti.is is a significant amocnt of
excavated ma�enaL Due to thz eeologic�l see�ing, the:e is the �oten[ial for much o tf�,is matera!
co be un<ui[ab;e t"or fill marerial in the cons:ruction of zmbankments associatzd wicn the roxd.
This is especialiy truz for are�s of AP reck. The DcIS dees net dlscass a disposal plan for this
ma;e,iaL Please descnbe how and where tliis material witl be disposed of and v;ha: the cos[s
esdmates of tne disposal would be. Thls description should imludz besc man�gzment praaices
`or vea[ment nnd their associa[ed cos�s. Please 6e a�vare thzt �ae DR'Q wikl r.ot allow disposal of
excavated material in s.seams or wetlands. In additior,. anv stcrm water draina¢° .hat contac[s
Pa� e 3 u: �
violarons are likely ta occur if any build scenario is ;elecezd. Ii thzse violations occur a; NCuEVA.Dwc]��2
especced, weter quality impairment it a likely autcome.
I[ is worth noting �ha: die Nonhem Shore Corridor al�arnativ� could potentialiy impac� over 4
miles of stceams in the project a:e� much oC which inciades the Great Smokey Nioun[ain i�Ia[ienal
Park and a nominated Outsear.din¢ Rzsocrce �i'a�er ;OR��') war�rs'aed. ?c is our understanding
that impacts oi this naanicud� would no[ be in xcordance «:th the Na[ionnl Park S�rvice
escavated materiat idzntifizd to co�cain A.° reck will not be allowed to discharee untrea.z to 13. sn August 2005, D!�'�1 biolo�is�s comoleted a benthic rr�acrcinvercebr�te survey of se�zrel
surfac� �.vaters. represeatati�e ribumrias zione the �orth shore of Fentana Lakc to dztermine if [4e strzams
cualifed for Outstanding Resource Water (ORW) desiena!icn_ AII bendtic rr.uaoinver�ebrete
6 -�° � imzs;one would'oz needed forencacsu;�cion of cellec!ions e��a!uated scored �n zxcaller.t biocL-�sslficauon and i�di_n;es �he tr.bu�aria [o the norl•,
A? rock to be uszd in :mbanknencs, ar.d thac the nea;zst auarry i= 3� miles a�vay. Do thc hC�CtvR.D�^;,�-3 shc� of Foncana La';e qua!ifv f�r ORR' de;ignacior.. In addi:icn, ,he biolc2is:s noczd tha; evuy
[he r sed altematives include the limestone haufino costs'? If not, these eample collected from this s[udy included a[ Ieast one rare muy�ly or caddisfly .4n extremely
costs shuaid be includ.d in ,ne ccs� analysis In nddition, rh� cou ana vs�s in open ix �, en y rar: caddisf'y, �Llapntrichia nymr,n, wns col!ec�ed et the E�ele Creek ;ite. This panicular taxor.
di;cusses the [rea!r,er� ef embankment ma;erial fer?? rock. AI! �xcavated 2nc ex csed AP rer, aapea:s ius[ ei;ht tim�s in o��er ��300 of D�ti'Q'; becuiole�ical collections thrcu�ho���t [he Sta[e.
P uccENa�obvi� �
woulu reauire treitr�e.=.�t not jus[ nat�arial used for em�ankrt�.er,[. i he ccst �n�!ysis should reflec: The presence ei s�ch rare and diverse be�rthic communities emonstrates tre cri>�me hati!ta[ and
additioral co�ts oFtreaiir� runcff trom this maten�i. ater �a�lity pro:ided by strear-�s alc �'he nort` s�ere o� Forotans Lak:. DWQ is p:r� cu!�r:y I
cor.cerned aba.n [ha potentia! loss of thes� ��.�nique communi�ies i; �m, o` �he Nor.hern �horc �
6
!h;es�o;:ls for negl��ible, m,�o;, noderate ard ma,or mpacts DWQ fee�s that [i:e ir�p .t
thres �olds sheu d b� adjusced ,o retl�cc t6e ra�ity a�d �he relati�z sig�incance ef we[� n s i� c:iis N�o r.ti-�w^=F
ar�a. DWQ teels uia� ��ny impac[ ro�tie�lsr,ds le>s iha� 0.1 �c,es is �it ieas[ a moderate u�paet, �
especia!iy corsicerin�� the rare ohanl snd onimaf com: ;��citias �hat occur ir these �.vetlands. �
,. I�� Appendix \-[ dia D°_I5 p;esen�s the individual s�re�m !mpac�s tor each �ltecna�ive. I[ is uncl�ai
�.vhedier thzse icna:ie[s are dire=t, indirec[, or [he cemSined direce and ;ndirect impae�s for esch
stream Pl�a<e rro:ida'th`e'�mozets associmad lviel�� e�ch s[resm for each altemuti��e 6roken do�vn
into direce und ind!rece impaets. '.n additicn. plans? provlde correspondine fi�u;es snd riaps e;iat
� s!�ow tte Ix�tion oFench imp;set.
9, I fc section �}.u.3 �, u:e d�cume�t ;tates �ha: for d.e buiid al[zmntives. �Vatar Quoliry S�ar,d�rd
vio( �[,c�s may occ�r or ore ;ikelv �a �ccur. A. Ner�h Ca�ol ra 40l ���u�ei Q��Iiry Certif=�:.on
can only ba issued tor a projzcl tnu: provides adeq..ute a�surances tnst Water Qua�lty Standards
I and �Is:harec guidelines w�i! not be viula,ed. Based or. ;he in`orma�ion pro�+ided in i;�e DEIS,
� D4V7 may auc be able ro is>ue a�01 VVater Qu�lity Ctrtificution for che bui!d aitems:ives
aSSOCi4:d� Wi[h Ihis 6:oieCt.
t0. S�ct�.on 4.4.3.d, ,r.r���ides a c�scu��ion of the Imonirmrnt E�a1 ;atioa, "impaired w,�uers" is a ter�u
�„I^r�ci'n vurPacr. �,�i;erc rha; dn not meat a,sneinted wn'��r n_� lih� stand�rds. These',�'a[dt� �re
list�d o,� the 303(di fise of Unpaired Waters in accxa�nve �s�rtn Che Clean �� a[er t�.ct. It is uncle
�=;hethe: u�e oI ihe ��vQrds "impa�rmen[" o_'•impair,�' uatess" �.n !he document correspor.ds with
tl�.e ma.r.:n3 of the words in the Gzan Water Act. ?I: asc p���<�d° a denr.ition anc : mo�a in-
dept'� discussi, n oi "i��nairmeni' in th.�� DEIS.
. � DW�,��i ���;re ; w��h [hr _,,.J.u�ion ,��at'mpuir,;ia; �u� wa�e �ual�tv �y u� I��kefy tased �an cuRC ��i
,���rr_ti�n. +�s:,,.�.!p.��i.�.,.>e:aon4.�.3,�,L��ItcSa�_,-_s,l;e�c;,tc-ti��i}�-
,.d��Cs
1-� he st � Ts alum r e nerthe n ho,-e ot r.,ntana' al h�, e � r n�i t d t r ORW
�s� na, en. T�. _ i�i� Env'wn.��ur,al ��Ianagerne. � Conn,l�_I�_� — Vur Q a�J:}� .. t �.�.<.. h�<_
aporove�l statf [o dis�:i'ou[e �raft rules fer public ��onr.�tn�. These rules ir.dude sceei:il
resCrietions on ¢onstructior. netici;}� w±th��.n the �f'Pee[ed �rea. "�hes�� re;[ric;ions mav �dd
:dditlunal cost to cunstruc[ion n;ojects. it is unc!e�; ��:�ethcr thesz aUdi!ional cos[5 ha�e been
inc:uded in �:he cost znafysis'or thi proposed projea. 'le: se inciu:le the es[imu�ed ces[s of
me<ting t,�ese addiCiun�l restria!ons i� thhe cos; analvsis for e';�e build altematives.
Sn [iia �ve�� [h: t a cons[ructien nitem�tive i; salec[a�. xibs[an[ial mitigatio ;�vill likely b�
required, 1: is unc;ear �vhether suffici�rt m![igation sitds are ar�ilabie �+�itl�.in �he 3-digit
hycro og;� ua,i� coda (HLJCI :nc'o; e_o - e un L t� e_. ,� ntuz�ucn .s .i �:.'�:lub�� ,n �i�e. w?..
prozac[ I:s .�iihir � I3iospnn:e Pre:er�'e, SnJ moscsfm'�.lar ;�a,�rshe�da �utside �he Fart;'ooun;3;�v
:ill �,vuhir, Na[ior,�l �cre.,s. Pl�use �.rosid� a di-�_in���n oF;,o,<<.:�� i �'i�i�:.t�u �_�r �r.�zies fo. :ni
C;e.¢�ra; G.n;meri:s:
L A[,,.�, „r. ,ziec[i� �., t`.le prate:reo ni[erno[h2 and �r [u an issuailc� ci U e l;. �1�a.t; C�u,.ii�y
Ce n` au.on. [he App�icen[ �s , scectf��1'.y 2mim e.i [nz[ thea :� i(} need :o ier;:o�str�te tF.e
avo�c;:r.�.. ,:n� r�:,..,,.�at�- , of �:r.pac�s ;o u�eilards �... s r� �,i„ ::, .! :, m,�r.n��n. �,�[ca: r..nu!.
Should �he irz: i�„ .�;unsd.�:tier,�l ���et�a,.ds ex: eed I �c-c a;;dlo: io�i..�sdictio-•al s,r_nm�s
�:<:eea u0 iirea� teet, n•i i iuc,n cvil' be required �- �ccorience ��u` ;��DRrQ �Ve:la�i� Rcles
;1�� �C.s.C2i1D;J6rh}�._2',;.
Agency Consultation and Coordination - 5-14
North Shore Road Final Environmental Impact Statement

Pa�e 4 of �
2- As pan of the 40't Na[er Qtiality Cenifcatlon Application process, the Applicant is 2sp�c[fully
remindzd to include specific; for boch onsi?e 2nd oftsitz mitigation p!ans. If mi[iga;ion ;s
required, i� is preferabie to prasene a conceptual (if not finalized) mitigation plan with the
environmeata; dccumznt�tion. Whi;e NCDWQ re2fizes [hac this may not always be pra�tical, ic
shou!d be coted .hat fcr projec!s requiring mitigation, appropriate mitigation plans wiil be
required in conjunctio � with the issuance of a 40l �Va:tr Qealiry Certification. �Vz underst3nd
that NC DOT wil! rzquest compersatory miti�acion through the ItiC Ecosystem cnhance;nen[
Proeram for offsi[e mitigation.
_. Futare doc�lmentatior., includin� t:�e 40l �Vat�r Qc�Iity Cer[ifcation Applica�ion, should
cer.tinua to in-:1ude an itemized listing of the propesed wedan� acd stream impac?s with
corresponuim� mappin�.
�t. �An aaalysis o( cumula�iv� and secundary impac�s ae�icip�ted =_s a resul� of this pro:ec[ is requi
�The tvpe a �d de:�il oi anilysis shou;d conform to the NC D:visicn of Wa2r Quali!y Pulicy on
�as�e;sment oFse��ondarv �nd cumula:iva in:oac�s da�ed Aoril '0. 3004.
5. Ti�a �.pp[ican� is re�pectfully reminded thaE a:l impac[>, inelucing biit not limited ro, bridging, f Il,
e.ecavaCion �nd cle iring, to jurisdiccionul wedands, sr.eam;, aed ripanen buft"er need ro be
ir,cb�ded in th� final impact ealcuiations. These impac[s, in addi!ion to any construc[ion impacts,
tentporary or other.visa, also naed to 6e in_luded a_ part of :he �01 !Va!e: Quality Certitica�ion
Application_
�. �5'oere s[reams mu>i ba crossed, the D�VQ preFer Lndces b� used in lie.0 pf cul°.cr;s. EI���e�;er,
we realize :ha: economic considerations of[e^. requira the u;e of cul��erts. Please b�° advised �iia[
calvers shoul� be ��_ountersunk co al!ow cnirnpeded p�ss�ge by t:sh and other aquatic or�arisms.
�!orcov�.r, in are�s �v��ere hi�h quality wa�lands or str:ams ar� imaacted, a brid�e may prov4
preferaola. �1'6en apolic�ble, brida� benn sheuld r:a be insta�led ie the cree4:, m the r*ia.�irnum
e.�;ant pra�[ic�b'�e. ,,- �
Sediment and er�sion control mensu2's s[iou!d n�t b� p!uc�d in v:etlaads.
8. Bbr�o�vha'uste a:e�; 5hucid avoid wetlands [o the na.eir.��urn e,�tcnt practicab!e. Imou�[s ro
we8ands ir, bon�o«'��:as�c a�eas �.�ill need [u be pr�seo�ed i�. tF.e 40l �Vater Qunlit} C�:ti:=icedon
ar,d eould pre�ipi[a;e comE�ens�[o.y mi�igation.
9. The d01 �V�ter C,,lu�liry "c;ertiFcation applicetion will nead ro specii�csl;y �:ddrass the pr000s�d
methods fcr s�orm �.va[er manaeenier.t. Ivfore specificclly, storm �.vater shouid noG be permitted �o
di=_charge direc[;y i;to streans o: surfaca wa;ers.
10. Based on thr inier.rar.on presenred In the docune��!, the m��itc�le of impucts Eo ��,�etkar.ds ar,d
strea�is may ;eq��ire u� Individual Pemut app!ication to the Corps or Engineers �nd
cc7esrandin� 40! W�ter Qua!it� Certiiica�ion. Plense be ad�ised zhet a 4U! 41'ater Quu'si<<�
C:rtifiea�ion req��..ires satisfecrory protection of ���ater q;::!irv ro ensur� �hat �vater quaiity
<_[:�ndvrds are �r.et and no w�denc or �t2tin uses a.e iest. Finat Permit autheriz�rion oaiii reGuire
the submittal of a Yor� �sl appl!�ar:on b;� th�� Applic�nt am� wri[ten co�currenca fro�i !he
N�'D�VQ. Pieu;e bc cware d:a� an� approva'. w=�.11 ';e ��_on�inPent on rppro�ri�ts av��idance an�l
n.� �imi_a.'�.o. e� .,�.�. � c ��.d s,re�m .m,a��s �o �,1: ..s:;<,�n;m �x�ent p�a ?:c�l, � � �ie, .�.oc�e:_t ei
Page 5 of i
an accepcabie storm wa[er manag�mznt plan, ard the inclusior. ot appropriate mi[i:a:io;� p!ans
wnzre appropria:e. �
D�VQ appreciates the ooportnnity to provide commants or your project. Should you huve any
questions or require any addicionaf information, r(ezse :cr.[ac, B:ian Wrer.n ac 919-7=3-57li.
cc: S�ave Lund, liS ACE Ashevilla Regulacory Field OPfice
biar!a Chambers, nC \VRC
b`:arcl(e Buncic�, L`SF�t'S
Chris bfili!sc!zer, USL-PA
h'(Ike Parkar, Ashcvilla Region�sl O[:lce, NC D`.VQ
A:ex Mur4;s, 1�C D�VQ, Plannin� Brsnch
File Coov
Agency Consultation and Coordination - 5-15
North Shore Road Final Environmental Impact Statement

���
�����
NCDER�R
No��th Carolina Department of Environment and Natural P,esources
h:lichze!, F. E2sley, uovemer 'P(if�an G, Rcss Jr., Sar!�rj
;viarch 3. 2006
i�tEMORANDC���M
T0: Ntelba �1cGc�
!r L
FRObi: Ham� LeGrand, i��ar.:ral Heritage Proeram
Si;IIicCT: i�`orth 5licre Roa� DEIS - Gre;�C 5mol.�� �:Icu�:ains Nationai Park; Swain Cour,r_.�
REFER6NCE�. C�6-02l4
�1'i \�[ura Ii ��a �e pt� r n,� h s. c rc ord� oY rare �pe�ies im7i the p;oject ar z 1-,d �
:��nt�a' ; t11� � i e\o � C�� ro�ina pur�io u, Great S�ruSy titoun�ains �Iauo���il P I. is a�
�e_ut;r:,i �a[u.,�l He it4_e A.,�,.. ri��acver, L�ecause the r.at;onsl aark ilas it's o�+�n n>lttual
F.enta�.: pregr:.m ans databa�e, n,>>ch if �.vh�eL has r.o: been s'i�ared ��ith dia Nosth Caculina
V�EiP, nuc P ogiam �±e:�r. !e ti_e Naiional Pack Sec�,�ice ior ;nfom,arioo a�out tl�e si�ani6canc
r.an:.a: h�ri;a_� re��urce� ir, t'r.e croiect a,en.
C..u,� o�; data aie i i i�� ;�Iete ��o: ft�e proFeet aren, ara bec, we o�sr Program uau:i;�t :a�i� d��at
�:e VC Deparrnent ot" En� iror,ment �nd �iaturaf Resourees is plar :in�, t� comn:en: on the DBIS,
� z 3,:e, 'o dic Dep�rmeat reg�rdin� the p:oposed 1`�rth Si�o-e Roac( project.
� . _ 1 �.., . . .:v � v Y,C�.. �i.i'��:
� ' _ � � ""' _ -- ���'�[l�s.�a���f�o(..
�� \TOrth �'arolina ��ildlife Resources Commissiotz ��
Richard B. Hamiiton, Execu�ive Direc�or
�IE�ipR.4�DU\4
T0: hle;ba VIcGe�z, Em�ironmental Coordi,�.atc�r
Offica of Le� islative �nd Inter�ovemmental Afrails—� ��
� � �
ERfJ�;: Dav; bicHury, Vloimta�,n Re:icn Coortiina�ar��fa'�'�
Hab`.tat Conscr.atiai P;oa;ain '�Ci�
D:-: CE.
�UI31E(:T:
P�b;uarv _0.?005
Comntent; o:i tl�,e Vorth Shora Reac Dr:�{t 6m�iro:ur.er„a! Ir.�,uac[ �'ar��r,en:
OLIA OG-03 tJ
!�r� �;;�[s ��U! . e A'o �h C�rciina �.VilJlifa Res� .:.es �e-rm .,i;��� (Co��r.�^i's��.���) ��. , .� d � . , �,�h
:n_�c Rced D-�Fr crviro�� *•�ental Impae[ State�ne!tt;DEfS). Cem�:�e�i,s o� t!�� GEIS �-om!he
. .mirio^ �re oC;are�' r zccorda.ice ticith pr�v �.ons �: th�e F�sh ana 1 il�.iiie (.e-,rdina;�C=t .1ct!4S
.,.t 4Q1. a= sr�ended; iG :;.S.C. 651 ._t sey ) ena t��e A'atio��a: Enaircnm.ental Poliev ?.cr (:,? U.�.0 �,33?
-,;'c)
� L•e CF_IS r. ��Irz.s Ure u,:iro: :ir.�al cen�eq��enczs o� al.zr ,at.�z> L_�r1 corsia:re:1 ce .'�e \rticnal P:�rl:
Se v�ca ;�lPS; �o >atisfy �he 19;3 4greane�t net,v�een the L' �[ed States Depa:ti��act o� I,tc�.u�,'I�e 7e-mes�ea
`�aua � Aut!=uery, S�ua n Co;!nn�, and the s*_ate o£Nuith Carolira �o ba�l i a ro�id alun_ �h: m rY i �ora cf
R��ntnr.o L�'�:e. The bu��,id altarn�ticas �,��ould zFfeo[ E:or:ions oi :i�e G;za� Smo:•:y \�i�o��:nnc�s \iaiionn' P:r''�
(GJ :Ctie'j'.r. Jwain Cour:��.
r...._��__ ..�.'e �. �cusr, �FtecG c;: ;:�.. h�u:.ii:i �>�� a; d�,��i���Ii�_ �:;scur �o an�l l�:�l��ta.s z:;n c _,� .�,`.
�n ,,le.n�°.c�t,�i, �ft'�.�c buifd al[emative>. Se�',m�n?stfun �f:cre.m�,� c.uin� co��,istruction �.nC� fi� m ro d��u.;
anu s'�,rcam ch�r.nel eresicn r,�.�. constrcetion is I�r_:�titiec ic u':e DGIS as a pri;nar: conce;n fcr uquauc
reso�,rc�s. L'nst;�l:le geo!os�*�� and steeo �opograp;n� in most af nic prolec, arec ���ould r:�a4:e �:osion oor,!ro!
.i�, i,I�e ba'Id af .;r, �t� . son:a o.`«hieh ���c�l� in;roh�e � �-r.si�:kerao�:. ear�ii���orn, u f�� �;:( , not :�;il:ost
:t_:.: �e. ��? �;uc��ar :c��cerri ,veuld be ?�brth Sltett _erdc'�or a!b ,n� ive� ih�� wo�.,lc. cro�s ,;t It .st 130
;rr�,�a�s, �cu�e zrd chrnnic erosion an�1 sedimei:ta[ien a� stream crossin�;s u� eon�u��cnon �.vr i:oses;
�raamanra':oc, and de�ra�ztior. of predi:ed'��c streams, rip�rian ar�s, �.s2d^_nds, en�i rare terres,rini
,.r��ai�itlts �ro^t _un�;r,:cuoc, h����.oL_k a.t�r.t on__ i��,a,i;� specie, in[rud�.�ti�n< a�d crh.r 1;2cte s u�e e;
f.� �. r.t �. _ i.udz P�. �an; e �� i..:o,^� ��i � i!d zC: ..� .!i :i � ro:� i.. �.i .:.sis,
� i_:� �I�� m � !�t_ .��r.�.� tiPS'.:i t �ican'�c l � �f !91 ��_o n � �s��c.� :_ _ �i arlv o � _n� . ._ �,, _.
Ii.:nn�, ����1�er.eS:uiJ ���i��iit� r �c�i.�.s of\u ,h Car�i .i.. �ar tlie ��t,�,: �� ��.;t :f' � cir�;z.�>, � ..�:�t �,i., r : tii�n
_.. ,�.�.. _i+, �.i���. .,i. ad e:_. �.ii:c e.�U'Ct_� � rt. t`te Si.�� i_� � i zrt .� _. �L•e t�:.i �iss��.or. �.,1��: en ��::a�'s
.�'e� ;^: ,l�..t, _:�.:� 1 _��lltl_i _I�Y .'CeFC, ..i. Hl „(r�;. Iv: �,.�.�1'�_� I'_ fll.', i�1.�7 L,� �.IiZ ._1� _....� c,( �'� i`.'C.
�� ul{�_� �.i�;�s: D i. .. ,. , �C� ..s 1' ,�il;._ .. ���t�r R . _ .A,_ _'i4+'� _;_.
�ir;�nur� . --- -_ ":ie: ", .._.
Agency Consultation and Coordination - 5-16
North Shore Road Final Environmental Impact Statement

Ncrth Shore R�ad DElS p�ge =
Pebr»ary 20, ? OCC
I�he niterno:i��e id�ntified as the preCarred altern2tiva is d�e ibior.e[ar: S=ttlemeat Alternative. Seleccion o; a
build altzmati�e ��ould do avoidable, lone-term harm to fish �:�d �vildlite resou,-ces that a:z critical :a thz
namral inte3nry of �he GSh.�P and �he misson of �he �1P5.
The Con�miss�on appreciates Ihe opporn�nity �u co��imer; on Yne DEIS reaardin� e(fects af iha projeeC on
Yi;h a:id wildfife� resourccs. If; ou n;ed ro discuss the>e commen�s ple: se call ma at{333) d�2-2�46
e�ten;io� ?=1
cc: b,rs. Cyndi Karoly — NCDENR, Di` iiion oF Water Quaiip, 401i\�etlands Gni[
�Is•. Becky Fex—V',S. Ecvironmen[nl Protzct:on Aeency
\4r. Dav�d Daker—U.S. AmiyCorpso.`L-ngineers, Ashe�illt
\lr. Brian Col: - US Fisl•. and �Vildl `z $ervicz, As!'.e�+ill:
l��I N(l� r�EC��I'!;=['
\ � ero � � ��.
��+8232 06€�iliR (4 P7 3 t�,3 . , �
w ti
o `l, � %
Tennessee Valley AuthoriTy, 400 West 5ummt HIII Dnve, Knoxv��lle, Tennes ee 379�-ifd(�71- !J ' I�, � � '
�XECUTIVE S�CRc i1�RlAi" t . ��, �, '
p��.. ��..
Bili 8zxter ., �
l71lEC10! . � �
March 10, 2000
The Honorable Gale A. Norton
Secre!ary
US Depsrtment of the Ir.terior
1849 C. Street, N`�,�
Washingfor, DC 20240
Dear Secretary Norton:
Tho Ternessee Valley Authority (N,4) is a cooperating agency in the prepara'ion of ;h=
Emironmental Impact Statement (EIS) on the North Shore Road Project in Swain County, Norfh Caroli�a.
In that capacity, we are curr�nfly reviewing the Dr2ft EIS and anticlpate submitting comments as a
�ooperating agency at a later date. TVA is also a party to the 1943 a�reement under wricr construction
of the North Shore Road is contemplated. I am writieg you 'today to app�45e you of NA's postioe on
this propos2l.
lVA agrees with ths National Park Service'�s (NPS) determinaP�on ChaC the altemative vdith the least
ern^ronm2n�al impact ���s the one that does not irvolve constructlon�, namely, the Monetary Settlement
Nlternafivs. Accordingly, we concur in the ider!ifcation of this aitemative as the Environmantally
PreferreC ARemative for �he purposes of Natlonal Environmentaf Policy Acf review.
The Draft EIS cid net identify NPS's preisrred altemative to allow consideration of public comments
on the completed environmental analyses and rev!sed cost estimates for the build alterr,atives. These
public comments and environmental anafyses will aiso help In(orm the decisions NA may have to make
ebout this. Based upon our prefiminary review, NA believes the range of identified alternatives is
appropriate and ihat any of the action altematives couid potentially form the hasis for an 3greement
discharging ;ne Department of interior from ony remaining oblioations under the 1943 agreement.
TVA has already fulfll!ed its obllgatiors under tne 1943 agreement by acqulring and trensfernng to
che U.S. Department cf Interior approximately 44,000 acres of land on the north ehore of Fontar,a
Raservnir Should ihe other pa�iies to the 19a3 agreement reach consersus cn the fVOrth Shc!e Road
issue and declde to enter'mto a new agreement, NA wouid be pleased to review tne proposal anc
dotermine if we shculd become a party to the new agreement.
Sircorely,
�l�, 1 J � �""�
Bill 6axter
Chai�mzn
_,. A4r. Cals A. Dl;manson, Suparintendant
�nited State�s Departn�ent of the !nforior
Na:IOnai Park Service
Gre2t Srnoky ^Aountains Na[ional Park
1��.-�7 =ar., Headquar,ers Roatl
GatBnbu;�g, Te��ne5ays 37738
Agency Consultation and Coordination - 5-17
North Shore Road Final Environmental Impact Statement

m
Tennesaee Valley Auihority, 400 West Summit Hill Drve, Knoaville, Tennessee 31902-1499
April 13, 2006
Mr. Dale A. Di!manson
Superintendent
Great Smoky �lountains Nationaf Park
107 Park Headquarters Road
Gatlinburg, Tennessee 37738
Dear Mr. Ditmanson:
DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)--NORTH SHORE ROAD,
FONTANA RESERVOfR, SWAIN COUNTY, NORTH CAROLINA
Thank you for the opportunity to participate as a coopetating agency in the North Shore
Road EIS project. As indicated in our letter of March 10, 2006, NA agrees with the
National Park Service's determination that the environmentally preferred altemative is
!he Monetary Settlement Alternative.
NA has reviewed the Draft EIS and has ihe following comments:
• Please include a Cover Sheet 40 CFR 1502.11
• 1 Sechnn C_5 Fnvirnnmontol Crvneoni �anroc onrl � C Im �r...�,.,t e.,..t� �.,i;.,., 4f..,
document could provide greater clarity on whether additionaf tiered NEPA analysis i:
anticipated, if a build or partial-buiid alternative is Impiemented. For example, would
this take the fonn of a specific document on a specific segmer�t, or a dor_ument on
mitigation aiternatives? Also, if tiered NEPA analysis is anticipated, the subsequent
analysis might be a more appropnate place to determine the Least Environmentally
• I secuon �.a, c;oaperatmg Agencies, first sentence. Reword as follows: "When more
than one federal agency is involved in approving a proposed project, NEPA
regulations encourage the agertcies to work together to produce on(y one t�iEPA
� �ecnan z,i �, companson ot Alternatfves, second paragraph. Reword as follows:
°NEPA requires that ali federal agencies consider avoidance and minimization
measures when adverse effects on the env+ronment are ide�tified. Mitigation and
enhancement measures are also to be considered for implementation to address
paragraph: "In addition, bridges or strsam relocations or other obs?ructions on
T9rltiBS582 RiYe� Vi6utarv sireams wnuld alsn renuire Sactinn iRa annrnval "
Mr. Dale A. Qitmanson
Page 2
April 13, 2006
Sections 5(Agency Consultation and Coordination) and 6(Public Invoivemeni). A
list of agencies, organizations, and persons to whom copies of the statement are
sent (40 CFR 1502,10) should 6e devetoped. This could be done within the conte:
Appentlix O, Great Smoky Mountains National Park Enabling Legislation. A large
amount of text was inadvertenily inserted in this appendix, following Section 4. Th
(text discusses pyritic rock and brldges, which would not have been in the enabfing
, legislation o' Mav 22. 1926.
We Icok forward to reviewing public comments on the Draft EIS and working with NPS
ard other ceoperating agencies to produce a fnal documenL Should yeu have any
quesFons, please contact Harold M. Draper at [phone].
Sincere!Y,
l �� J�C/ /�%
/
L� Jan tvt Loney, h�an�ger
NEPA Folicy
Environmental Stewardship and Policy
cc: _�'�orth �tuzLe Road Prpject Comments_-.,�_
Post Office Box 30185
Raleigh, North Carolina 27622
Agency Consultation and Coordination - 5-18
North Shore Road Final Environmental Impact Statement
rvn-�

- T O
4�' . Og
A
,yc . �2
iw '
o' �J t���`! m
`s e S
.:.w''`
DF,P:iRTYIENT OF T1iF, ��11y
W7l,pI1NG1'OY DISTRTCT, CORYS OF EncfNEF,RS
I51 PA'fTQN AYEn'UE
ROO�I ZOS
ASHEVII,I,F„ NOR'1'H CAROLiNA 28H01-5006
hr��t, z1, zoa�
Regulatcry bivisior.
Aciion � Vp. 2�)033U�74
�4r. Dalz A. Ditmanso❑
Si:perintencicnt
Grcat Smoky �tour.lains Vation�l Parl:
107 Pazk Hca�quuners Koad
Gatlinburg, Tcnncssce 3773S
`Jc:u,Vir. Dim�,a��:soa:
P1e:��4 ref�rcncc your J��uary, �pOC, correspordence requestina our rcvicw oCthe drafl:
Litvironmenial Lnpact St�tement�`DF,T�} forihc proposed cons[rucGon of thc Nvtth Shore Po��d
along ihc nort�.ern sliorc af FonWna C:eservoir throueh Chc "Fonlana Additiutt" po[iion oPlhc C:reat
Smoky M14ountains �i,�tiona1 Pack in S�v,�.;n County, \iath (:yolinn. Also reCerence our pre� ious
cerre;;pendcncc concun�in���-jth [he proposed Puroose �id Nced .i:;temcn; provided li; y�ur lette:
dnted Augcst 22, 20p, �s �vcll ns thc altematives to be carricd Fonvard lor detuiled analysis in �?�c
I�I�tS
We have reciewed d1. DEIS and provid� tie fo1lo�,vSnu coimnents ;�ncl recummenda[ions
ior inc�rpo;ntron into the nna] HIS.
... !1!e National �ai c bectiic? (NPb 1 has se'ectcti d�e `;Alnnetary SCttlemtnt Altcrn ��live"
»G4(b;(1� Gnidehres. The Monus.ry Settlement .AltemaU�u aFoears ;o be the vnly of
the studial ¢)tem�tives tl�e[ docs not !nvolva imp�cCS to �vatLts of thr (,IS and thus does
❑ot rcqi�ire u Deparrnent of tl�e ,Snny (D,4j pcm�it. Furtiter, th��re arcno uthcr adverse
envico�uncrt�l impacts identified .{or the 1�Ionetary Sctt)emznt?,Iternativc. �Vc
d�ereiore concur, baszu o� �h: inForn:ation nvai.aole at ihis tima, thzt',l�c ;�lonele.ry
Settletnent nitcm�tive appeais to I�� dic;cast envirunmenta�iyda��:a,ind aLernativi;.
We do not �grce Lhat the issu� oFl;rac,icubility has becn a�equately addressui ncr rha[
applic��ionoftt�e?G4(b)(1)guidel.inesisappcoptiatchere. Wcsuogestth�ttiie
11or.uary �ett'ement Alte:nativc be iJen;ified a,a the "en�iromticr.?ally pre(erred"
31te:ra,ive ar.d tlaat referenec to thc 4�4(b){I) �uide!+zies Le renao��ed You ar� ad���e�
th�? i`�thc NPS doeti e�•enrsally selec[ ;� `;prcfc:-n d aitemative" oll:ec tl� tci the i�loneturv
Setd�mcnt Ntcma[ive and that prefzsred altcntaiivc reqtires a DA permit, it will bc
�nc�:mbei2t uprin thc NPS �� provice fuither detailed ine�rmatioa regardin; ti�z
enti�!roivn�n<,ai co;isequei;ces ns �.vc;I ;s the coonomic �u�d lpeis:ic �ra�.tica6;li�y �f tilc
=1i[, tT �ti:�dS.
I��ac_-�
1
b. 'lhc NPS should includc all appropri tc availabie iiUomiah:on regardir.g Swain i iu�qc�-z
County'suscofthefunds. � ,
c. The docuntent states dtat wutlan� �vill bz fu:ther investigato�d to determine �he exaci f
impacts a!ong a�y corridor assoeiated with a permit :��plicztion. Tk�ece may �Iso be a� �s.ac=_-s�
pem�it condi?ion that requires [hc wetland boundaries t�e si;rvcye;l along any proposcd j
eomdor to f.^,cili�ate cotr.plianec inspecrions.
d. "I7�e liSAC6 is responsible for adminis�ering Section 4C�1 ofthc Cleun Wa�cr ncL Thi; ,�;gace-a
slio�Id be r.iade morc cle;u in ti�e secor.d p:u-.�grapti on pagc 3- �9.
a If a�entxit is rcc{uired/issued, nlitiga[ion may L•c tequired Cor afl imnacis to strc�ms a�td �
���etl.tnds_ A tin;.l da[emiination ofmi!i*ation �equircmenls u"vu!d bu made as pun ot �— uSAG=-s
any permi� �valnation. i
f. T1,c usc of bndgcs ar�d,'or bcttoiu:css ciilvrrL,- maq mduce impac�s and eli,ninatc cr
r��eiucc oemz;� �equirenents, if ic�p2cts coul;; be reduccd su,`fici�ntly, �'�a[iotnvidc c�,�
Y�mut mnybe ��ai!a�[c !hat �couiA:educc lhc tinte 3nd coordina:io:? ncc�tisa, io; ��
�ai;horization ry �
g. Il� a permit is requued'issucui and mittyntion is required, tnc US.qCE ayTCes tha,
resWration or er,!iariccmcni would be prefcrable to creation. Compensatory mitigation
rtios nay �e ir,creascd i Cthe proposed mitie�tinn is no[ within die s:ur.e watersh� a�
d:t et000sed imnacrs fnlf-snel
h. G Sec4ons 4.4.I.A a��d 4.4.2,4 st�te tiiat thcre is no artirpa[al impainncn� of wed.=.nds or
� strea �is ;usociated wit.i thc p:viia; build allern��. vrs. itnpr�ts n*e �os � t� with th;;c �- �
a�t�r�uve,a as d��scnbed in Tnblc 4-17a. S'le:.se �t sify wl°y thuru �.vou•d be rso � �-�� � I
impztrment.
.�J
.. Thcre sho•.:ld bc no ter,lpurary stockf�iling of matcrials in w��tlan�s or s!:c.1m5. �-- ��_iSa o
J• El�pp�;ndiX �l st2fas that no idstinction wts mndc b�ttvicen pc:cnni�l and intcrmi[LCn!
'�' ew,� segmcnts. Furti:e� scld,vcrk may Le requirc�i tu disti;;bui,h �;erotmial anJ
i
r
intcmur,ent sagmcn�ti �or ia,ermining miti�otior ncc�.
Agency Consultation and Coordination - 5-19
North Shore Road Final Environmental Impact Statement

R'c app;eciate the opportunity [o cooperate in [he EIS proeess and loo:c forward to
pm-ti cipaiing in fuFt�rc ir.tenguncy meetings. Should you have ahy fur.l�ef questions oti th�se
conmenGS plc:�,se con:act b15. ;�n� e Pennock, Project blanager, in the Ashc��! Ic Re�vlalcry Field
UIGee at (428} 271-�980, extension 226.
SinCCrely,
.�a..�k �-�____
David, f3:ikcr
Actiitg Chtef
Ash�vilic Re�;ulatu_ry Field OfGce
Copy fiim:�h�d:
�(c JOCk i'an pup
US 1�ep�.rtrnea,C oi Tr.m.>p�3a'.ion
PCderal Hishway r,(In�i�llstrution
214Cp Rid�c'ol� Ci!'cic
Stcrlin„ �'ir��ima?p;5�-C»11
hir. Dnvc McHtnr✓
\orth t'arolina Wi�di:fc F�esocrees �orvnission
20530 Great Smokey Mountain Expre�sway
14'a}ne;villc, ;Vortlt C.voliaa 287SC
Mr. Allen R:�[2laff
1)nttCd Jtates Fis'h untf VJildliic Ser�icc
tl5heviilc Field OfCice
1h0 Zilicca Streat
.',51�c�2'Je, Nortn Cari�linu 38bD1
i.4s r3c� }� ('c��
('nr�_d S!a.e Lnvir�rm�cr,t�J I'to,u;�,�on rAgcncv
134J Firefly Koati
1Vhi:ticr, Nu: ilt C:;vofine 2375�)
I�ZCC St. S
�; A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
< ��i ` FEGtON a
;� �A ATLANTA FEDERALCENTER
yrt et FORSVTN STREET
� P�o ATLANTA, GEORGIA 30303�8960
March 27, 2006
Mr. Us�lw ��. Ditmanson, S�.�pennter,dent
Nt�tional P��r',; Ser;ice.
Great Smoky Mountains �'ational Park
107 Par'� (��le�idcuartcrs Ro�ad
G��di�hure. �[�V� 37738
R[?: EP:� Review Comments on
Draft Environmental Impact SEatemeitt (DGIS)
tiorth Shore Road, Great Smokv Mountains �'a�ional Park
CEQ No. 2005t�54S
DctirMi: Lhtmainson�.
Tl��a U.S_fnvirunmantul Protcc[ion A,encv(U.S.EPAj Re,ion� revie���ed t}r�subject
Drd�r E'nvironm�ntal Empact SCatement fDGIS) pur�u�nt to Scction 3U9 ul :h� C!e��.� ��ii :�ct, and
Sec[i�?n 103 (?)r,G) u'the �etronal Er�vironmenteil PoGc�y Act (NT-;PA�. Thc pui�i�se or this le��er
is �o prnvi�e ycu �vith EPA's comment_c.
� he DE!S identifics Cne sin�,ular putpose for Ch�s tr�moorta:ion ��o���t as p oc�,din� ��uSEPA-i'i
�rr,pru� .d �i��ens ta cemeteries. The cemetznes arc rela[ed tn eo nmuriti�5 tha� exi� ed prior to
_� crez ion o ontana aKe. ne Wture tra �c astim�ites ao rot ��su � t7e roadwav or
connect�v,ty or mobility purposes.
The DFIS �isscssec the potential environmenta! im�;�cts oF ine no-build alte�rnative.
monetary se�ldement, Laiirel Branch Picnic Area, paniai-bcild and full-bui!d alterna;ives fo: tha
i�urlh Sho;e Road.'Che projett smdy area i��cludes a linear 3-l-mile portion o( �he Urcat Smoky
�'l�,wm��ins NatiUn�l Park ur�d a portion of tEic App�tiachi�n N.�.tion�il Scenic "t'rail (.�T). wh!ih ur:.
both indirid�:al units pf the rational par:� system.
ChL cntire noithara shore a-�a ie �ti ithin the cxist os u �Idei �;; desi;n�ation br !hu �I
pct�;,ti l efUi[ion I�cii�ierness �re�� Ihat axtends so rt w ud t> d,� no.th ,hoic ul Funwn� L�I�e -� ;
�����.,��:} tFirou��h [ u ar�a �.vould not aliuw �h�� �+�ila�n��_ ces:�r ,.t�,:m tu iomu��n ��hcn thc ci it�iia �
i
�, se� hy �'ne NPS .u�c zPPl�.c�- ,
The DLIS idzntifies Cne Monetary Se[dement �I,emu�ive a, the em�ironment�illy
pretarrcd ultemat�ve �s well as the ��ai Fnviro�m°nt�lj��_�i�o Pn�ii��,hlF al��
�(LEDP.A) in eccordanec wi[h Section 404(b)I.1) g��delines. £-PA conci�ns th3t ihi b1o�.etarv �
Sen!en.c r� �itsrnati� e is [he le;;,t envimn�ne�ntallv dniTi;��l �;�. ar�d we tro� �.I�,� Ss p�>on �hi. �- uSEP.c3
'�� aliemausc ,
n.,, . ,.�... , n. - � . , ��., �...�:i ,� .,..,�.�. � ._.. .�.. i.
Agency Consultation and Coordination - 5-20
North Shore Road Final Environmental Impact Statement

The Leurel Branch Picnic Are�� Alternativ� would result in impacts varying fmm minor
severe, and therefore we have semc environmental concems. However, if [his altema[i�c can
sitcd in e way to a�o;d and minimize stream impacts, this alterna:ive could be madc
�eptable. F'urther informntion should be procided about measures [o a��oid ar.d mitieate
vironmental imp�c[s if this alternative is pursued.
Sased on the data ir. tt:e DE[S, EPA has serious concems re�ardin, water quality impacts
of !he full-build and partial-build alterna[ives. 1'he most pronaunced adverse impac�s would be �c
wacer quality resultin� from cons�ruction, ��ven the probabiliry of encountenng acidic rock with
high metals_ 7'he document states tfiat major impacts would occur, alon� wi[h possible violations
o a e wa er qua �.y s an ar s. n a i ion, �mpacts resu Rng rom construcuon wou include
waste generation from acid rock, as well as impac[s to Floodplains,jurisdiccional wedands,
cultural resources, special aquatic ha6itats. streams and lakes, water quality, vesc�a[ion
communiries, teiresvial wildlite, migratory birds, invasive exo[ics, federal �pecies ofconcem
and vi;ual rzsources.
We no�e that although air quali!y monitors in [he Park indicate tha[ regula[e� air
pollutants are dcclinirg, the arca is iocated in a non-attainment area tor ozone and PM2.5. The
build ulternalivas u�ould �esult in air yu�lity icip�,�c[s from coostruction and impac[s �rom
vehic�ulttr traffic duiing d�e operaiti�n phase The full-build eltern�tive e��ould ree�!� in m�re
iinpacts compared io t(�c partial-build altemat±ves, and would require a leng�hy construction
penod, which would result in air quality impaets ovcr an axcended pc �iod of year.
Due io the putencially severe fmpacts to �ne environmcnt, we agree tiaith. the NPS that
selection of ei�her tne North Shore Road or the partial-build road to Bushnel I woufd require
supp(emental site specific NEPA analysis tu determine wherher any of these altematives'�vould
be environmentally acceptable Th� curren� DEIS does not address these alt�maCives in sufficient
detail to suppon cheir selec[ion.
PPrV da(ers the decision regardin� H�hich of the altematives is most consis[ent with the
funeti�n and mission of [he Pzrk and the Appalachinn Trail to the� National Park Service. We
cuncur dia� [his decision must protect the in�e�nty of the Park and the Appal�ehian Trail an�
their functions. Based on the stated concems regardino thc build:ltematives., the project rcceia�ed
an overali "EGI" rating, meaning ihat EPA's review identified e�vironmcntal impacts that
should he a::oided in order [o tully protec� the cnvironmer.t.
Thank you for [he upportunity io comment on tnis project Vde look forwa;d [o rev;e.vin;
tne FEIS, If ErFA may be bl fwther ass:s[.mce, please contact me or Ramonu [�IcCorney of my
staff at (404) 562-961),
Sincerclv,
� / ' � �' � /� �, �
��r
kicinz 1. 1��lueller. C�iet'
i�EPA Vro�ra�n Office
cc: Greg Thorpe, NCDOT Raleigh
Ken lolly, USACOE Wilmin�ton
°ete I3enjamir�, L�'SFWS Ralei�h
John Sullivan, Fi�WA Ralei�h
John Hennessy, NCDWQ
Agency Consultation and Coordination - 5-21
North Shore Road Final Environmental Impact Statement

EPA Reriew Comments on
Draft Environmental Impact Statement (DE(S)
North Shore Road, Great Smoky Mountains National Yark
CEQ No. 200�05a8
General Comments
We appreciate [he indusion of a diverse an�ay of alternatives in this DEIS. Wc note that ��ue to
the masnitud� of the Nqrthem Shore Corridor (baseline, full-build al[erna[ive), the DEIS
acknowled�es that it is Iikely that additional NEPA documentation would be requirod to address
site specif ic impac�ts if'that al'.ema?ive is sc lect�d.
The entire norihem shore area is within the exis[in� wildemess decigna[ion or the �otential
addinonal wilderness are� �hat extends southward to the north shore of che lake. A roadwav
throuoh th� a!�ea woul�i nu[ alluw the wilderne�s desisna(ion t0 remain �ahen tne cnteria set by
,he NPS are ;�pplied. The horthern Shore Cor-idor Altemadv� wocid increase Ihe annual visitors
[o an es:im�tled �k63,600 (Table 4-8) which ��ppears to be in conflict wiih maintainin� wildemess
st�tus. 1'his should be an important factor in decisions re�ardin� the p,-oposed action.
Yurpose and Nced
The doeun�ent notes [hat public lands w��houi vehicular acces; rotal 3 percen[ oF the land, in the
southcrr: Appalachian region (page 4-8). The'�.nference is that [here is not much area evithout
access [o a road.
The documen[ states [hat "...to discha�ge and satisfy any obligations on th,e par[ of the United
Srares... ° relativc to che 1943 MOU that the U.S. govcmment entered into :o replace SR 2&8,
floodad when E�ontana Lake was created. The MOU specifically called for a ne�� road [h:ou�h
Lhe GSMNP north of the lake. As time. passed and env;ronmental awareness increased, thc need
Eo* the pruic�� came to be qucstio�ed. Not only did it con(1 c t w�:h certain GSMVP c,sils and
�bjecti �.,s. but also [hc diYficulty of th,a prc,ject �,ncl [he discov„ry of acid-bearing ro�k caused
construc[fon oF the projcct to be haited.
The Di iS does �� rem�rl. on [ranspertau .n dePi�ieniies, execpt Cor �� itin ; a need ;o im?rc ��c �I ��s�pA-�E
uccess �o old cemeteries S�ate and fenual �and���avs within the a�ea one�3t^ at low daiiy+rafYi^ I
eveis even uring [he summer season. "Ihere �s nq doaumen[tition of how ma�y t�i�s would be '�
talen s� ce'fica!!y for visiei�� [h� cemete-i�,, 5u� ra[her [hc esun.�[ed A��erogc A�n�el Daiiy ,
Traf�ic (AADT, 6�-4751 fnr �he vano���s alt�rra[� ves considered in det�:i arc mps.ly ge•ic�atzd u}��!��
recreafonaJ travclers None of th�se uanc� cstim�tes comes any�,vhere c�,�_� [o justi€ying £he. i
projeet �or gene�ai mobilitv. I
The DEIS sta�es that reg,ardloss of the al,eina'ii�e selected, annual ferry su.ic� v:oi�.id'be
prov,de i f�>r ,ran;po�tation t�> e;�ch cemete� y if uirect rond aceess is not an the sel��teti
alterr�.ai.vc.
.4lternatives
The documen[ covers a full range of build altem�atives. The Laurel Branch Picnic Area �voufd be
located at thc immediate viciniry of rhe turinel, and wou;d involve QS milc of pavement end bc
located near ehc end of ,he preseot pavement. l'he roadway optiens would cuver the complete 30-
34 mile nortnern shore, with partial build options of acecssing tha Former Bushnell community
area in between.
The NPS explored a �ull ranoe of alte�nati�es in !hc DEIS. The extren,,ely Ir�w qqD"I"s (;44 to
475j do not iustify either the 'partial' or `ful(' build alternativc selection, "Che costs for the
Northe�m Shore Comdor aliernatives (Prir.iieive Park Road & Pnncipal Park R�ad) are be[wcen 6
and 10 times more expensiroe than the monetary se[!lement with potentially unaccepeable lon4-
term envisonmen[al impac�s (IS years of cons�ruction im,�acts alone). For U�e PaRia! buifd
al�ei��a[i��es to Bushnell (Primitive Park Road & Principal Park Road), the cos�s ure
approx�,metcly 1$ m 3 timcs more exuensive than the monetary seulemen�, wi[h comparative
adverse cnvironmertal impacts.
TF�e Laurei Sranch P'.cr,ic Area Altemative for �zvera! rcasone does no� hinder the pursuit of
Formal �vildemess de�si�7ation, a res�uroc increasingl�� in short supply and in dcmand along the
Ap�sl�ehians. Also, it add,ess�s a need for a visitor u�c nnd trailhe;�d to �vildcrness. Havina this
recreation�i �se (and ovemi�ht backpack �arkine) tacilityjust ea;t pf the �unnel �u,ments the
tunnel as a"`�atcway` ro the wildemess area. It would give Bryson Ci�y �n additional boost
economically because oP another visitation point to the GSMNP in nddinon [o the Deep Creek
Campground which is located north of town.
Aes[hetic lmp�cts
The impacts asscssment hea�ily emphasizzs [he po[encial impscts to the tradition;�l purposes
specifie� �n [he GSMNP management plan. The Apoalachinn Development High�vay System,
inv�lvine irnprovemenG to the US 74 corrldor_ is cone�d��retl �n tne cu�uld[ive im(��.cis
as�essment. I'his project is dcsign�d to promo;z ccvnomic development, �nd thc document
rrentions relocation of park headquaners and ca;ino operations by the Cherokees ac othe;
economic stimufi. Actuallr, tne GSMVP is itscll a huge economic stimulus GSMNP i; the most
visited national pu-k in thc U S.
Anothev concem in the DE15 is the impuct on [he enis[ittg trails, includin� [he A�palachi�n Truil
(:�?l. Ad��e:�e 3estheti; efFects :o the .4"C c�ould oceur becau�. �:�e �o�d�a�ay cuul�l t�� i� �ie�v �F
hikers una tt�.e �veste�m end of the Northe•r, Sf ore l'or��d�r, reGui�ing reloca:ion ol �on�c oF the
A"f' Rega�di Zg wi!derncss usage�, lhe llE1S s[ates [hat "7�hc baseline Northern Sho;e Coi:idor
wc;uid na��e maj�r, adverse, and long-;erm impac[s ro backcountry camping fo; aciive visitors,'�
(page 1-SJ). A simil�rl�� ;evere summan- s�atemen! appe,�rs ori p�gc 467 re�ardin� impaats to
!he AT: "Tk�s alt�r���zfive wcul�l e'im.btitte se�-en c�Ir tp,��i;cs "
[i!.:c= t {��� �1)>u;nr..�iz.;i�e ���ticroi(��M1INi'trai� resuitin�ir;n�ili-: ',terna!i�es;,
T re f.ai ir � Pranc f��� �eic A�ra .ti�o��.ild r�wl: in i.b i�s �, ._ �an + e.,fhcr bu I�� .i:!enr ��� _c wo�.�ld
Agency Consultation and Coordination - 5-22
North Shore Road Final Environmental Impact Statement

result in 9- 32.4 miles of trail kosses, mosdy hecause the roadway would oc: upy much of the
Lakeshore Trail.
The projected IS.year consvuction penod for ehe Northern Shore Corridor preserts a substunti�l
adverse iioise and visual impact to any recreational pursuit within the GSMNP, This should be
eonsidered a chronic impact because of thc duration. Tfie 5-year construc[ion peiiod for the
artial- uild A temative would have ;imilar impacts but for a lesse� period.
The Bryson City side of the park would be enhanced by the proposed addition of cu!tural and
cducational information about the history of [he set,lements lost due to Fon[ana Lake's creation.
Finally, the NPS has $16 million already allocated for addressing this 1943 commitmer,t. The
La�rel Branch Picnic Area altemative would cosi $f3 million !u build This al[emative
minimally addresses thc conccrns of the descender.ts of Norh Shore area inhahi[ants, but it
appears that much of what che NPS wishes [o uddress has more to do with the procection oY
traditional park uscs and vi5itor rec;eation facilities there.
;1ir pualitv
The D�IS states [ha� .�ir quuliry monitors in the E'ark indicate tha[ re�uiatcd air pollu?ants are
decfinine, b�t that the area is locate.d in a noman�zinment area for ozone. The build alternatives
would result ia air ualit im.1c[s from consu�ucdon and im acts due to vehicular traffsc durin�
the opertition phase. Howevzr, the BEIS �Iso notes tha� even relativaly small increases in
emissions and change, in air qu�iity could be ;mportant influences in meeting C.4A
requirements If one o� the build alternatives i; selected, tne Fin,u EIS should include further USEaA-io
information regarding the monitaring of impatts and result on air quality compiiance s�ar�s
associated with that �I[ernative.
The FEIS shoold indude mobife input and output filcs and a summary oF �he a,sumpuons and
methodoloe used. A so, plea�e provide a s��mmary of the transportation conforniity
requirements For this area and how thcy ap��y Transport�tion conformity requirements can be
found in 40 CPR Part 93.
Interagencv Consultation is a patt of tr�n�portation conformity. A statement is needed in the
FEIS that discusses that a con(ormity determination wiil be made with the selected aiternative
include.d and wi11 be achi; aed throuoh the In[era�ency Consultatien process [[ is ocly �f[er the
selected a�temative is included in ihe con�ormity determina�ion that �he Record of Decic�on
(RUD) can be signe�.'Ihe FEIS should include a s'taternent �hat the Great Smoky Mouo[ains
Nationail Pa�k ard F'eaert>>, StFte ur.d local partners wi1( be coovenin� to discuss and review [he
regional conformity determination prior [o s4�nature of the ROD.
�1'ater Oualitv
W'aterquality (Stream) irnoacts are presentcd in "Pable 4-13. Piease clarify whether che linear fcet
of impacts are a ithin the nght of way rather thar the habitat lost within culveils. Habi[at losses
cou poten[ia y be less, given the statements regardin� bndaing expccted to be part of the build
altematives. Nevertheless, these are sizable imp.�ets (up to 25,374 Ft.) unless the Laurel Branch
Picnic Area or no-build altema[ivc is selected.
The mus[ nronounced adverse impacts would be ro water quality resulting fmm construc�iun,
given the probability of encountering acidic rock with hi�h metals. Thz documen[ states th2�
major impacts would occur, a;ong with violat.ons of state water quality scaadards.
The s]EIS states that mitigation and/or avoidance of acid runoff from rock Formations will be
necessaiy to ���oid possible water quality violations (page 4-L72). Ct eirhar the partial build or lul:�
Northem Shore Road al�emative is sclectzd, the }�inal EIS should include further information
regardin� ihc impacts and mitiga[ioo 3ssociated with that alterna[ive.
Habitat Loss
The panial and tull-build alternatives would result in the direct loss of hafiit&t .icreage. The DEIS
mentions pote�ntial mitigation, but does not go into detail or commit tc miti�ahon If o��e of the
build altematives is selected, the Final fiIS should give Further information re�arding miti�ation
and/or avoidance of terres[rial habitat loss.
Threalened and Endanaered Species
EP.4 defers [o FWS regardina threatened and endangered species issues. However, eve note or
page �-233 that `informal' consulta[ion is in proces,, but it is unclear how the `effects
dete�minations' were de[ermined for the Bald Ea�le and Indiana Bat. Because of tha large extent
ot diswrbance [o habitat, Che Northem Shore Corndor could repr�sent a ulay Affect — Like�iv to
Adversely AFfect detemiination whicl,, would require fc,rmal consuita[ion for either spzeies. The
EIS should include additional survey information that leads into a disc���ssion of ;he effects
derenninations.
Cultural Resources
Some o� the build alte.rnati �es would h���e impacts pn archcological ;ites ar�'�r histuii�
— least impacts in this catcgory. EPA recommends that the vPS coordina�e with the State Histori;
�VeNands Preservation Ofiice regarding cui�ural resources and histonc preservation if one ol the build
� altematives is selected. �
The bnld Itern u�cs woull irnp�ct bet��,en 0 1�- 2 1� acres of i��risdic�ional wadand; Ta��le —
�� ti-1?ai Ihi, r�a} al u tesul in hvdrolo i� i�npacU to �tream, nd aci�a ic hahit its The DEIS
eiscus e, rr n�et oi ttchniqi f�.�etl�id eom� rsa,io� t it do�s n� o itlinc t�f i F.x �
'��EPA-��1 �
� r.�iti�, ir� �� th� h il� i' � n�i� t If i< <:�t �'�� hu.lu altu-r 4r ��:' ic Ic�.tc�i. '� Fi �a�, cIS ��
np�.�lu n,I id�e n n ni llio❑ �, �.run��, t ic :t��np n�1.��ry ir ti< �,�<. j�i�i°
------------------------------ ---------�
Agency Consultation and Coordination - 5-23
North Shore Road Final Environmental Impact Statement

[muacts and Summarv Condusions
From Table 2-6: Impacts to Land Use, Visitor Use, Cultural Resources, Waste Generatio� (Acid
Rock), Floodplains, Junsclietionnl Wedatnds. Special Ayuatic Habitats, Streams and Lakes,
VY'ater �uality, Vegetation Communities, TeiTCSUial Wildiife, Migratory Birds, invasive Exotic,.
Federal Species of Concem and Visual Resources are charactcrized as being major, ad��crse
and long-term for the Northern Sh.ore Con�idor.
[mpacts [o Land Use, Visicor Use, Cultural Rzsources. VJaste Generation (Acid Rock),
Floodplains, Junsdictional Wedands, Special Aquatic Habitats, Streams and Lakes, W'ater
Quality, Vegetation Communities, Terres�rial Wildlife, Mi�ratory Birds, Inva,9v� Exo�ics,
Federal Species of Concem and Vlsual Resources are charactenzed as being moderate to
major, adverse and long-term Cor the Partia! B�iild to Bushnell Alterna[ives.
OveralL there is lit�le difference in the total quannfiable impacts for many resources behveen the
Primiti.e Park Road and P;incipul Park Road Options. The magnitude and se�.eiity may oc
somewhat iess tut the Primitive versus Principal op[ions for 2 number of resourc:s, nonztheless
chey arc no[ `environmentally comparab!e' to othcr al[ematives (monetary settlement & Laurel
Branchl.
Lnurel E3ranch Picnic Area Al�erri2:ivc impacts are oenerally negli�fble to minnr, wiih the
excepuon of [he waste �enera[ion (acid :ock). floodplains streams and I�ikes wa'er qual��y ard
vegetation communi[ies, which could result in rnoderate to severe impac�s. "fhe FE1S needs to
�lanfy the analysis regarding ge�lo�y-reiated impacts (was�e gei�eratior� — acid rock) in terms of
seventy. Noiihern Shore has betweenl.7 to 2.9 milliun cubic yards, Partial Build has between
693,900 ro 948,100 cubic }�ards and the Laurcl Brach Picnic Area alternative has 24,700 cubic
yards. Yet all three are charactenzed as being major, adverse and long•term. [n terms of scale,
thzy represcn: a magni[ude of difference.
"Che _ame issue is truc for Stream and Lake impacts between the Northem Shore and Panial
Build :Vternxtives: 131 vcrsus 34 stream crossings. 1_.aure! 13ranch has 9 srream aossings hut
the imp�ct5 are characterized as mudcrate, In tcrms of magniiucie, thc Partial Build alternative is
closer tu the impact sevcrity of Laurel Branch than it is to �he Northern Shore. "fhere zre simiiar
`discrepan�ies' in charac[�rira[ion of other impa: ts,
Regarding the thece impac:s to the L.{urel Branch Picnic Area, it appears tha[ [he ro�d is vc:y
close to tha creek and the onc-a�ay loop portion crosses [he creek more �han once. 3f tf;is iocution
was shi`ce:S s!i�h:ly away Irom the ereck, potentiai direct impacts to ;ur(acc water wi�uld �e
minimized.
�rage v-p� sla[es [ha[ °a parti¢1-build ar �i��iCc( r�henuztive wouCd raquire extensive eaistructi�n;
� th2 Effects (iriapacts?/ �f w�hic{i wo<<lcl bc luny-terni arid permanent- Th'e alteniatives �rould
I requirr. __..thnt h�ou!d bc in�etrievahle i� rmpric�ted by tlie altemati�:es� _.... " These sta[emcn's
�' nre in direc[ eonl1ict with thc cnndusicr,..:atamcr„s on Pages 3>9 and 26� reetirdin� the Parti��l.-
� buitd ar_d Vorth Shoro Corrid�r altemar:ve>.
Aftcr all c�f th� decenbed "major° effects m tne ciiscussions about the conrlic[s of the build
alterna�ive's (other [han che Laurei Brnnch P�rnic Area) the conclusion staternent on pagc 4-2�9
�states Ihal "...none oftlte alternatives woufd hmvri the integriry or ��nlues of'GSMNP orAT
�resoiu�ces ... " This ;tatement conf1icts with inYOrmation civen elsewhere in the document,
The magnitudc and duration of GSN]NY impac[s from the Northern Shore Corridor alternative
a�e exten,ive. While the Partial-Build impacts are ;enerally characterizcd as being lhe s�me as
Yhe North��m Shore, there is aquantifiahle drop in both [hc magnitude and seventy. The Laurel
Bra,.ch alcernaiive appears to provide neel�gi'ole adverse impact to visitor use ar.d zxpencnce
(Paec _-2?1 (or $13,700,000 in construction costs, $454,000 in construction O&M a^d $313.000
in annual 0&M, and represents a park modi;icu[ion consistent �vith projec[ and GSMNP goals
and objectives.
hlieratorv Birds and Invasive Suecies
The DEIS hud wcli-wnt[en drscussions on Migratury Bird; s7d €nva�ive Species. Both Sectio�s
�ere very comprehensive and provided � Iull e.aaminauon of the issues.
Agency Consultation and Coordination - 5-24
North Shore Road Final Environmental Impact Statement
USEPA-20

SUMh'[ARY OF RATIV'G DEFINITIONti AND FOLLO��V UP ACT[ON
Environmentallmpaet of theAction
LO-Lack of Obieei�on<
Tht EPA re��iew� has nni ideotifi:.d any potential envirunmental impacts requirin� substanti��e changes to the
proposal. l'he review may ha��e disclosed opportunities for application of miti�ation measures chn[ could be
eccomplished with no morc than minor changes to the propos�l.
EGEnvironmental Cuncerns
The EPA re��iew ha; identitied environmencal impac�s ihai should be a�oided in ordzr �o fully proeect ehe
environment. Corre:tfve measures may require changes tn �he preferred ul�ernative or upFlicaiion o(mitigaCon
meusures tha� can redirce the envlronmrntal impac�s. EPA would like [o work with the leud ngency to reduce thase
i m�nac[5.
EO-EnvGonmentul Ob��(:cuun5
The GPA review ha, identiPied significnn[ environmental impacts that must be �voided in osder to provide adequa;e
pro[eclion (or the environment. Currecti�e measures may require substantial changes !o ihe prefcrrcd ¢Iteroa[ive or
ccnsi�eraliun oi snme n�her projen al[crna[ive (includm�, the no action altema�ivz or a new aliernaiive). EPA
Intends �o wo;�k «�ith [hc lead agency to reduce these impac�.s.
BU-Envirnnmeni�llv �insatisfnct�
The EPA rer.ew has identlfied adve�rse enrironmenml imp�as �ha� �;: of s�fficlen�, mn�nlmde thim thoy are
�.:nsmislacorv trom du ;inndpoin: �f public haalth or wcifare t�r nn�ironmenml quality. EPA in�ends ro work with
�he lcad agcncy;o redo�:e ihase impocis, I( the potentlal unsntisfuaory imp2:ts are not corrected nt the f nol F.IS sa[e,
this proposal will be recummendtd for referral to the CEQ.
Adcquac} oY the Impact Statemen�
Cateeory I-AdeauatP
The 6PA belleves the draft EiS adequaccly sets forth the emironmental impoct(s) of the psefcrred alterou��e end
ihose of the altcrnouves « asonab(y avaflable ro the proj»ct or action. Vo further analysis ur data colicaing is
neccssary. bu� the reviewer mzy suggest the addition of clarlfying language er informa�ion.
Cata¢orv 2-Imut`�ciert tn'ormar�n
The draft 6IS does noI �ontain sufficlent informaG�n tor the GPA ro full�� as,ess the envtronmental impacts [hat
snould bu �voided in order to faliy prniea the environmrm, nr �he EPA reviewer h�s iden'iFed ;.c•.c re�sor,e6;y
a�+ailable alrematives that are �+-ithin ilie spectr�m of nl�emaiivcs analyzed in the dr�ft E[S, which could reduae the
environmen[el impacCti of the ection. The identified additional informution, datt�, nn�lyses, qr discus'sion shou!d be
included in the final LIc.
Caic�o-v �.I .,d� a n'c
LPA docs nu� believa �hu< <he drafl LIS udequotely asses>es potcntially s]gni5cant enviromnental impac�s bf the
nc�ion, ur i6a EPA revlewer has identifed new, roasonably avallnble aiternnrves th;it xre outside of:he spectrum oF
alternativeti analyzed in the droft P15, which chould be nnniyzed in order io reduce �he pomnii�lly sianiticun�
environmentai impacts, FpA believes that the identified addi[ional infurmation, da[a 2nalyses, pr discussions are of
svth a ma�nimdc tha� they ,hould have full pu6lfc roview ai a draft stage. 6PA does not believe �hat [he draft HIS is
adcquate for thc purposes ot'Ihc NF,PA and/or Sution 309 review, and thu5 should be forma!ly revised and rcade
available for publie comment in a supplementai or revised draft EIS. On the basis r�f the potential sionificant impact;
involvad, this proposal cuuld be a candidate for reterral to the CEQ.
'F�o�„ een H+.,���,! i e'ao r�r��y,«a e-«�a����s ro� m< er,��eu� or �ne r�n�; �i �oao�s imP��d�, me e�,.�ro.,m��i
SMy�� e N
f
�,v�E_ _,:,.
'a -
. x, '
Mc',�,a
Unitcd States Depaztment of the lnterior
F1SH AND WTI,T�(,U�L SERVICE
Ashevillc I'icld Uflicc
I fi0 7.i1 i icoa S vcc!
Ashcvillc, Nnrth Cerulin� 28301
April 6, 2006
h1r. Dale Ditmaraon, Superintendent
Great Smoky Moun[ains Nationa'. Park
107 Pazk Hcadquartcrs Road
Gatlinburg, Tcnncsscc 37738
DcarMr, Ditmanson:
Subjcet: DraR Environmenfal TmPact Statemenc for L'�e �orth Shorc Road Projcet, Crrcat Smoky
ylountair.s'_Vational ?ark, Gr.taam and Swain Counties, North Carolina
tiVe rr.c�ivc:d a copy o.` the subject Draft Fnvironmental Impzet Statement (DEIS) on Jan:i:uy 5,
2005. Thc following comments are providcd in accordanec •,vith thc provisioas of the Na€ional
Lnvironmeniai Policy Act (42 U.S.C. 4321 et sep.) (NL'PA); the Fish and Wiidli Fe Coordmation
Aol, a� amended (16 U.S.C. GG1-GGi e); Thc Migratory Bird Treaty Ac� {16 U.S.C- �f13, et seq.)
(\rTBTA); an& section 7 of thu Endan�ered Species Act of 1973, as amendad (IG US.C.
1531-1543) (Act).
r.ccorcing to th> DETS, thc �Tational Park Scrvicc (DIPS) is prcparino an Enviror.mental T;npact
Statemc�rt (E1S) to analy�c aHematires for resolviug issues ieiated to the Irorth Shorc Road. 'i"ic
projcci sNdy arca is in wetieem North Carolina and incIudcs a poYior, of thc Gmat Smoky
A7ountains Kational paxk (GSMNP) in Swain County and a porticn of the Appalachian Nationat
Scenic Trail (AT) in Sw:tin and Grahar Counties. Both the GSMNY and the AT a:e individu, l
units of'Uie i:ational park system. Alt altematives requiriag conshuetion :ue teczicd within thc
GSMNP, and some alternatives cross the AT. I6c purposc of this action is !o di�charge :u�d
satisCy an, obligahons on the part of thc Unitcd Statcs ihat pruwnlly exist s the result of the
1943 Agrecmcr.t.� The nacxi for ihe proyxt is to de,emune wheth� it is fcasible to compiete tha
road and ta evaluate othcr altcmativts that would sali�fy the obligation.
' h� Iul 19a.1, ,tee'� ennessee Vullc Authori
Y y ry(TVA)�, ihe U.S. DeD�»t atcho in[sriot (ll01); [he �tare uf Vu.-ih
G.rolina; and Svrai2Counry, Nut�h Curolina, entered into a MernorandumefAgrxment {1943 Agroemtnt) ihz�
d��lt vdvi the creatlon of die 1'ooianx Dxm ;md Resorvni� �ne; ehc resaltant floodin� of lanC aad roads withu� S�.vaie
Couo;y. As part of the 194J Agree¢ent, 4A,I70 ne.:cs af land wac tr�a�.'cr, ed in Uie DOJ and n�ade parz of the
GSD:NY, 'lhe 1913 Aaccmcnt a'so contai:.ed o provision by wtuch uc State of North Carol ina �uie to �pnstrv�at a
road :��o�n 13ryson Ciry to tho C;5�1h''� bouAadary, and [re DOI wlls �u cocstuct a roud through ;hc GSMNP, aloag 9ie
aorth shorc of ri�� ncwly forn-,ed Fon�na Resavo'v, to r�pl�cc thc fleudcd \C 2F8. Ths Swte of No:Bi Glroliha
compkettd ii� ooligafion Sn 1g ;9,
Agency Consultation and Coordination - 5-25
North Shore Road Final Environmental Impact Statement

Pmoosed Altcn:uivu,
An extensive list of about 100 initial opqons to be consider,d was compiled after a review of
previously documented concepts and recommcndcd allemat;vcs. Aitemadves wcrc cv:iluatul
b2scd on a list of vatiables that includes environmental, social, ccoromic, ancl en�ineering
constrair,ts, as weli as documented data on �isting conditions. Nt�Knatives that were lil:elyto
l:avc the grcatcst impact or �hat appeazed to offcr littic bcnefit to ;he study area were eliminated
from iuriher s[udy. This initial rcvicw resulted in the decicion to suggcst six prcliminary stnd,v
alternutives for morc deti3ilcd evnluation in the llETS. Thcse six altcmatives were presented ta
t;�e ou6lic u;d to rewurce ugencies. Public and agency commer,ts and a revinw of G5MNP
visimr needs weze considercd in de[ermining che facilitics, amenitics, and altematves to be
stud'aed in thc DEIS.
Dctailul Rtudv Altcnfativcs
No-Action ,4ltemuRve: NEPA requires the No-Action.Altemative as a basis for eomparing the
}wtential benefits and impacts of ot6er xltcrr.advcs. This altcrnative would avo�d study arca
disturbance and adverse unpacts to culhua] and naturul resou,ces.
'_vivactary Settlemait A,lternntivc: The Swtin County Board of Commissioocrs passcd a
resolution o�i february ll, 20G3, s(xting that :he counry would acccpt a monet:vy settlemen; of
552 million [o ;ctilc the 194; A3reement. It was sc��;cstcd for Cctai led ,tudy in tk e fJEIS
i>ecause it would nvoid clisturbance and other advecse impaets to tt�e existing natur�l
enviro;tmcnt, cicltural resources, and xecrcation:il rr,sources (including che GSbtNP, the A'1', and
tbc Nantaha]a Nationul �pSest).
Laurel Branch Pienic Area (part;al-build): 1'he Laurcl Branch Picnic Area would conszst of a
day-us� urea on the north sidc of cxisting Lake View Road, just east of the cxistiog tunncl
oarking uea. A new two�way paved rntrulce/exit road would provide aeces,e to the clay-use areu.
Outdoor facilities would include a multi-usc picnic shelier; picni;. tables, several loop trails,
dnnking toimtains, and restroemc.
Partial-Build A?:ten�ativc to Bust,nell: Ths alternative would inclvdc up to ci�t r,ulcs efr.ew
"oadway from thc cxisting tunn�l west to the vicinity of the formcr Bushnell seltlement This
ahcmadvc would include a br.dge crossing Forncy Creek north of the impounded wa±ers (also
:eferred to as tk:c bas�line). This aftemativc weuld also nrovide a boat-launching ramp and a
resiricted boat dock. The boat dock would uiso 6e used for scenic 6oat touts and woutd be
av�ilablc to the public for temporary dockin; to acccss cona:ssions, *estrooms, and ether
facilities. Located ncaz thc tcrminus of die new roadWay wou:d be a mulu-use pic:vc ;hcltcr amd
picnlc tables, a baekcour,try permit stati,on, � iafermation kiosk, resrroorns, u p;uk;ng area, aad
interprcUve, sclf-guided loop traiis.
The P;utial-Build Altcmative to $uslmell would al,o ir,dude pivvisions for cnhanceme,rts at
Hucl Crcck for lhe fonner community of Proctor. A new, acecssiSle trail from the hoat dock to
Proc(or ;�d new wayside exhibits would convcy thc his:ory of the area. Ttic Bushnctl Arra
weuld p;o�idc a uniqua experiencc in the GSMNP becausc it would hnvc the anly boating access
directly in GSMT�'P bounciarics. If this altema[ive were sc;cctcd, a Commercial Services P(an
weuld be prepared to dctcrminc the type of concessions that would be necessary and appropriatc,
financially ��iabl�, and of scrvice co the public. In conjunetio� with che design az�d cons'�ruction
of the madway leading to the P�rtial-$uild Alternative ;o Busimell's destination, planning and
puhlic involvemenl �ctivitios would bc conducced to detail tbc final complement of facitiCes ar�d
dcsign t6e's locatiun on the lancl�cape.
SouthernOptia�at!'o�r�EyGeekEmbaymer+t: AmajorbridgecrossingoftlleFomcyCrcck
Embayment was studiecl as an oprion to t:�c baseline comdor. The Southem Option at the Fomey
Creek Embnym��nt would continuc wcst past the existing mmcl and tum to the south to cross thc
f omcy Creek Embaymeni. This route is about 1.3 milcs to 1,5 miles shorter tl�.au [he bascline.
Northern Shore Corridor; Tke Nortliern Shorc Cemdor is the oaly ful]-build altema:ive
cvaluated in the DE1S. lt would cennect Lake Vicw Road :o VC 28. Iye alternative (or bssc)inc
corridor) would include a small bridge c!-ossing ot Fomey Cr.ek north of the impour,ded waters
ane would svoid major Bndge crossings of thc H:+zei ard Eagle Cceek �,mbaymcnu. The
corridor wottld tum northjust west of Calheun and I�1i(I branches to follow Lakesl,ore Trail to
thc vicinity of the formcr Procior settlemcnt. Once nucth of thc Nace( C�eek Era6ayment, thc
cor*idor would turn to the wcst and con[uiue th:-ongh a portic�n ofFlint Crap. We�t of Eaglc
Creek, tho corridor wou?d !um to the sou;h znd cont��uc west to NC 28 toward Dcals Gap, I'h�
estunatcd lcngth of the basefin� corridor is 30.6 miles or 343 miles, depending or thc road fype.
Dcp. n�iins on options chescn a[ Fomey, Fi:vel, and Sn�lc Crecfw and the westran terminus, thc
iength r�ciges from about 24.9 to 34,3 miles.
The i�o?-hern Shore Corridor weul� xnclude provisions for the devclopment of an auto tour gtude
describing tbc historic and natural poiats of interesl a(oag tl�e routc fo: tt:c study area, tzlii.ng
local history, �.�d illustrating thc localinn of trails and backco�uet.ry c�mpsites. Wayside :xlubit
pancl. would be provided a]ong thc new road aad at app:�priate pull-0T �ue�s and o� erlooks.
Intetp:ctation woutd be providcd at Proctor. Ir addition, resvooms would be built at appropr:atc
locations.
Mejor bndbc crpssings of thc Fomcy, Hazel, and �agle Crzck Embaymer.ts were studied as
op:ions io thc bascline comdor. In addition ta ;hese options, another opuon Co* t};c wcstcm
tcr!ninas wouid involvc thc corndor tying into ront�.na Dam Road ,^.nJ crossu:g Pontana D. rr
x:ore ir.tcrscctir,g with NC 28. (Lengths vrry de;�ending on the road type.)
SoutHern Option at Corrzcy Creek Eml�ay�ner.t; This op[ton vrou:cl condnue west p.ast thc
zxistiny tunnel and him to the south to cross the Fomey Cr:ek Embayne�t. Th'ss routc is abcut
!.3 mi les or (.S miles shorter in lengtb then thc baseline
Agency Consultation and Coordination - 5-26
North Shore Road Final Environmental Impact Statement

Southern Option at 11¢: e! ursd Eagle Creek BrnGavmenW: This option wou1J continue west pa t
Calhoun and Mill Branches, btidgu�g thc Hnzcl :utd Eagle Creek Embayments. This route is
about 23 niiles or 3,1 milcs shoxicr in ]��ngth than d�e base(ine. T'bis opcion would tum ro tbe
nortl� neaz Calhoun and Mill Branches.
Southern Option Crossing Fontana Dam: �'}iis option would tic tl�e Norihem Shore Cor.idor
znto the �isting GSMNP roadway sagmcnt that crosses FonGu�a Aam. This connxtien would
havc lcss roadway conshvction (about 1.5 milae or 1.6 miles sUortcr in lcngffi than the baseline
corridor).
All detailed study altcmntives includc continued cemctcry acccss into GSb1NP. Ar.nual ferry
service, as it is currently provided by thc NPS, w�ould continue under altemaHves that would nat
inelude provisions for a new road, would r.ot interseec az� admi�istrative road, or would reach
only a portion of the cameteries.
Road Types: Two road types-•a Principal Park Roa3 and a PximiYivc Pazk Road--wcre
recornmendrd for detailui s�udy zu d�e DE1S for the partial-build :uid build al[emadves.
PriiicipaJ ParkRoad: Thc proposed roadway typical scction for �hc Principal P:uk Road has a
tu�o•way asphait surface wi9i nvo 10-fout travcl lar.cs and 3-foot-w;dc gra�s s'.muldcrs. lt li+s a
posted speed Timit of 30 miles per hour (mph).
!'rimilive Pwk RouJ: The proposed roWlway rypical scction for lhc Primitive Park lioad 1�as a
two-way 3�ravel surface wlth two 9-foot [ravel lanes and 2-foot-widc �r:iss shouldcrs. It hu a
posted speed lunit of 15 mpn.
Environmental Conseaucnecs
Direct, indirect, and cumulativc impacts w�e analyzed, Direct eff�es arc causcd by the aclion
and occur at the same ti.me and place. Thc Councii on Er.vironmental Quality (CEQ) deLnes
induect impacu as those'Yhat are caused by the action a„d are lacer in time �r farther removecl in
dis(anc;,, but ue sti11 sasonably foreseeable" {40 CFR 1508.8). "fhe CLQ tegulations So
impiement NEPA rcquire the �.esessment of eumulativc ivpacts in thc decision-making process.
Cumulativc itnpacu are defined as "impacts on thc cnvironnt�nt which result from the
ineremental impact of the action when addal to other pa.at, preseut, a2d reasonably foresecabic
fciure actions rcgazdlcss of what agenry (fedcral or nonfcdcral) or person undertakes such. other
actions" (40 CFR 1508.7).
The DbZS anal}zos thc irnpacts without detailed ;nitigation, bascd oo informacioa krow�n to datc.
Detailed mili�ation p'.ars would he developed bafore impiementation of an alt�native. The
deve',o➢ment of a M��rnorandum, of Cindcrstanding bctwecn thc ;�TPS and the Federal Highway
Admini,tration i, cutrentiy ;uider way to documcnt the commitment of the ;wo age�cios to
jointly produce detailed cuitigation plans if � parti�l-build or build a(Yemative is implcmcxted.
Final desz�-n and dctailed mitig�tion nuy reveat sitospccille impacts that are not curcentfy
knowr. Additionat NEPA analysis would be requiccd if impaca were £ound to bc grcater than
idrntiflcd in the EtS for any of thc p:utial-build or build altcmativcs.
j�.�nd Usc T�acts
The Northtm Shorc Corridor (any option and cithcr road lype) and tho partial-Build Altcmati. c
to Buslznell (any oplion and either road type) would change Rand uso within thc GSMNP,
resulting in major and moderate unpxts, respectively. Impacts for boffi alteruatives wouid be
advcrse and long-tean. Thcsc altcmatives do not comply with thc current GSMNP General
Managcmcnt Plan. With thc Nartiicrn 5horc Corridor (principal Park Road), about 823 acres
would be reclassifecd frorn "Natural Environment-� Iypc I" to "Transportation" s¢bzone, With
tltc Northcm Shore Corridor (Primilivc Park Road), about 90G acres would bc rccla�iFicd. The
Southern Option at the Pomcy Creek Embayment would reciucc the arca to bo reclsusified by
about 34 acres with the Prir.cipal Park Road :md by about 4Q acres with the Primiti ve Park Rozd.
The Southem Opuon a2 the Hazel end Eae1e Crcek Embayments would reduca tbe area to bc
rec3us;fied by about 83 aezes w;th the Privcipal Park Road and by abouc GO acres with the
Primi.tive Park Road. Wilh the Southem Option Crossing Fontana Dam, the size of the arca ce bc
raclassificd from `Natural Environmcnt --'I�pe I' �o "Transportatlon" subzone would be reduced
by about 41 acres with [hc Principal Park Road and by about 42 acres w ith the Primitive Puk
Road.
�t'iti thc P:u:ixl-Build Altemativc te Bushnu!1, the *oad wmdor would also he rcctassifiai irom
"Nalural Em;ronr.ient" to "Transportation" subzoae. For die baselinePartial-Huild Altema�ive
lo Bushne',l, tht Principal Park Road would includc about 155 acres, and Lhe Pnmitivc Park 12cad
conidor would includc utwut 205 acres. Thc souihem option woutd reduce thc size of thc
rcclassilial "Trunsportatior." subzonc by about 34 aaes using tUe Prineip:tl Psrk Road and hy
about 40 acres using che Pnmitive Park Road. With fnc Parial-Build Alternative to B-sshne!1
(eithcr ro2d typc or option), about 3 acres would be reclassified from `ivatural Lnvironmcnt --
Type ?" fo "Gencral Pazk Pcvclopmcal."
In add�tiea, the Northcm Sho:c Comdor wou!d reduce the a:ca thst wou?d poter:ia!Iy be
wnsidered for future wildemess designation, with the Primitive Park Road h�ving the greatesc
impact. Thc Principal P:uk Road wauld climinate about 5,215 acra from futwc wi',dcrncss
consideration, xnd che Primmtive Park Road would eliminate about 5,314 acres from future
consideration. Tht Soutncm Option at the tomey Crcek Cmbayment would reduce che impact
by about 258 acres with che Pnncipal Park Road and by about A51 �cres with the Primitive Park
Ruad. Thc Southern Optzon ut thc Hazcl and Eagle Creek Emba}lnents would reducc nc� impsct
by about 630 �c*os wiLh tiie Principal Park Road andby about G39 acres with thc Pnm;tive Park
Rond. With the Southcm Opticn Crossing T'ontana Dam, thc impact would be reduced by abou:
551 acres with the Principai Park Road and by about 550 acres w; th the Primitive Park Road.
VJith tha basetine par�ial-Build Altemative to Bushnell, thc arca thnt would potentially be
considered for futurc wildemess designation would bc reduced by about 1,G58 ac*es with nc�
Princip�tl Park Road and by zbout 1,839 acres with !he Pcimative Park Road. If t:�c Southcm
Agency Consultation and Coordination - 5-27
North Shore Road Final Environmental Impact Statement

Option at thc Fomcy C��k Embayment wexe selected, this impact would bc rcduced by abouf
25S ac;es wi,h the Principal Park Road aod by about 451 acres W�ith the Primitive?ark Road.
Thc rcciuction of acrwge pete?ttiaAly considered for fuhue wildcrncss dcsignation resuttir.g &om
the Northem Shore Corridor and the P:utizl-Build AliemaGve to Bushnell does no*. affect the
potential for thc fUnireHildemess designation oftho remaining acreage widun the GSIvL*!P. Thc
por;ion of thc projec[ study urea withm the GSb1NP, along with a lugct poaion of the GSMNP
con�igiious to the smdy area, is ooc of thc largest land trlcts in the eastem United States U�at is
not impactcd by or casily accessible from modern roads.
)and usc ouuidc tY,c GSbIIvP is likely ;o be affected by the consuuction of cithcr thc Northcrn
Shon: Co:ridor or the PaRial-BuiId Altemativc to Bushncll, Thc Nor[hcm Shorc Comdor would
have a m;nor (Primitive Pazk Road) to moderate (Principal Park Road) indirect iFnpacc on land
use outside the GSNNP, especially in doumtovm Bryson City. At tiie wostom ternunus, dic
Northern Shore Corndor would likely creatc dcvclopmcr.t potcntial on privatcly owncd
prouert;es on die soulli side of NC 28 ou[sidc thc GSMNP. The Partial-Build A Iternative to
Bushnetl would havc a minor, indelermina,c impact on land uso change and developmcn2
paucros outside the GShiNP, primarily along Contana Road and in downtowr. B.ryson Ciry.
Dcvclopmcr.t petcntia! is al;o likely as a cumu(aiive impact if eitl�ex the Norhern Shore Corridor
(�7thc�r road �,ype or any option) or the Partial-Build Alter:nativc to Bushncll (cither road t}pc or
any optior.) is conscn:cted. ;mpacts resulting from thc Notthcm Shorc Corridor, whcr addch to
l'ne devciopment expected in Brysor, City, Cherokcc, :uid surroundir.g countics, wotild resu;t in
greater cumulativc impacts ;o surro�7ding cornmunitias lhan wou}d other altem�tives. Houever,
dcvclopmcnt potenfial in the regio�x is lunited by thc ?argc percenWge of land under public
ownership.
FloodPl�ins und F!oodwlvs
In campliance with Executive Order 1:988 a��d D'ucetor's Ordcr t?77-2,z a"Statcment of
Fin<lin�s' fpr fl000pialns would be dovclopcd and rel�a�etl Io: publiC Ycvicw if a padial-buiid or
build aatemative were selceted.
Tbe Northem Shore Cor,idor (all optio:is azid eidier road type) ar,d the Parcial-Build Alternativc
ro Bttshnall (all options :tnc cithcr road typc) would encroacn on ,he 100-year fleodpl�in vt major
stream crossings. The encroaclur:enu consist of fiif in thc cxisting floodpiains duc to roadway
embankmcnts. All impacts notcd would be alvezse and lor.g-tena. I'he ir,tensity of the ;mpac:s
H'ouid vary wiNi t�e ar�oun: o: fili Wnd the lcrgth of bridgc cnc:oachmcnt wi�Sin thc f.ocdplain.
2 Executive Order 119R8, F3o0dplact Munagemtn(, d'aceu Ccd�-sl �gcxics ". .. to avuid to thc czmnt �zsibic G'�c
lor� and shun-le� adv�r.;c impacta accociated w;th L7e occupanty anG rooAificarion of floodFla!ns and io avoid
direct or indi[CC[ 5�1ppaR of il0�xiplein dcvclopmcnt wherever there �5 a practicablz a!temati�e:' TEe dzveloprnest
of flca�pl.ains witl;i[� ihe GY.LN? is pro:r.cied and monih>red under Dircetpr'<Orde* i?7T-2; Flondola��.r.
M1:anagcmGrt.
Tf an alternative involving <onshucbon is imptementcd, c,'neroaehments could te minimizal
durind morc detailed design.
Tmpacts for thc bascline Northern Shore Corridor (Pnncipal Park :Road) would includc about
4.8 acres of minor impacts, 1.G acres o[moderaLe impacts, arid 1.G acres of major impacts caused
by fill. This afcer,,ativc would also ir.ciude 570 fcet of minor impacts caused by bridge
ancroach�uent within tt;c flooJplain. As compazed to tFe bascline, fhe Southern Option at thc
Forney Crcek EmbaymenT (Principa] P:uk Road) would have about 1 W additiooal fcet of bridge
encroachmenl related to minor impacts. The Southem Optioa at thc Hazel and Eagle Croek
Embaymcnts (Principal Park IZoad) �vould avoid minor and major impacTs causcd by fll and
would have about 12 fcwer acres of 611 related to modera±e impacts. This opuon would also
I�avc about 180 fewer fcet of bridgc encroachment related ;o minor impacGS. The $outhem
Opiion Crossing Pont:tna Dam (Prir,cipal Park Road), as compared to the be;olinc, would ha� c
about 0.2 acre less f ll r�lated to moderate imp�cts.
Loca: impacts �or tlxe bazeliuc Nornc�m Shore Conidor (Prinuuve Pazk Road) would include
about 3J acres of minor impac�ti, 23 acres of modente impacts, and 1.7 ac�es of inajor impacis
caused by till. Th:s altemative wou]d also havc about 180 feet of minor unpacts causc;d by
brid�c enercacha:ent within thc 17oodplain. The Sou;hern Option at the Fomcy Crcek
�m'bayzr.ent (Primitive Pxrk Road) would have abou: 03 acre less GII related to moderate
impac!s. However, iC alsa would have roiegniy 420 additio�al fcet of bridge cncroachment
reluted to iAiaor i^�pact's. .�s comptved �vit1� tl.e baseline, thc Soutttem Oplion ut the 1-1:v,el a;•:d
Eagle Creek Embaymccts (Pnmitive Purk Road) would have 3.7 fcwcr acres of fil I retaied to
minor impacis, L3 fcwcr �cres of fi!1 related to modcrate impacts, and 1.6 fewer acrrs ef fi II
related to major impacts. This option would also havc 180 fewer feet of bndge aucoachment
rclatcd to m;nor;mpapts. 1'he Sauthern Option Crp�sing Fontan�, pam (Prittutit�e Park Road), as
comp�red to the baselinc, would have aboui 02 •rcre less F.11 retated to modcratc ir.tpacts. The
PaCUaI-Baild tUternative to Buslmell (Pnncipal Pazk Road) would include abont 390 feet of
hridge encroachmuu, rosultin� in mit�or impacts. TLe Southem Option at the Fomey Creek
Embaymcnt Cor the Frincipal Park Road would inclnde un �dcitional ] 0(7 ;cet of bridgc
encroachment
The Partial•Build Altema�',ve to Bushncll (Primilive Pa*'< Ro�d) would inctude about 0.3 acre oT
iill within the floalplxii�, resulting in moderate im.pacta The Southem Option at :hc Fomcy
Cr�ek �nibaylnent fot thc Primitive Patic Road would a��o:d fll wiCyin the floodp;ain; ho.vever.
tlxe Southcm Option Eor the Primitivc Puk Road would ha�-e rough ly 420 fezt of impacts r�la[cd
to'oridge ercroachmcnt witi�ia the fSoodplai�i.
Lnpacts for thc Laurel Branch Picnic Area would indud^ about 0.5 acn: oF fill �vitnin th�
ftoodplain. Whilc the arcas of impact would be sriallec ;han those for [he Norlhem Shore
Corridor (a;l options and eit6er road typc), fnc impacLs would be n�ajor due to �: ucipated
inundation of C:�e en;rance/�it road during sto;m event,v.
Agency Consultation and Coordination - 5-28
North Shore Road Final Environmental Impact Statement

Wetlan s
In compliance with Executive Ordcr I 1990 and Director's Qrcer �f�7-1,' a"Statcment of
Findings" for wetlands wouid be developcd and re]easai 1'or public rc.wisw if a pactial-bui13 or
bui3d altemative were selected.
Ficld surveys wit]:in the study cocridors idcntificd 69 wedands totaling atwut 6.9 acres. Dircet
impac�s to wetlr�nds wou!d occur within the consavction footprint of a partial-build or build
altemadve due 10 u new roadway's embankmcnt (GIl) or due to si�ficani alter.�tion of
hydrology or vegct3tion. Chunges to hydrolory, vegetation, or oth��r environmenta( factors thai
influence thc compositipn and function ofweYlands mayresult in in�tirect impacts upstre:un or
dow�ns�eam from thc constrzcaon fcrotpriat Impacts woufd be adverse :u d permanent.
The Korthcm Shore Corridor would have greater impacts than the othor altcmatives. 'JVi th the
bascline Northem Sl�ore Coaidor, the Princip�l Park Roxd would havc more direct impacts than
the Primirivc Park Road and about equal indirect impacts to jurisdiction�il wetlands and special
aquatic habitats. '['he Pr'ncipal P:uk Iioad would directly affece 15 jurisdictional weclar,ds
comprising about I,60 acres. Of the 15 wcdands, 13 are rare communities :u,d comorise about
Q9R acre. ll�esc direci impaeis would bo major. The Prineipal Park Road would direetly impact
lu�o spei;iai aquatic habitats compnaing about 0.�3 acre; however, both arc r.1re communities, so
thc impacts woul� bc moderale. i7�e Principal Park Road wou'.d indirectly imp�ct
16 jmisdicrional weUancis wmprising about 2.09 acres, of which about 1.85 aaes are rare, ;u�d
i�ight special aqualic habitats comprising about 0.57 acre, of wtich a1I are r�re. 'lheretore,
indirut impacts would be �r.ajor to both wetiand typcs for rhe Pcincip�l Park Road.
The baseline Northcm Snore Corridor (Primitive Park Road) would dir�tiy impact
lu jurisdicdona) wetlends comprising about 1.23 acres, of which 9 are rue eommunuiea
compr;sing about i.02 acres, Thesc impacts would be major. Thc indirect impacu from [hc
Primitive Park Road tir•ould be similar to the i.idirect impxls from the Piincipal Park Road. '1')ae
Primilive Paxk Ro.3d w•ould ind�rectly impact 16 jurisdicdonal wctlar.ds com�rising about 2.15
lcres :uid six syccial aqiwtic habitats comprising ahout QS:i xrc. Of the 16 juosdictioaa!
w etlands, 13 arc r:ut: (;,bout 2.G 1 acres), ;u d al l ofLie special aquatic h:il�iWts are r•are. Si:�nilar to
tbe Pru:cipal Park Road, ct�e Primitiv� Park Road wou:d have major indircet impncts to
jurisdicdona? wetlat�ds and spaciul xquatic habitats.
� Exec�UVe Ortia 1 S 99� requ�ros ihe protection �t wetiands by fi•de.r 1 xgrncics in ocder [o "r,void to hc extcr.t
possi6;c ihe long y�� shori�tcim adverse impacts auucistcd wieh :he destn�etion or modification ofa�eda,nds and to
avcid ihe dircct or indirect suppor, of ncw con,cpycuon ia wcUand, wherever thero s a praclieablc altcmative." 1n
compliance wilh Ex.cutivc Ordtr 11990, Ihc NPS hns dcvnloped policics and procedures ia llilacloi s Ordcr 1177-1:
W��tl�nd Protection. Induded in D'uu;ier's Ordcr'77-t werc n�o�tl ol "no nct losa of wetla�ds" ay] uduptior. nf
the U.S_ Fial;lnd Wiltllifc Sen°ice'P elaesifiCntioa systcm for defi.iag clussifying, m�d i�venturylcg wcL=nneL.
Selectian oPany of thc southcrn options would reduce tb.� potcntial for direct wctltind impaccs.
rts compared with the b:ueliae Narthern Shore Corridor, the Southem Optian al the Fomey
Creek LmBayment (both road types) would avoid impucts to jurisdictiunal wetla�ids and spec;al
aquatic habitats associatcd with Fom�y and Grzy Wolf Crecks by brid�ing the Fomcy G�ee[s:um
of Fontana L.itc. However, this option would impaci weil:u�ds associatod Hdth Glady Branch.
The Yrincipa! Park Road would reciuce direct impacts to jurisdictional wetl:uuLs, includiag razc
communitics. Indiroct impacts tojurisdictio:�al wctlantis frotn il�e Frincipal Park Road would
increase, but indirect impaets to rare communilies would decrcase. The Principal Park Ro.1d
would directly and ind'uecdy impact fcw�Y acres of special :tqua[ic habitat. Ali of thcsc special
aquatic l�abitat areas are classificd as rare communities. The Pniwitive Pazk Road wou(d reducc
direct impacts to judsdictional weUxnds Uut would incre;ise ir.dircct impacts. Wzth thc Southem
Option at Fomcy Creek (Pnmitive Park Road), thcrc would be na chaoge in ;he amount of dv ttt
or uidircct impacts to special aqualia habiTats from the haselir,e Northcm Shore Coczidor.
When cotnparcd wi[h thc b�scGnc Nor(hem Shoro Comdor� the Southem Option at lhe Hazel
and Eagle Creek Embaymcnts would elnnuiate impacts to weUands associatcd with thcsc two
stream systetns bat would incraise indi�ct imp:�ctc, For this option, both road typcs would have
simi laz footprints, witl, �ost idcntical impacts. Thc Principal and Primitivc Park Roads would
r�3ucc dirext ir.2pacts to two jurisdictio.�al wc!]ands; both are ruc communil'aes. Therc would be
no change from thc b:uelinc Vorthern Shore Corridor in the direc: i.mpacts to spccial aquatic
habitats for both coad typcs The indinxt impac[s tojunsdictional wct3ancis would alsobc thc
same for both road typ�s. There would be an incrcase in indirect impacts, al] of which are in raxe
comnn.nities. Therc would be a slight di{ference in ffe :mount of indirect impacts to special
aquatic habitats for the hvo road types, Tl:e Primi:ive Park Road would impzct one additionat
spccial aquatic habitat, and :here would bc no change from thc bascline Northem 51�ore Corridor
for the Principal Pdrk Road.
The Southern Option Crossng Fontana Dam would only dxrcasc impacts to juiisdict:onal
�vetlar.ds :ind spccial ssq,iatic habitats, as this section of road would not impact any additiona]
wetlands (for both Principal and Primitive Park Road designs), Atl impacts would be reduced
lsom ihe baseline Northern Shnre Coz�ador duc to the avoidancz efwctlands. ?n �ddition, tY:e
reductions would be [!�c same for both roa8 ty�pcs �,�d ure discussed tog�thcr. The uirect :uid
indirect impacts tojuriscic�ioc�al wetlands would hc xeduced by avoidinK five wetland arcas, all
of which uc rare communitics. Thero would be no chan�e from the bueliae Northcrn Shore
Cotrider i� the amount ofspcci;�l aquatic habita[s diroctly impacted for ciTher rond type, but
indirect impacts aould be reduccd by avpidiag onc razc weiland community.
The basolinc Parti�l-$uil3 Altcrnative to Busluiell wo:ild impa; t weilands in tt�rcc g�„eral �: eas:
Gray 1�'o1f Creek, Forney Crcek, and Gtady Branch. The Principal Par:c Roatl woufd diiectly
impact five jurisdiction.al weUa�ids totaling about G.42 �cre, ofwhich about 0.13 acre is classificd
ai rare, :md indircc[ly imp:ut two jurisdic4ionxl wetlands toialiag about 0.13 acre, v,�hich is also
cl�usifiod as rare. The direct aZd indirect impacu wocId be major due to thc prescnce of rare
communiucs. Impacu to spccial aquat�c habitais m.ry also occur fro� thc Princ3pa! Park Road.
Impncts wpald d�ceetly occu= to one special aqi�a:ic haoitat comprising nbout d.007 ncre and
Agency Consultation and Coordination - 5-29
North Shore Road Final Environmental Impact Statement

inciirectly occur fo threc spccial aquutic habitats comprising about 0.26 acre, Al] four arc rare
communities. I'ho direct impaet ro speciai ac�uatic habitats for the Principal Park Road would be
modcratc, and the ind'vect impacts would bc major. The Primitive Park Road would directly
imp�ct one jurisdictional weQand totaling about 0.21 acre anc] indirectly irnpact four
jurisdictional wetlands totaling about 0.22 aera Ai] four of the jurisdiciional weU�nds dtat may
be indin;ctly impacted are tare. Tht Primitive Park Roud would have no direct impacts to special
aquatic hubiwt azeu, but may indirectly impact about U.2G acrc o1'three wetla�ds classificd as
r,ue. Direct impaets tojurisdictional wetlands and special aquatie hnbitats would be modcrate;
however, due [a the preseace of raro communities, tlie indimct impacts wouid be major.
As Compared to thebaseiine Partial•Build Aitemativt to Bushncll, ihe Southem Option at lhc
Fomoy Crcck Emba}�ent (bo;h road types) would avoid impact� ro jurisdictional wedands :uid
spccia] aquatic habiTats asseci:�ted widi Gr.ty Wolf and Fomay Crecks. However, this option
would impact wetl<wds associated with Glady Branch, The Principal Park Road would reducc
direct impacu W junsdictiooal wetlands, including raze commm�ities. 6idirect :mpacts to
jurisdictional uetiands from the Principal P;ark Rond would inaeasc, but indirect impacts to rarc
coromunities would dccrease. Tho Pxincip:il Park Road would d�:ectly and indir�tly impact
few�r ucces of speci�l acuatic habitats. All of these special aquatre hnbilat areas �e cl.�ssifiul a.
r;ue communities. The Primitive Park Road would reduce direct impacu tojurisdictional
wetiands but inercase in3irect impacs. For lhe Pnmicive Park Road, there would 6c no change
from basclinc P;utial-Build Aitccnalive to l3ashzcll for direcf or indirect irnpacts to specixl
2quatic h�bitats,
Watcr OuaG'.v
Eac;� stre,un cross;ng crcates an opportuniry for impacting wafer qualiry. I'he stccp terrain cause;
strcams lo respond quickly to rainfalt evcnts, and ;u�y pollutants would quickty enter watcr bodies
dunng these event,.
ihc pnmury w.,tcr quality concems for thc censtruction of a ruac; in the project sNdy araa aze the
F: es�ce ef po;enti;illy ucid-producuig roek �.�cl sedimentation due to laind-�3isturbing aerivicies.
Exposure or dish�rb:u�ee of acid-producing rock coutd result in inereased acidity, inercased
suifates, Sncrcased heavy meYals, wd aauatic wi Idlife mortttliry in streums and I�:l�es within tiie
projeci study area Construction �ctiviries would likely resuit in decreased dissolved oxygan
from the decon;po;ition of ax�anic material in receivirg �vnters and .rom increased sedimentatior,
ani
&om land disturbir.g activitics and erosion. �cse ad�erse imnacts wocld result from ali dic
partia;-build and build altemattives.
?mpacU with tl�e baseline A'orthcrn Shore Corridor woul�l be tL•e greatest �i�ith [he pnrtiul-build
�.�d build altematives due to lheir ]c�ngth, prox¢nity to known acid-producing rock, and
141 str��tm c-ossings. Thc southem op�ons, which have i Z to l7 fewer sCrc.m cros�ings, wouid
:ednee the potentizl impaets to water quality. Howevec, the intensity of the impacts would aoY
change, Impacts to water r,uality would still occur but at fewec locations. For th� most part, no
ditference in ianpacts is expecud between che Pnncipa! Park Rond and the Prin:iuve Park RouJ.
Tmpacts �o pH with the b:ucline Nonhztn Si:orc Corridor (any option znd both road ty7�es) would
bc major (violations Gkcly woufd occur), long-tcrr.�, . nd permancnt duc to intrusive rock bctwccn
Eaglc and Hazel Cn:eks. Becausa detailcd gwlogy is uiilmown, impacts for the baselinc
?artial-Build Alternutive to Bushncll would be modcrate (violations may occur), long-term, and
pemianent due to the potcatial for acid-producing :rocles {any opton and both road types}. W i:h
thc I.�:urel Braneb Picnic Area, impacis would be moderate (ti iolations may occur), long-term,
and permanent if there wcre no special mitigation or avoidance of acid runoL'F.
With thc Northem Shorc Corridor (any option and buth road types), die short-tcrm and long-ternt
impacts from decreased dissolved oxygen (DO) wou!d be moderate (vio]aAOns rnay occur).
Afta construction, the DO eoneentratio�s would return to precaastrucuon levcls because no
add;tionat organic mattcr {vcgetation) would bc cn_c,r:ng tha systom. Thus, perm•�.�ent impacts co
DO would liketybe ncgiigible. TUe shoR-ar.d long-:cmn impzcts resulting 6om the
?artirl-Build Aitcrnative to:Bushncll (any option and both roa�l types) would be modcr3tc
(violations may occur), and thc permar.ent impacu would bc negligible. blodcratc (violaiions
may occur) shoit-tcrzn impa�ts wou;d bc anticipa[ed with the Laurcl Branch Picnic Arca.
Based on ihe �eology of thc Northcm Shore Corridor, thcrc wou',d be major (eiolatior.s ;ikcly
weuld occur) impacts for the baselir.e Northem Sfiorc Comdor. 'i'he potentral for the imp�cts
would cx;sc for tbe shor[ and !ong term durin, construction, wher mincrals could be exposed at
utLl'nown locations. '£here would be subsequcnt permm�ent impacis if thc�c au:is .veze not
mitigated. Due to thc> low ttaf5c volumc, ihu permar�ent impacts from vehicular sources of
metals wottid be negliglble for the Principal Yark Rond and minor for the Pri;nitivc Park Road.
Based on thc geology of the Paztial-Bui1J Altemativc to Bushnell (::ny option and boih road
types), mcxleratc (vioiabons may occur} short-term, long-tcrra, an3 permanent impacts would be
anticipatcd fTOm potential r,aturall,y occuning hcatiy metalg. �ue to Ute potcr.tial r�reation:il :u�d
pnrkin� fseilities a:Sus�rcli, n,;nor lon�-tttrr and parn�an�nt inip.sots cae a,iticit�aced .Gam
vehicles az�d mnolTC:om parking arcas.
tificor shart-icrm, long-term, and pcm�:uient impacts would be anticipa;ed with tlie Laurcl
Bt�ne : Picnic Area if therc were no avoidancc or minin;iraiie� teclvuqucs. Dua to ti�e
aa[icipated aaffic volume, inipacts from vehicles (heavy mctals) would be mtnor, lonp Cerm, and
pe�maner,t.
ScdimentatioGi and an increase iq twbidity would have the grcatest impnct ut streani aossir:gs.
Thz b;selinc Nonhem Shero Conidor (boUi road types) woula ha�e majoz (�•:olaticns likcly
�yould occu:) short- and lon�-;crn impaccs duxin� cor.suvction. The pexmancnt impacts wou;d
Agency Consultation and Coordination - 5-30
North Shore Road Final Environmental Impact Statement

be ncgli�ble for ti�c Principa] Park Road and minor fur Qie Primitivc P:erk Road. The southcm
optior,s would reduce stream crossings, bat overall impaot intensities would not change.
Ma;or short- and long-term impacts duc to conshucfion ruooff and sed;mentation woiild occur
with the PazYial-Build A(temauvc to Bushnelt (botl: road types). The perutancnt impacu would
be negl:gible for the Principal Park Road. Thc permanent impacts would bc minor for the
Primit;ve Pa.�k Road duc to runoff from thc gravei surk'ace of d�c road.
Tho Laurel Branc6 Picnic Area would l�ave major (v;olatSons likcIy would occur) short-term
impacts duc to sc;dimeniarion from conslcuction-related activities. Long-term and permanent
i:npac�s from runoff from the parking lot and recreatioital activitics would be minor.
Aauatic Imnacts
Adverse impac�s to aquatic wildlife within lakes, streams, and wedands (col?ectively referred to
as aquatic habitat) arc expected from all the build altematives. Impacts to aquutic wildlifc habitat
wuid result 4om sedimtntation because it alters habitat or dcereases visibi liry; strcam crossings
that crcate fish-passage barricrs; r;parian buffer rcmoval because it ahers availabic food and
t1'�ermal regulalion; runpff from exposcd acid-procluci:ig rock; and watcr-lcve; fluctuatio�s. .4ny
partial-build or 6uild ahemativc would have impacu ro aquatic wildlife, with thc Northcm Shore
Corridor h.aving the geatest potential and �he I,aurel 8rnclt Picnie .Area having the least
poteotial.
The bascline Northem S�torc Corridor would havc major anc: lon�-term to permancnt impacts :a
aquntic wildlife habita*. within shca�ns for both [hc Pnncipal and Primitive Puk Foacls. Tl�is
a:temarive w�ould poten(i:�llyimpact grcater ihan 0.5 tnile of ripuivi buFFers along three
strcuns--Shehan Branch, Hazel Creek, and an unnamcd tributary to C6eoah Lakc. The Southem
Option at the Fomcy C�ek Embayuicr,t would avoid impacts to Fomcy Creek. This option
would reducc direct impacts of thc Priacipal and PrimRivc Park Ro:uis by zbout i0 percen[ as
compared with thc baseline Northem Shore Corzidae Tnd'uect impacts would still xcur bu?
would'oc reduced from the b:uclinc Northem Shore Corrider. The Sou:hern Op:ion af the H;vel
and Eagle Creek Embaymc7�s would reduce direc[ impuc4e by about 3G and 41 percent,
respectively, for thc Principal :uid Primitivc Park Roads, as comparcd with the b�.celiue Nonhcrn
Shore Cortidor. Indirect impacts would be ezpected, but would be reJuced from die bascline
Nonliem Shore Corriuor duc to fewer stream crossinss. The Southem Opaon Crossing Fontana
Dam would avoid up to 16 stream crossin�s, potent;ally reducing the direcc and indirect impacts
to aquatic wildli fe streams by about 71 percent for cach road type.
The haseltne Paztia!-Build Alternativc to Buslmell, which includcs a boat rcunp, would result in
fhe wmplete ]oss of about 0,34 acce oFaqi�alic habi,at within Fontana Lake. Impacts fron the
boat racip would be moderatc and permanent. lndi[xt impacta to ayuatic habitat within Fontara
J.akc would be rnodecate, long-terrn, and permanent. flnpacts from both xoad typcs, based on tl:e
area of impact, would have major, permancat dircct impacts and major, Iong-icmi ir,direct
impaets to stream an�+ wc(land aquatio habltat, With the Soutliem Option at lhe Fomey C:eek
Embaymcnt, lhe potential for di:�i anJ ind'uect L�npacts to aquaric habitat wowd be reduced
from the baseline Partial-Build Aftern�fivc to Bushnell for both road types bycrossing 50 percent
fewer streams.
Dircct impacts to aquatic wildlife habiLZt within str�ms would bc moderate :uid pennancnt with
the Lauret Branch Picnic qrea, (ndlrcet impacts would bc moderate for the short and long tcrm.
Vcgetation Communitic5
Direct imputs to vcgctation communities wou]d uccur as land is dishu�bcd in constructing a
partial-build or build altemative. Potential alteration of downstream hydrology; chan�es in
��nvironmental conditions :�csociated with edge effats, such as alteration of atmosoheric moisturc
levels, incrcased wind �d sunlight cxposure, and changes in temperature regimes; and the
ixreased potcniial for human distur6ance have the potcntial to indireccly impact thc distribulions
of vcgctation species acd thus alter the vegetation community lype. 7'hese impacts would be
adverse and pennancnt.
Ihc Northem Shorc Corridor (both road typcs) would result in major impacts to rare vegelation
cu�r:tvuniucs and major impacts to securc vegetntion conununitics. Thv 1�orihern Sl�ore Coaidor
(?r.ncipul Park Road) would �irecUy impact ;ibout 36.4 acres of rare vegetaUOn communities and
about 351.53 acres of secure vegetation communities. The Northern Shore Corridor {Primitivc
Pack Road) wouid direct(y impaet about 38.1 acres of rare vegeta�on communities ar.d about
?SR95 acres of s�ure vegetation communities, For both ro2d typcs, the Southem Option at thc
Foi�aey Creck Em6ayment and thc Southem pption at thc Hazcl and Sagle Creek Embaymcnts
would reduce dirat and indircct inipacu. The Soul�crn Option at the Fomey Creek Emhaymcnf
(Pri�e�pal Pack Road) would recluce the direct impacts �o rare vegetation cocnrnunilics by abou[
7.29 acres a�7d to seewe eommunitics by about 8,0 acres. The So¢thern Option at the Forncy
Creck Embayment (Primiuve Park Road) would reduce the direct unpacts to razc vegctafion
communiues by abouf 5.51 acres and to secure communides by aboi:t 430 acres. There would
bc an associatcd proportional dzcreuse in du indircct impacts (both road types). For the South�tn
pption at thc Hazci and Eag�e Creek Embaymenls, the Prindpal Park Road would reduce tLe
direci impacts to rare vegatz[ion communilies hy aboui 1R.47 acres and to secure cemmutitie_e by
about 19.Q2 acres. The Prir�itive Park Road would reduce the direct impacts to rare vegetation
comrnuni:ies by about 19.49 acres and to secure communirics by about 10.18 acros. There would
also be an aswciaied proportional decxease in the indirrct impacts to both community ca:egones.
Fo: theSou;hem ppaon Crossing Fontana D;ui;, therc would bc no change from impacts to ra,-c
vegeYa;zon communities from Ihe basclinc Northem Shore Corridor (both road lypes). However,
the impacts to secure eoaum3niti�s wou!d be reduced by about ? 8.80 acres with the Pr.'r.cip:1
Park Road ud by about 18.86 acres witin the Primitive Park Road, with an associated
proponion:il de„^rease in the ind'ucct impacts to the secure vcgetation communities.
Lmpacis resulting from the part:ai-build altcmatives wou'.d be less than from thc ?ve:them Slzore
Corridor. Tne Partiai•Build Altemative ro Bushrcll (Principal Yark Road) v✓ould direcdy in,}�act
:uont ] 9.90 acres of r�c vegetxtion communiYics and nbout 7I.53 acres of secure vegelaoon
Agency Consultation and Coordination - 5-31
North Shore Road Final Environmental Impact Statement

commtmities, The k'rimitive Puk Roati would;mpact ahout 1834 acres of Appalackuan
Montane Alluvial Forest, a rare com�nuni;y. Additionally, about 80.76 acres of secvre vegefation
communities would be d'uaUy impacted. The direct and indircet impucts to rure communities
were assessed to be major, znd thc diiect �nd indirect impacts to the secure communitics would
bc cur.or (both road types). The Southem Opdon at thc Fomcy Creck Embayment (Priroitive
P:frk Road) would ruiuce thc ducct impacts to the Appalachian Mon4ane Ailuvial Foresl
Community by aboat 5.51 acres wd to secure communiti� by ahvut 4.30 acres. The Soudiem
Op.ion at the Pomey Creck Embayment (Principal Park Road) would reduce the direct unpacts to
raze vcgetation communities by about 7.29 acres and to secure coaununitics by 2bout 8.0 ac*es.
7he Laurel Branch Picnic Area would directiy imput about 3A0 acres of Appalachian Montane
Alluvial Forest. Dirxt impacts to this rare community wauld be minor, while the in&xect
i:npacts to d�e remaining local portioas of the care vegetation couununiries would be mioor. ln
addition, about 5.54 acres ef secure vegetation communitics would be dircetly impacted. Thz
direct and indirect impacts to ?he secute communities from this altemative w�uid be negligbie.
Tccresttial Wi1dliFe
Both ditect and indirecl impac.s io tcrreshial wildlife may result fro:n a partial-build or build
aitemative. A d;rect impac: to terres[rial wildlite would be the loss of habitat within the
constcuction Yootprint, while indirect impacts could includo habitat fragrncntation, intcrruption oI
mi�{ation pa.tems, incre:ised sound frotn ltumazi ac.ivity, and dec;e:�sed habitat quatity. Impacts
arc advcrse and dirc ctly rzlated to the leng,l� of the par[ial-build or btiild altcrna*.ivc and its
distance fror,i the northecn shore of Fontana Lakc.
Tl�e ereatest impacts arc associmed with ihe baseline Northern Shore Corridor, which would
resutt in the direct loss of about 392.2 acres and 400.6 acres oi'potcntial terrestna! babitat
associated with [he Pnncipal Park Road ard Pcimitive Park Road, respeedvely. Impaecs due to
thc d'ucct los, ef habi�ut, as well as from ecosystem fragmcntauon, arc anticipatcd to bc major
and pennzneut (beth road t}pcs). Impacts rclatrd to sound level inereases would z*:ost likely be
major and ]negScrm. Thc eou�hcrn option�, whicL byp3ss a n-:ore inter'o� portien ^f the
CSMNP, would recu:t in icss L*a�Rnencuxien of hab� cac, kor the Southern Oprion at the Fomey
Creek Embaymcnt, the Prir.cipal Park Road would reduce the d'uect loss of habitat oy about
15.9 acres, and the Pnmitive Park koad wouid reclucc thc dir�rot ioss othabitat by about
9.5 acres. The Southern Oplion at the Hazc! and Eagia Creek Embaymenls wou:J xeduce Uae
d'ucct loss o f hzbiiat by abeut 37.1 acres with thc Principal Pazk Road and by aMut 2�.4 acres
with the T':imilive Park Rozd. With the Soutlaem OpLion Crossing Pontana Dam, the direct loss
ofhzbilat resulaug fiom co;LStruction ofL"c Principa3 Park Road would be reduced by abo❑t 212
acres, and the dircct loss of:nabi(at associated with che Prnnitive Park Road wou!d be reduced by
abouz 20.7 acres.
Thc Panial-Build ,4ltemative to Bushncl] wouid tesult in ihc sunc [ype of im.pacts that wo�:ld
result from tne Northem Sttore Cortider, but thc arca of clirect impac� wpu!d be reduczd. The
baseline Partial-Bui1d Altcmntivo to $ushnell (Principal Perk Road} wouid resu!; in the direct
loss of about 92.4 acres ofhabit;�t. I'hePrimitive Pa;k Road would result in the direct loss of
about 99.4 acres of habi,at. Impacta due to the d'ucct Ioss of habiklt �vithin the construction
footorint ;md due to habitat frag�nentation (bolh road types) would be mioor azid ptrmancnc.
Impa�ts duo to sound cmatcd by hum:�� acrivity, such as roadway constructioa, would be minor
and long-tcrm (both road lypes). As compazed to the bucline P.-utiaL-Build Altemative to
3ushncll, thc Sou!hcrn Op�on at the:Fomey Creck Embayment woufd re<l�ce tlze overal� impacts
withui th� project study corridon. The Principal Park Ra�d would reduce the d;rect loss of
}aabitat by a6out 15.6 acres, and the Pnmitive Park Road would reduce the d;rect los,a oP hab',tat
by about 9.5 acres.
Aboui 9 acres of habitat wculd bc lost from bui!ding the I:urel Brsnch Picnic Atca. lmpacu
fron tl�e direet Ioss oPhabital would be negligible and pertnanent. The sound ae�ted by
construction and other human.a3uscd �isturbance ac!;vities would d:rectly affect wildiife by
causing species to avoid thc I�abitaT. Soundscape impacts frmn traffic noise :vould bc ncgligiblc
and long,texut.
Mieratorv Birds
The assessment of impacts ;o magratory birds and thcir habi±ats is rcquired by law prior to ury
accion, :� directed by Executive Order 13186 and the MS"fA. Poteatial impacts resu;7ng From
thc a�trtial-Nuild and build altemauv;s include mi�ratory bird hxbitat loss, habit3t
f-agmientatioi�/edge cffcct and soundx:,pe d;sturbance. Lnpacu wo,�ld bc advcrsc an1
permanen*, wiin the exception of constrvctien-rcla*.ed impacts tha[ would be long-tem_ 'fhe
Northern Shore Corridor would have thc grcatcst impact on mib�ratoiy birds, as comprse3 with
the othec nitcmatives, d��e to thc sizc oFthe constraction `ootprint acd Uie expected durauon o:
consm�cton. The Pnncipal Pe.rk Roaci wouid impact about 392.2 acres of migratory bird hlbitat,
xnd tl�e Ptimitivc Park Road would impaU about400 fi acres of migratory bird habitai, Po'ential
impacts due to habitaY loss, impacts from sound gcnerated by consh-�etion utivities and facility
operutions, azid effects relatrd to habitat hagmentapon and edge effects would be major (both
road typcs). Impacts wouid bc slightly reduccd with thc souihcm opcions, as these opdoos we�ld
impact less migraCOrv bird hatitat thsr.would Lhe c:iseline �orthem Shore Corridor. ::so, in
these oPtions, decreases in sound levcls and habitac frav,mentatiou may acconpany ihe sma!Icr
constructiun footprint Fo: bo;hroad typc., the $outhern Option at [he Forncy Crcek Embayerer,t
�vould providc a srnall dccrease in tiie construction footprint, soundscapc intrusion, and possible
negative effce+s af habit�t &agmentation relative to thc basciine 1Vorthern Shore Comdor. The
Principal Pazk Road woulc rcdticc ihe construction footpzir.t by about 15.9 acres, and thc
Pdmi:ive Park Road would reduce the constracdon feotprint by about 9.5 acres. The Souttaern
Op:ioa nt the H:u,e1 aad Exgle Creeic Emba��ncnts would impact aboui 37.1 fe•�+,'er aeres of
habitat with thc Principa] Park Road and z6out 25.4 f��vcr acres oErabitat using the Primitive
Pazk Road. Fhcse opticns uould aiso res::lt in l�s soundscape inirusion und habitat
fra�ncntation th:ut with the baseline Nonh�Yn Shore Comdor. Conrirvction of the S�uthera
Op:ion Crossing Fon;aoa Darc using thn Priminve Yazk Road would impact about 20.7 iewer
acres of migratoty bird habitar ����n the ba,�elinc Nortncm Shor� Corridor. linder this op;ior., the
Agency Consultation and Coordination - 5-32
North Shore Road Final Environmental Impact Statement

Principal Park Road would affcct abou'. 21.2 fewer acres than thc baseline Northern Shorc
Corridor.
The Partia.•Build Altemativ� �o Bushncll, which h�,4 a smaller construcuon footprint and shorter
construc6on penod, wou?d result nt Fewer impacts than thc Northern Shore Corridor. Possihlc
impaccs for this altemative also includc migratory bird habilat loss, habitat fragmentaiio4 2nd
soundscapo disturbancc. Thcs� impacts would Ix minor for th� Principal Pazk Road and
Primitive Park Road. Thc construction footprinc resulting from the Principal Park Road would
be atwut 92.4 acccs, and [he construcdon foo:print resulting from thc Prim:tivc Park Road woidd
be about 99.4 acres.
lnvnsivc Exotics
The partia]•build and huild alternatives would crcate condit;ons such as disturbcd roiside, Forest
edges, and opcn spaces that favor invasive exotic spec�es. Thcse adverse impxfs would cause
thc loss oFna!ive plant habitat duc to the loss of shading, temperaturc changes, new wir.d
pattcros, ch:��ges in soil conditions, �urd crear.on of roadside habitats.
As comparcd witf� the other altematives, thc basclino Nadhem Shore Corridcr would have the
grcatcsi potential io crcatc favorable condi:ions for invasivc cxotics. The baseline Northcm
Shore Corridor would impact 30.8 miles with the k'dncipal Pazk Road and 34.3 miles with the
Primit;ve Park Road. Ti:cse impacts would be major .,nd perm:ment. The sou[hem options
decrease thc potcnC�l for invasive specics to penetrate lo more interior poxions of the GS',vLVP.
The Southem Oprion at t:�c romey Creek EmSa}ment would resuit in 1.3 fewer ;niles of impacts
for the Principal Park Road and 1.5 fewer miles of impacts for the Primirive Pazk itoad. Thc
SouCnem Option at the Hazet aud �agle Crcek Emhayments would havc 3.1 fcwer mifes of
impacts Ior the Pnr�cioai Pazk Rond and 23 fewer milcs ofimpacu for ihe Primitive Park Itoad.
The So utlient Option Crossing Fontana T�am would havc 1.5 fewer miles of uupacts frorn thc
Princip»l Patic Rozd und �,G fewer nu(es of impact, for t6c Primitive Park Ro.td.
Thc. bzselir.e Pa,tia!-Bci]d A(ter„ative to Bushneit wou;d ca�se nSoct 6.5 m;;as ci L-npact; Lrom
die Principal Park Road �uid about 8.0 milcs of impacts from the Prin;itive Park Road. Imp��cts
from both road types would bc minor and perrn:u�ent. The Southcm Option at tl:e Fomey Creek
Embayment would havc I.� fcwer miles of impacts for thc Principal Park ROad m�d LS fewer
miles of ampact :or thc Primit;ve Park Road.
Federaly Protec:ed Soecies
Section 7 of ihe Act cequires federal agencies to eons�tlt with che U.S. Fich and Wildlife Senice
(Service) whcn any act4on tze agcncy carries out, fuads, or aut6orizes may affcct a listed
cndangcred or threatencd sp:cics. Potentfal impacts to 15 fcdcrally piuiccted species were
evaluated i� the prepacation of t)ie DETS. The proposal p-ojeet would have no effect on the
Ca:olina northcm ilying squirrel, r.00aday g]obe; s�rucc-5r moss spidcr, or rock �omc ]ichen
d�c to the absen; e of!iabiL�t for thesa species in the projcct corridor,, Hab�tu; fcr t1:e
red�cockaded woodpec;er, bog furtle, spotfin ehub, Appalxchian elktoe, little-wing peazlyr,lussel,
smz11 whoried pogonia, and Virginia spirae� exisu in thc project comdors; howcver, nona of
these spccir,s were identi5ed dnnng ficld survcys. Habitat ulso exists in tha project wrridars for
thc tcd wolf and eastcm cougu. A reinVOduction of red wolvcs into tha GSMI�'P was
unsuccassful, arxd the population was removcd. Recondt of thc crstem cougar are over 20 ye:i*s
old, and this nativc cat is believed to bc extirpated fiom the project sludy area. Based on
i:xfonnation colic�ted to da�e, none of thc proposed alternutiv�a would zffect these species.
Tn the DFSS, impacts are assessed on the known oeeurrences of the fedcrally threatene�i hald
cagle and potential habi4it for both thc bald eagle and thc cndangared Tndiana bat within or near
thc study corridors. bircct loss of habitat would occur within constructioa limits. Soundscapc
impacts from Vaffic noise ;usociatcd with road consLuction actirities und human disturbanccs
from the usc of a roadway:utd any �.:ssecia`ed faeilities are anticipated with the Northem Shore
Co.�ridor and Partlal•Build .4ltemative to Bushneli for the bald caglc and with the Laurcl B: anch
Picnic Area fot the Inclian� bat. Theso unpacts would be adverse .md pennanent.
Future eoordinatiou az�d consultation, including a biological assessment (i1'required), wiii� tbc
Sctvice would depend on �he alternativc ultimalely stlected. A biologic:il assessmeni would be
completcd if a p�utial-build or bui Id �Ifema6ve is sciccied. Tt may becomc ncc�sary to cnnduct
additiondl survcys for feder,itiy protect� �eaies as morc refined project desigcs azr develope3.
Lzdi�na Bat
(mpacts to the Tndiana bat dua to direct !zabitat loss aad a pote�tidal reductiun in habita[ we
surroundir,g thc new roadway and any associatal facilities would be greatcsl with the baseline
Northem Shore Coaidor. About 387.03 acres of potential habicat would be impacted by thc
Principal Park Road. The Primitivc Park Road woulQ impact about 397.79 acres of potcntia]
habizat. Iatpacts due to d'ucet hab�t�t loss and a putcntial reduction in habitat usc surroun�ling the
road and =ucflities arould likely be minor. "Thcse imnacts aze the sainc for both the Primitive and
Principal Paiic itoads. AU of the southcrn options would likety deerease possible impaets due to
decreases in the eons!ruction feotpnn!, huma:i i2flaenee �ore, �nd hzbi;at :raga;cr,tation.
The Partiat-$uild Altcmaii�e to Bushncii would imput about 91.43 acres of habitat with d:c
Principal Park Roa3:u�d about 100.42 acres ofhabitaf with the Pnmiqve Park Road. ?mpacts
duc to direct habitat Ioss and a potential reduction in habitat use surrounding the ro�d and
facilities would 3ikely be minor, Thcse impacts aze the samc for both the Primitivc and Principll
Park Roads. As cornpaccd to the buscline Par[ial-Build Altemarive to Bushncll, the impacts
tivould likely bc rcduced *or tlie Soucacm Oplion at the Fomcy Crcek Embayrr�ent.
About 8.96 acres othnbi�at witilin tlie GSMNP would be im�acted by the Lau:el Brunch Picnic
Arca. Impacts due to direcl loss or a pountial reducLion in habitat usc s.uroundirg the road a�id
facililies would likclybe minor.
Agency Consultation and Coordination - 5-33
North Shore Road Final Environmental Impact Statement

I: a par,iti-b::ild or build altemativc is selectcel, the NPS would dcvclop a compreh��sive survcy
plan for the Indiana bat to determine [his specics' stahzs noar Ihe selacted alternativa Thc
objecrives of the survey would be to ev:tluate potential habitat, espaially thc summcr mator.uty
rooslinb potentlal, and to detcrmine tf�e actual utilization of the area. The survey wouid assist in
iden4fying matemity cobny sitos and cstablishin� appropriate tree-cuttiog morn;oria Surveys
wou;d bcgin pnor to khe initiation of construction. Tbc survcys would fol',ow the mist-nating
guidelines as speci5ed in thc Indi�na Bat Revised Rccovery Plan. Yeuriy population moniroring
would be conducted by the NYS during and following any construction. Coordination u-i:h thc
Scr+��ice would be ongoing to dctcrmine the nxd fo: additionai recommendations to protect or
mitigufc for impacts to the Indiaua bat.
Bald Eagle
Tlie majonty of the conmuction footpr.nt For any oprion, u wcll as both road types, acsociatcd
with the Northc,n Shorc Comdor is ]ocated within I.0 milc of open water, resulring in potential
impacts to bald eaglc habitat. About 300 feet of the bascline Principal Park Road wov:d be
widvn the sccondary m:uiagement zone for bald eagles. Tmpacts due to sound associated with
eonstruction ec�ivities and duc to human disturbance from use of thc road and faciiit;es would
likely be nxinor and long-tcrm tv perr?aanent wiin thc Principal Park Road aod the p;imilive Park
Roaei. Poc the Sou€hern OpEion at Fomcy Creek, abou_ 2,375 feet of thc Principa] Park Road and
3,775 feel of the Primitivc Pazk Road wou'.d be locatcd in thc sccondary exgle management zonc.
This option has an incrcase� potential for impac(s due to iu �rc;atcr presenca in tl�e vicinity of a
b:! Id eagle nes[. Ti�c rcmaining soufliern options would likely increase pos,eible impacts duc to
theic proximiry to hald eagle hsbitat.
The Psutiai-Build Altcmativc to Bush�aetl would impact Coraging acli vities of tkre baid eaglc duc
to ir.creased boa?rng a,csodated with lalce aceess af the proposed facility. Dewelopmen± of the
Buihneil :irea, espccially the boat raznp, would likcly lcad to increased boating acuvity in thc
vicinity of s kno•am bald ea�le nest. PoRions of Fonkana Cake in tht vicinity of thc eagie nest are
within are:s desienatcd zs primary and secondary bald cagic managemen� iones. About 30U fect
of [4�:e baselinc Principal n:ir4 F,ead ate wiCnin Lhc sccer.dary bsld eag:e manageme::t 2on:.
Tnpacts dac to sound associated with construclion ac�ivides would likely be minor and
tong-tc;m. imp��u due eo tamr.an disNrb:u,ce from use of thc roac} and facllit;es wau!d likcly bc
mincr und pecinancnt. Impactis on foraging activitics duc ta inereased boatiug associaced wi;h
potentia] iner�vcd laxc access at tlie propescd facility would like;y be adversq local tc regionai,
permanent, and modera,tc.
As compaed !o lli: baselinc Partial-Build A(temative to Bushncll, tl�.c Southem Ontion a' Fo:rry
Creek would have :tbout 2,375 feel of the Pzincipal Park Ro:cd and 3,775 fcet of che Pnmitivc
Parl: Road within ihc sccondarv eagle managemcni zonc. The possibilities for ot(ier impact; arc
Iikeiyto be inctcas;d due to the alte.-nativc's proximity lo bald e;igle habita[. If an altcmztivc
involving conshuciion, o;�a� tl,an thc I,aur¢i Br�nch Pirnic Area, werc implcmcntcd, the n�S
would dovatop a comprehensi��c survcy and mon9toring plan for thc hald cngle t�o detmnine t6is
spccie,' status in tho GSM7VP. Coordination with thc Scrvice woultl be ongoio� to determinc the
need for:additional rccommendations to protect or mitiga[e for imp�cts to thc bald cable.
Tf an a:temative involvir.g construcuon, other than the Laurel Branch Picnic Area, is
implcc,ented, the NPS woula devefop a comprehensive survcy and raonitoring plan for the bald
eagle to deterrnine this species' stat�s in thc GS�INP. This plan would be devaloned in
cooparation with property managers oP land adjacenc to ihe GSMNP. 'The monitoring of known
eagle nests wo�ild follow the Service's Rald F,agle Monitoring Guidetines :u:d thc Habrtat
Management Cuidelines for tFe Bald Gtg(e in the Sou[hew: Region. Surveys wouid boy,in pnor
ro �ie uritiation of cons`wction. Yearly population monitonng would be conductcd by the NPS
during and following any conshvction. Coordination with [he Service �crould be ongoing to
determine the need foc addi¢onal recommendatior.s to pcotect or mitigatc for unpaets to the bald
caglc.
Othcr Specics
Thc DBIS identifies 25 `edera! species of cor.cem (FSC) for G.^ahun Counry, NoR:n Carolina,
and 4G PSC and 1 candidatc spccics for Swtin Coanfy, Narth Carolina." These species are not
protcctcd undcr thc pro�isions of section ? af tLo Act. Additional species reccivc protccaon
und� North Cnrolina General Statutes or statc laws. NPS policy includes the protection oCFSG,
candidate, ar.d statc•protceted species tp the s:une level :u endangered and th;entened spec;es. Of
:ecsc specics (FSC, candSdate, o� siace-protected), there are 12 vertehratas, 5 ir•.eaeb:ates, and
3 plant specic:s kno�vn to occur within the project smdy corrfdors.
Records �f the tocal ran�e and status of FSC and stltc-protcctcd spccics in �tic GS'��l' are not
complete. investigations undertaken for !he DETS have JiscovereJ species new to the GSN(NI'.
ncw rccords Por ��ies kr,own from tha CSb1NP, and specics ncw to scicnca Thcsc
i�tvestigations did not constitu:C a compreaensive survey of the project study corridors, and they
eovcrcd ]�:s than 1 percent of the total land contained withui tlie GS.'�fNP.
Enviro[unentaliv PccFe.rred AiteroF�tive
As dcGned by the CEQ: "l'he er.vironmenta;ly prcfcnb;c ;�ltcmativc is thc altcrnadv: that tvi11
promote ihe nacior,al envirunmenta; pouey as expressai in VEPA's Sectioa 10i. Ocdinarily, this
means thc :tltcrnativc that causes the least damage to the biolo�ncal wid p3iy5ical envirorsneat; if
alsp mea�s tlze altcrnative wltich bcst protccts, prescrvcs, aad cnhar.ccs historic, culNral, :md
r.atural resourccs.' After consideraaon of Section 1C1 with regazd to the detailed study
alternatives, the bfoeeta_ry 5ctdcmcat Altcmativc wa� seletted as the Environm.en!ally P-ef°rrcd
Alternativc for this project because it best adheres io Yhe goals desc: ibcd by the CEQ. 1"his
altcrnative is not neccssanly �he saaie ss the Pzeferred Alternative nor is the yPS tequircd ta
selecl this altemarive as the Prefcrrcd Altemativc.
1'�e Scrvicc curicnciy (14arch 29, 200;i) considers Or�hnm Couttry to �av; 2S PSC : nd Sv,�a ia County lo he'; c ,—�
,39FSC,.A^o _tt �I
` PY ^
" hc rkist recen; lut for these two cou�cies is enalos:d. i JSFW S� t �
L—__'_' -___— � _ _. _.__—.__._ "___._ ___�
Agency Consultation and Coordination - 5-34
North Shore Road Final Environmental Impact Statement

l,east Enviro.�uncntallvDamaeine PracticaAle Allern;iliva
T1�a Section 404(bxl) Guidelincs, publishct? by Ihc Environmcntal Protcction ngency in
conjunclion with the U.S. �'�rmy Corps of En�ineers (Corps), contnin substantzvic e.nvizoiune�atzl
criferiu used in evxlua6og discharges of dredgcd o: fill matcrial. Under these guidclincs, no
dischazg� can be pem�itted if a practicablc :iltcrrative K�ith lcss adverse impacfs or the aquatic
environment (unlcss thc idcntificd altcmative poscs other significanl environmentaJ
consequcnc�s) is available. The Corps re,quires that an ETS, being prepared for an action which
will rcquirc a Seclion 404 permit, identify the Least Environmentally llamaging PraUicable
A1ten,utive on the aquadc environment in accordanec with the Scetion 404(b)(1) Guidclines.
Howcvcr, du Cocps' cv�Fuation ofa Sec6on 404 p�rnit application is a twapazc test in�olving
(1) a deterniinadon of wheYher the project complics with thc Scction 404(b)(I) Guidclincs and
(2) a public interest revia'w. This p�hlic interest review is a balancing tast in whicli th� public
and pnvate benef,ts of a project ue compared against its adverse impacts to die envimnment. lt
includes such considcrations as cansrnation, economics, aestl�etics, navigation, fish and wildlif'e
valucs, wzter supply, water quaGty, ener�• nceds, floed damago prevontion, a-�d cultural
resources. 7'he Corps also considers all cornments reccived in the permit process, whether in
response to a public noticc or a puhlic hcaving. A permit c�nnot bc issucd or an application must
be denied if the project faiis to comply with the Gvide(ines or is found to 1x ca:t:ary to t!�e
pub ic intzrest. ln that tlie Monctary Sctticmcnt titcmativc would not invoh c fil] in'watcrs of
the Unitcd States;' and �x�ouid have no efFect on the aquatic environmer.t, it was selected as the
Le;ast Env;ronmcn�,al3y D�m�aging Practicable A;temative.
1?rcfetred AL*cmativc
'Ilie Arelerred Aiternative is the a`temative that best mce[s a project's pu�vse anJ neecl :uid
accomplishes the pmject's goals and objcctivcs. To datc, thc NPS has not deter.nir;ed a Preferred
Altcrnativc. flttcr full rcvicw of thc DEIS and carcful considc;at'.on of commcnts, a Prcfcncd
A$crnativ� w911 be idanlifieJ und made avuilable to the public in the Finul Environmental Tmpact
State�nenz.
Summarv
The DETS highlights cixo considerabtc adverse and permaacr.t damages ro fish and wildlifc
resourccs that would res��.:lt from eny of [hc build a1t�7nalivcs. Expcctcd damagcs ircludcd, but
a;e not Iimited to, stream•channel erosion; sveam and wetiand sedimentation; unstable geoJogy
and po[cntial acidifccation ofsireams; :� n;:uiy:LS 141 strc�m� crossings; hydrolog�ica! aitcration�;
loss of riparian habitat x;id sseau; buffers; 1o;s of terrestrial and rare aquxtc I�abitats; habita,
fragmantasion; invrsivc spccica ir.trodncrion; and impacts to fcdcrally lisicd cndangcrcd and
threatcncd spccics.
GiVCn Ihc m.:ynitude of lhe azpec�ed impacts �nd the sel_^ction in the DETS of ihe T4oneCary
Selll°men( Altem:�,ive as Uet6 the Enviracuncntally Preferred Alterna!ive and the L,east
20
Envixonmentally Damaging YracticaUle Altemative, the Service stron�;ly encourages tl�e IvPS to
scicet thc Monctary Scttlement as the frnal preierred alfemative.
"FhanY, you for allowing us to comment on tlus pmjecL lCyou have azry questions, piease contact
Mr. Allen Ratzlaff of our staf2'at 828/258-3939, Ext. 229. In :uiy futurc correspondcncc
conccrning this p:rojcct, plcasc rcfcrcnce our Log Nuv-�bcr 4-2-OS-297.
Sincerely,
i
��. . s�C��
Bri.m P. Cole
Field Supervisor
6nclosure
cc:
:�Ir. bavid Mclicnry, Mountain Rogion Rcvicw;.r, North Ca�olina Wildliie Resou:ces
Commission, 2G830 Crreat Cmoky Mtn Expressway, Waynesville, NC 28786
[vli. Tom W alker, Caie:, Ashcville Regulatory Ficid Officc, U.S. Aimy Carps of Engiueers,
C 51 Patton Ave;we, Room 208, Asheville, NC 28801-5006
Agency Consultation and Coordination - 5-35
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North Shore Road Final Environmental Impact Statement

5.15.2 Study Team Responses
The following are study team responses to the agency comments received on the North Shore Road DEIS.
5.15.2.1 Eastern Band of Cherokee Indians — Tribal Historic Preservation Office (EBCI-THPO) — April 7, 2006
5.15.2.1.1 EBC�THPO-1
"The Eastern Band of Cherokee Indians Tribal Historic Preservation Office is entering into the forinal
record that the archeological and cultural resources data included in the draft Environmental Impact
Statement is insufficient to make a decision regardingpotential alte�natives. This office questions if a 70
percent' survey of the project corridor can sufficiently enable the Eastern Band of Cherokee Indians
Tribal Historic Preservation O�ce to reflect upon proposed alternatives? "
Response: NPS appreciates the EBCI-THPO's concerns regarding archaeological and cultural resources,
and has fully considered those resources. NEPA, the NHPA, and NPS policies require that data collection
and analysis be reasonable and sufficient to support a decision, but do not require that all possible data be
collected. In addition, both NEPA and NHPA provide for phased approaches in identifying and evaluating
resources, effects, and impacts prior to implementation of an alternative. In particular, the NHPA regulations
(36 CFR Part 800.4[b][2] and 800.5[a][3]) provide for phased identification and evaluation of historic
properties, and allow final identification and evaluation of historic properties, as well as assessments of
adverse effects, to be deferred if provided for in a programmatic agreement.
The use of sample surveys to generate predictions on the nature, amount, and distribution of archaeological
sites for use in evaluating project feasibiliry and alternatives and to support NEPA documents is a widely
accepted procedure. A 10 percent sample of the first 5 mi (8 km) of the study corridors was chosen for
intensive archaeological survey after initial inspection of the corridor and in consultation witb other
consulting parties, including the EBCI (see Section 5, Appendix H, and Appendix P). The sample survey
area included representative samples of all major environmental zones and historic settlement areas traversed
by the study corridors. The intensive field survey covered approximately 7.8 percent (800 of ] 0,260 ac [324
of 4,152 ha]) of the study corridors, including almost 50 percent (800 of 1,610 acres [324 of 652 ha]) of the
area contained in the first 5 mi (8 km) of study corridor and representing about 6.2 percent (104 of 1,694
acres [42 of 686 ha]) of the portion of the total study corridors with less than ] 5 percent slopes.
The EBCI-THPO has previously agreed to the survey methodology utilized, as outlined in Appendix P
(EBCT-THPO, undated letter). In addition, the EBCI-THPO was invited to participate in all interagency and
Section 106 consulting parties meetings, including development of the PA, and the EBCI has signed the PA
for the project (Appendix H).
The results of this sample survey, when considered along with two measures of the likelihood of site
occurrence (the amount of high probability area for site occurrence and the number of potential historic
period sites), provide sufficient data to assess the potential impacts of each project alternative upon
archaeological sites, as well as the differences in those impacts across alternatives.
Due to the visible nature of historic structural resources and the extent of investigations in the study
corridors, sufficient work has been done to identify these resources. Notwithstanding, however, additional
Agency Consultation and Coordination — 5-37
North Shore Road Final Environmental Impact Statement

field surveys would be conducted of any potential impact area that has not been intensively surveyed if a
partial-build or build alternative were selected for implementation.
Potential project impacts to the AT and Fontana Dam as historic resources are considered in Section 4.2.8.
Additional assessment of those resources would be completed if they were to be potentially impacted by a
selected alternative.
5.15.2.1.2 EBC�THPO-2
According to the information provided, eight sites were determined eligible for inclusion on the National
Register under Criterion D. Moreover, twenty-three additional sites are `considered significant or
potentially significant resources and must be considered in the EIS process. ' However no inforination
regarding these `potentially significant' sites is included in the section entitled 4.2.8.3 Impacts to Cultural
Resources beginning on page 4-88. "
Response: Summary information on all known sites within the study corridors, including those that are
eligible, unassessed, or ineligible, is provided in Table 3-1 and included in the discussion in Section 4.2.8
when these sites are contained within the footprint and potentially impacted by a particular alternative.
5.15.2.1.3 EBCI-THPO-3
"The rich cultural and traditional a�liation with the river valleys of western North Carolina obligates the
EBCI THPO to protect our Tribal cultural resources. We would ask that the National Park Service, as the
lead federal agency, and also as stewards of this regional, state, national, and more i�nportantly Tribal
history, work in concert with the Eastern Band of Cherokee Indians to protect this rich cultural region. "
Response: NPS appreciates the EBCI-THPO's concern regarding protection of cultural resources. NPS has
consulted with the EBCI throughout the development of the EIS, as well as on other projects in the region.
NPS looks forward to continuing to work with the EBCI on this and other projects through project-specific
meetings, as well as through quarterly meetings of the Cherokee-Park Coordination Committee.
5.15.2.2 Federal Highway Administration (FHWA) - April 5, 2006
No comment response required.
5.15.2.3 North Carolina Department of Administration (NCDOA) - April 6, 2006
A cover letter from NCDOA was submitted with the comments from divisions or departments within
NCDENR. No comment response is required. Substantive comments requiring response were provided by
individual NCDENR divisions or departments.
Agency Consultation and Coordination — 5-38
North Shore Road Final Environmental Impact Statement

5.15.2.4 North Carolina Department of the Environment and Natural Resources (NCDENR),
Secretary — April 6, 2006
A cover letter was submitted from the Secretary's office with the comments from divisions or departments
within NCDENR summarizing agency concerns. No comment response is required. Substantive comments
requiring response were provided by the individual NCDENR divisions or departments.
5.15.2.5 NCDENR, Environmental Review Coordinator— March 28, 2006
A cover letter was submitted by the NCDENR Environmental Review Coordinator with the comments from
divisions or departments within NCDENR. No comment response is required. Substantive comments
requiring response were provided by individual NCDENR divisions or departments.
5.15.2.6 North Carolina Division of Environmental Health (NCDEH) — February 13, 2006
'F�i�'�.�tJIN�l�:61
As proposed this major road project will impact water quality along the shoreline and into Lake
Fontana, which is a source of drinking water supply for the Fontana Village Resort commur�ity. ...
Although the Environ�nental Assessment does address source water impacts, this assessment does not
address direct impacts to this drinking water source. Should the `Southern-Fontana Dam' optior� be
chosen, there is a chance that direct water quality impacts could occur very near this water supply intake.
... It is not apparent what direct impacts �nay occur to the Fonta�a Village Resort water source with each
option that is proposed and what actions may be taken to better protect the drinking wateN source. "
Response: Text describing this drinking water intake has been added to Section 3.4.2.1. Water quality
standards for drinking water supplies were reviewed and included as part of the impact analysis for water
qualiry as discussed in Section 4.4.3. Text has been added in this section further discussing potential impacts
to the Water Supply waters and mitigation strategies to protect the drinking water intake.
Prior to construction, if a partial-build or build alternative were selected far implementation and upon
completion of the final design, a Section 401 Water Quality Certification application would be completed
and submitted for approval. NPS would comply with the conditions and requirements associated with this
permit.
5.15.2.7 North Carolina Division of Land Resources (NCDLR) — March 2, 2006
5.15.2.7.1 NCDLR-1
"I have reviewed two portions of the DEIS, the Summary and Section 4.4.3, Water Quality. The document
does not adequately address the environmental impacts of the Build and Partial Build Alternatives.
Sedimentation pollution is the most prevalent cause of stream impairment in North Carolina. The North
Shore Road cannot be built without causing high levels of sedimentation and turbidity in trout streams. ...
Bridging the stream crossings would be necessary, with extensive provisions for sedimentation and
erosion control. The best available technology would notprevent violations of the water quality standard
. for turbidity in tr°out waters. "
Agency Consultation and Coordination — 5-39
North Shore Road Final Environmental Impact Statement

Response: Discussion of waters and aquatic resources in the study corridors and potential project-related
impacts to these resources are included in Sections 3.4.1 to 3.4.4 and 4.4.1 to 4.4.4 for Wetlands; Lakes,
Rivers, and Streams; Water Quality; and Aquatic Ecology, respectively. Each respective topic includes a
discussion of existing conditions, potential impacts, and options for avoidance, minimization, and
compensatory mitigation. Additional detail on these topics is provided in Appendix M. Sedimentation as an
impact to waters and aquatic resources is discussed within each topic. Additionally, bridging and the need
for sedimentation and erosion control are also noted for each topic.
NPS is committed to maintaining the water quality in the Park and does not intend to violate water quality
standards if a partial-build ar build alternative is implemented. In general, the mechanism for limiting
impacts is a three-step process: avoidance, minimization, and compensatory mitigation (such as wetland
restoration). Avoidance of impacts would have the highest priority. Techniques to avoid, minimize, and
compensate for impacts are provided by resource topic in their respective sections. These techniques would
be applied as appropriate during the final design, if a partial-build or build alternative were selected for
implementation. As stated in Section 4.1, "detailed mitigation plans would be developed befare
implementation of an alternative." This would include encapsulation in all appropriate locations.
Prior to construction, if a partial-build or build alternative were selected for implementation, a Section
404/401 (of the CWA) permit would need to be obtained from the USACE and NCDWQ, respectively. The
Section 401 Water Quality Certification process by the state is the mechanism by which the state assures that
a project will not violate the applicable water quality standards and that appropriate measures are in place to
avoid violations. Applications for the appropriate permits would be completed and submitted for approval, if
a partial-build or build alternative were selected for implementation, upon completion of the final design.
NPS would comply with the conditions and requirements associated with these permits.
5.15.2.7.2 NCDLR-2
"Attempts to establish ground cover on acidic soils often fail. ...No confidence should be placed in
proposals to mitigate or neutralize acidic drainage. "
Response: AP rock is known to occur in the study corridors. If a partial-build or build alternative were
implemented, excavated AP rock would be managed through encapsulation embankments, as necessary. A
detailed description regarding the construction of an encapsulation embankment is included in Appendix L.
This appendix analyzes the effectiveness of encapsulation as a strategy to handling AP rock on the Cherohala
Skyway, a comparable road project in the viciniry of the study area for the North Shore Road project.
As noted in Appendix L, soil would be utilized to cap ihe embankment. Since this soil would be similar to
the surrounding native soils, it would support a corresponding similar community of plants. Additionally,
per NPS guidelines, native seeds would be utilized in a timely manner to revegetate the site. This would aid
in preventing the establishment of non-native plants.
Appendix L states that "based upon recent water quality analyses and historic data from before, during, and
after construction, the water quality of two blue-ribbon trout streams, given the status of `high priority'
streams by the USEPA and the NCDENR, have, to date, not been adversely impacted" and that "re-
vegetation of embankments and cut slopes appears healthy and continuing in maturiry. The exception is the
trees being blighted by disease or insects."
Agency Consultation and Coordination — 5-40
North Shore Road Final Environmental Impact Statement

5.15.2.7.3 NCDLR-3
"The Draft Environmental Impact Statement has no basis for concluding that the Build or Partial Build
Alternatives would not `Impair' the Park. It is an erroneous conclusion based on inadequate research. "
Response: The EIS covers a full range of impact topics as suggested by NPS policy in DO-12 and as
outlined in CEQ's NEPA guidelines. The topics are listed in Section l.7 and they include: "community,
economic, land use, visitor use and experience, environmental justice, cultural resources, public health and
safety, geology, floodplains, air quality, soundscapes, wetlands (jurisdictional and special aquatic habitats),
streams and lakes, water quality, aquatic ecology, vegetation communities, terrestrial wildlife, black bears,
migratory birds, invasive exotics, federally protected species, and visual resources. Other topics with
discussions of effects in Chapter 4 include utilities, hazardous materials, energy, indirect and cumulative
effects, private in-holdings, and sustainabiliry and long-term management." The detailed study alternatives
have been analyzed for their potential to impact each of these resource topics, as applicable. Section 4.1.1
states the general methodology for analyzing potential impacts. It states that "DO-12 requires that an EIS
must discuss the impacts of each reasonable alternative under consideration and must quantify the impacts in
terms of iheir type, context, duration, and intensity. This section defines the type, context, duration, and
intensity for impacts based upon NPS technical guidance and internal documents. Methodologies, detailed
guidance and regulations, and tailored definitions of impact intensiry are provided for each resource, ar
group of resources, in the corresponding section in this chapter." Details on the analysis of impacts for each
resource are presented in Chapter 4 or summarized in Chapter 4 from a corresponding appendix.
As described in Section 4.1.3, NPS Management Policies define "impairment" as "an impact that, in the
professional judgment of a responsible NPS manager, would harm the integrity of park resources or values,
including the opportunities that otherwise would be present for the enjoyment of tbose resources or values"
(NPS 2006b). NPS policies require an analysis of impairment to resources as part of the environmental
impact analysis process. Impairment determinations are treated as separate findings from impact thresholds.
NPS policy guidance does not define "impairmenY' as equivalent to a"major, adverse impact."
In determining whether an impact would be likely to cause impairment, the NPS manager must consider the
extent that the impact affects a resource or value whose conservation is: necessary to fulfill specific purposes
identified in the establishing legislation or proclamation of tbe park; key to the natural or cultural integriry of
the park or to opportunities for enjoyment of the park; or identified as a specific goal in the park's general
management plan or other relevant NPS planning documents. While impairment is discussed in the EIS, it is
a separate evaluation based on these considerations and in consideration of the impacts noted in the EIS. The
impairment analysis is not a NEPA requirement, but a DO-12 requirement.
5.15.2.8 North Carolina Division of Water Quality (NCDWQ) — March 1, 2006
5.15.2.8.1 NCDWQ-1
`7n general, the Draft Environmental Impact Statement (DEIS) reports that the proposed partial build and
Northern Shore Corridor alternatives would have major adverse impacts to wetlands, streams, lakes,
water quality, aguatic ecology, and vegetation communities. ...At this time, DWQ does not feel that the
potential benefits of the Purpose and Need justify the level of adverse i�npacts to these resources. "
Agency Consultation and Coordination — 5-41
North Shore Road Final Environmental Impact Statement

Response: Comment noted.
5.15.2.8.2 NCDWQ-2
`Based on removal of access of some cemeteries, it is unclear how the Partial Build and North Shore
Road alternatives would meet the goal of protecting the tangible aspects of cultural resources. "
Response: Current assessments of project impacts on cemetery access are based on consideration of
functional roadway designs. As with other cultural resources (and other resource types), efforts would be
made to avoid, minimize, and mitigate potential adverse effects to these resources, including cemetery
access, if a partial-build or build alternative were implemented. NPS is committed to providing cemetery
access, as outlined in Appendix D of the GSMNP General Management Plan and as stated in the Summary
"[a]nnual ferry service, as it is currently provided by the NPS, would continue under alternatives that would
not include provisions for a new road, would not intersect an administrative road, or would reach only a
portion of the cemeteries." In addition, the Park staff actively works with the North Shore Cemetery
Association as well as descendants of former residents to maintain cemeteries.
5.15. 2. 8. 3 NCD WQ-3
"In section 4.2.8, the document states that adverse impacts to cemeteries would occur as a result of the
Partial build and North Shore Alternatives due to `cutting current NPS provided vehicular access. ' It is
unclear what the NPS provided vehicular access consists of. Please describe the NPS provided vehicular
access. "
Response: Current NPS-provided vehicular access to cemeteries varies based on cemetery location in
relation to administrative roads and is discussed in Attachment G-2 (to Appendix G). For many North Share
cemeteries, such as Woody, Proctor, or Bone Valley cemeteries, four-wheel drive vehicles or a small bus are
used to transport visitors from the shoreline to a parking area near the cemetery. Some cemeteries (e.g.,
Proctor) are a short walk from the parking area, while others (e.g., Hoyle) require a considerable walk. A
few other cemeteries (e.g., Mitchell) can be reached only by foot from the shoreline.
5.15.2.8.4 NCDWQ-4
`Please provide a discussion of the strategies that would be implemented to prevent water quality
impairment due to runoff from AP [acid producingJ rock. "
Response: NPS is cammitted to avoiding and/or mitigating impacts to human and natural resources to the
extent practicable, including those impacts related to AP rock. This is generally a thre�step process:
avoidance, minimization, and mitigation. Avoidance of water quality impacts would have the highest
priority. Sections A.4.1.3, 4.4.23, 4.43.3, and 4.4.�4.3 list various techniques that can be employed to
minimize impacts to waters and/or water quality. Additional detail on these techniques is included in
Appendix M. Encapsulation would be employed in all appropriate locations for embankments with rock and
soil with the potential to produce acidic runoff as discussed in Section 4.3.1.4 and Appendix I. Details about
encapsulation are included in Appendix L and discussed below. Measures to reduce the impacts from
exposed AP rock faces would be evaluated and employed where appropriate. These measures are discussed
below, and text has been added in Appendix I and Section 4.3.1.4.
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North Shore Road Final Environmental Impact Statement

The encapsulation method proposed for the partial-build and build alternatives is based on FHWA guidelines
and was effectively used in the Cherohala Skyway project (see Appendix L). The focus of encapsulation is
to control exposure of AP rock to the environment in order to prevent acid drainage. This encapsulation
method is not intended to totally offset the acidiry of the encapsulated rock by adding a neutralizing base, but
is designed to control water flow around the encapsulated rock, control the influx of oxygen, control
acidophyllic bacteria, and enhance alkalinity. The limestone aggregate layered between filter fabrics at the
base of the encapsulation (limestone filter) is designed primarily to divert runoff below the encapsulated
material rather than through it. This limestone filter also serves as an extra layer of limestone for
neutralization in the event that water does percolate through the encapsulated embankment. The agricultural
lime added in layers within the encapsulation serves to raise the pH in the system which reduces the
solubility of heavy metals, allowing them to remain within the encapsulation. These metals then act to coat
sulfide minerals such as pyrite, shielding against further oxidation and reducing permeabiliry of the pyrite,
thus retarding the influx of water and oxygen. The elevated pH also reduces the catalytic action of bacteria
(such as Thiobacillus ferrooxidans).
While excavated material can be encapsulated to abate acid drainage, no treatment has yet been discovered
for effectively abating the oxidation process on the rock cut slopes bearing significant amounts of sulfide
minerals. Any strategy that can enhance the alkaliniry of runoff or divert water from the cut slope can reduce
the risk of generating acid drainage. At present the BMP for dealing with the rock exposed on cut slopes
involves diverting the runoff above the cut around the excavation and constructing a slope as near vertical as
the rock structure will allow. The diversion of drainage will reduce the amount of percolation into and
through the rock, thus reducing the transport of acidiry and potentially toxic metals. Steepening of slope
angles reduces the surface area exposed to precipitation. Further measures include using a source of
alkaliniry in the drainage system. Strategies used on the Cherohala Skyway to minimize acid drainage from
cut slopes and additional measures that could be applied to cut slopes to minimize acid production further
include: excavating slopes as steep as the structural conditions would allow to reduce the exposed area and
the amount of runoff; diverting runoff around the cut face using limestone rip rap or concrete-lined ditches to
retard acid production within the rock; and seeding flatter slopes with native grasses as soon after exposure
as possible. An additional measure for consideration in mitigating acid drainage from cut slopes in AP rocks
is diversion of runoff from the cut face area into open limestone channels. This strategy has been used
successfully in the treatment of acid mine drainage in coal strip mine reclamation (Ziemkiewicz et al. 1997).
The alkaliniry of the limestone reduces acidiry, causing precipitation of inetals, but the turbulence of the flow
prevents the reactive surface of the ]imestone rip rap from being coated with secondary iron minerals.
Another treatment that can be effective, but costly, is the formation of a grout curtain above the cut slope to
prevent groundwater from percolating through the bedrock and flushing acid and metals into the slope
drainage.
5.15.2.8.5 NCDWQ-5
`7n section 4.3.1.2, the DEIS states that up to 2.9 million cubic yards of excavated material would be
produced by the Northern Shore Corridor alternative. This is a significant amount of excavated material.
Due to the geological setting, there is the potential for much of this material to be unsuitable for. fill
material in the constr�uction of embankments associated with the road. This is especially ti^ue for areas of
AP rock. The DEIS does not discuss a disposal plan for this material. Please describe how and where this
material will be disposed of and what the �costJ estimates of the disposal would be. This description
should include best management practices for tr�eatment and their associated costs. "
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North Shore Road Final Environmental Impact Statement

Response: Embankment fills and excavation volumes are based on calculations using the proposed road
design and assuming that all of the excavated material is AP. The present design assumes using as much of
the excavated material as possible within on-site encapsulating embankments. However, present calculations
indicate a surplus of excavated material over that which can be used in embankments for the Partial-Build
Alternative to Bushnell and the Northern Shore Corridor necessitating location of other sites for wasting or
burial (depending on the quality of the material). The Laurel Branch Picnic Area altemative is not projected
to generate a surplus volume. Surplus volumes are projected to range from 282,300 yd3 (215,900 m3) for the
Partial-Build Alternative to Bushnell (Principal Park Road) to 414,800 yd3 (317,100 m3) for the Northern
Shore Corridor (Primitive Park Road). Text has been added to Section 4.3.1.2 noting these surplus volumes.
During the final design phase, road alignments and slope configurations may be modified to lessen the
impacts associated with the AP rocks as well as to balance the volumes of cut and fill material. While the
surplus volumes may be minimized, as discussed in Section 4.2.12.5, it is likely that encapsulation sites
would be needed north of Bryson City (for the Partial-Build Alternative to Bushnell and the Northern Shore
Corridor) and possibly an additional site on the western end of the project (far the Northern Shore Corridor)
to reduce construction traffic impacts and costs based on the anticipated amount of excess rock to be hauled
off. Should the material designated for offsite disposal be identified as AP, the material would be placed
using a design similar to the encapsulating embanlanent on the roadway discussed in the response to
NCDWQ-4. Such sites would be located outside of GSMNP. Costs for the off-site encapsulation cannot be
meaningfully estimated at this stage of design and are not separately identified in the capital or operations
and maintenance cost estimates for the project. However, the capital cost estimates for the partial-build and
build alternatives include an allowance for engineering and contingencies that has been established at a level
that reflects the unique requirements of the study area, as well as project unknowns or uncertainties.
According to FHWA guidance on estimating costs for major projects "Costs to mitigate impacts to natural
resources, cultural resources, neighborhoods, etc., must either be individually estimated or included in a
contingency amount" (FHWA 2004b).
5.15.2.8. 6 NCD WQ-6
`Do the construction costs for the proposed alternatives include the limestone hauling costs? "
Response: Transportation to tbe study area is included in the unit costs for limestone. These and other
individual cost items are identified in the detailed cost estimates developed far the partial-build and build
alternatives provided to the public on the project website (ARCADIS 2005a).
5.15.2.8J NCDWQ-7
"In addition, the cost analysis in Appendix E, only discusses the tr°eatment of embankment material.for AP
rock. All excavated and exposed AP rock would require treatment not just material used for embankment.
The cost analysis should reflect additional costs of treating runofffrom this material. "
Response: As discussed in NCDWQ-5, surplus volumes would be refined during the final design phase.
The location, design, and final cost of encapsulation sites are usually addressed by the contractor. Location-
specific detenninations on reducing impacts associated with exposed cut faces would be based on
geotechnical drilling to evaluate detailed geologic and related engineering information. T'herefore not only
the costs far the off-site encapsulation, but also the costs for the treatment of exposed cut faces with the
Agency Consultation and Coordination — 5-44
North Shore Road Final Environmental Impact Statement

potential to produce acidic runoff, cannot be meaningfully quantified at this stage of design. As discussed in
NCDWQ-5 these costs are reflected in the allowance for engineering and contingencies far the project.
5.15.2.8.8 NCDWQ-8
`DWQ feels that the impact thresholds should be adjusted to reflect the rarity and the �elative significance
of wetlands in this area. DWQ feels that any impact to wetlands less than 0.1 acres is at least a moderate
impact, especially considering the rare plant and animal communities that occur in these wetlands. "
Response: Comment noted. As discussed in Section 4.4.1, the intensity thresholds for wetland impacts were
"based on the current USACE agency requirements associated with permitting for linear transportation
projects (Nationwide Permit 14)." The thresholds were adjusted to account for the rarity of some wetland
cotnmunities. Those wetland types that are Globally Ranked as G1 or G2, considered rare, have been
analyzed under a lower threshold of impact than those communities not ranked as rare. This lower tbreshold
category currently covers over 80 percent of the wetlands identified in the study corridors. Impacts to
vegetation communities, including rare communities, and protected species, both animals and plants, are
accounted for under intensity thresholds far those topics as discussed in Sections 4.4.5 and 4.4.10.
5.15.2.8.9 NCDWQ-9
"In Appendix M the DEIS presents the individual stream impacts for each alternative. It is unclear
whether these impacts are direct, indirect, or the combined direct and indirect impacts for each stream.
Please provide the iinpacts associated with each stream for each alternative broken down into direct and
indirect impacts. In addition, please provide corresponding fzgures and maps that show the location of
each impact. "
Response: Attachment M-6 of Appendix M identifies the direct stream impacts for each alternative and its
options. As noted in Attachment M-6, these are approximate impacts based on functional designs prior to
delineations and the inclusions of mitigation strategies. Indirect impacts to streams have been identified in
Section 4.4.2 as "impacts [that] occur when a road parallels a stream, especially within 50 ft(15 m)." The
indirect impacts have been identified as part of the impact discussions in Section 4.4.2 as occurring along a
stream reach, but have not been calculated as a length or area and are not included in the table (Attachment
M-6).
Figure 2 of Appendix M is a map of the study corridors that identifies each stream by number and includes
an overlay of both the Primitive Park Road construction footprint and the Principal Park Road construction
footprint to show the location of each impact.
5.15.2.8.10 NCDWQ-10
"In Section 4.4.3.2, the document states that for the build alternatives, Water Quality Standard violations
may occur or are likely to occur. A North Carolina 401 Water Quality Certification can only be issued for a
project that provides adequate assurances that Water Quality Standards and discharge guidelines will not be
violated. Based on information provided in the DEIS, DWQ may not be able to issue a 401 Water Quality
Ce�tification for the build alternatives associated with this project. "
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North Shore Road Final Environmental Impact Statement

Response: Comment noted. See the discussion regarding assumptions for water quality impacts in the
response to NCDWQ-12.
5.15.2.8.11 NCDWQ-11
"It is unclear whether the use of the words `impairment' or `impaired waters' in the document
corresponds with the meaning of the words in the Clean Water Act. Please provide a defznition and more
in-depth discussion of `impairment' in the DEIS. "
Response: Section 4. ].3 discusses impairment as it relates to Park resources, both human and natural
environments, and NPS policies on what might constitute impairment of those resources from an NPS
perspective. Per NPS policy, NEPA documents should include an impairment evaluation of impacts to park
resources. This evaluation relative to water quality is included in Section 4.4.3.4. The discussion in this
section is not related to the CWA and its Section 303(d) list of Impaired Waters. The text in Section 4.4.3.4
has been revised to reflect that the use of the word impairment is focused on NPS use regarding Park
resources. Additionally, the word "impairment" in Section 4.4.3.3 has been replaced with "degradation."
5.15.2.8.12 NCDWQ-12
`DWQ disagrees with the conclusion that Iinpairment of water guality is unlikely based on current
information. At severalpoints in section 4.4.3, the Draft EIS states water quality standards violations aNe
likely to occur if any build scenario is selected. If these violations occur as expected, water quality
impairment is a likely outcome. "
Response: Please refer to the discussion of impairment as defined by NPS in the responses to NCDWQ-11
and NCDWQ-13.
The assessment of applicable intensity threshold for water quality was made assuming no mitigation,
including no encapsulation of AP rock. Text has been added to Section 4.4.3 stating this assumption. This
worst-case assumption has been used since details regarding the final design of the partial-build and build
alternatives and the precise associated scope of needed encapsulation are unknown. However, encapsulation
of AP rock would be employed, at all appropriate locations, if a partial-build ar build alternative is
constructed.
NPS is committed to maintaining the water quality in the Park and does not intend to violate water quality
standards if a partial-build or build alternative is implemented. As stated in Section 4.1, "detailed mitigation
plans would be developed before implementation of an alternative." This would include encapsulation in all
appropriate locations. Sections 4.4.13, 4.4.2.3, 4.4.33, and 4.4.4.3 list various techniques that can be
employed to minimize impacts to waters and/ar water quality. Additional detail is included in Appendix M.
Prior to construction, if a partial-build or build alternative were selected for implementation, a Section
404/401 (of tbe CWA) permit would need to be obtained from NCDWQ and the USACE. The Section 401
Water Qualiry Certification process is the method by which NCDWQ assures that a project will not violate
the applicable water quality standards and that appropriate measures are in place to avoid violations.
Applications for the appropriate permits would be completed and submitted for approval upon completion of
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North Shore Road Final Environmental Impact Statement

the final design, if a partial-build or build alternative were selected for implementation. NPS would comply
with the conditions and requirements associated with these permits.
5.15.2.8.13 NCDWQ-13
`7t is worth r�oting that the Northern Shore Corridor alternative could potentially impact over 4 miles of
streams in the project aNea much of which includes the Great Smoky Mountains National Park and a
nominated Outstanding Resource Water (ORW) watershed. It is our understanding that impacts of this
�nagnitude would not be in accordance with the National Park Service Organic Act as stated in section
3.2. 5.1. "
Response: Cominent noted.
As noted in Section 3.2.5.1, "The NPS Organic Act of August 25, 19l 6, states that the fundamental purpose
of national parks is `to conserve the scenery and the natural and historic objects and the wild life therein and
to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired
for the enjoyment of future generations.' ." As described in Section 4.1.3, NPS Management Policies define
"impairment" as "an impact that, in the professional judgment of a responsible NPS manager, would harm
the integrity of park resources or values, including the opportunities that otherwise would be present for the
enjoyment of those resources or values" (NPS 2006b). NPS policies require an analysis of impairment to
resources as part of the environmental impact analysis process. Impairment determinations are treated as
separate findings from impact thresholds. NPS policy guidance does not define "impairment" as equivalent
to a "major," adverse impact.
In determining whether an impact would be likely to cause impairment, the NPS manager must consider the
extent that the impact affects a resource or value whose conservation is: necessary to fulfill specific purposes
identified in the establishing legislation or proclamation of the park; key to the natural or cultural integrity of
the park or to opportunities for enjoyment of the park; or identified as a specific goal in the park's general
management plan or other relevant NPS planning documents. The impairment analysis is not a NEPA
requirement, but a DO-12 requirement. While impairment is discussed in the EIS, it is a separate evaluation
based on the above considerations and in consideration of tbe impacts noted in the EIS.
5.15.2.8.14 NCDWQ-14
"The presence of such rare and diverse benthic commur�ities demonstf^ates the pristine habitat and water
quality provided by st�^eams along the north shore of Fontana Lake. DWQ is particularly concerned about
the potential loss of these unique communities if any of the Northern Shore Corridor build alternatives are
pursued. "
Response: Comment noted.
5.15.2.8.15 NCDWQ-15
"The streams along the northern shore of Fontana Lake have been nominated for ORW designation. The
NC Environmental Management Com�nission —Water Quality Committee has approved staff to distribute
draft rules.for public comment. These rules include special restrictions on construction activity within the
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North Shore Road Final Environmental Impact Statement

affected area. These restrictions may add additional cost to construction projects. It is unclear whether
these additional costs have been included in the cost analysis for the proposedproject. Please include the
estimated costs of ineeting these additional restrictions in the cost analysis for the build alternatives. "
Response: Effective January 1, 2007, NCDWQ, under arder of the North Carolina Legislature and with
concurrence from the Environmental Management Commission, amended 15A NCAC 02B.0225 to establish
the Fontana Lake North Shore ORW Area. The Fontana Lake North Shore ORW Area consists of the entire
watersheds of all creeks that drain to the north shore of Fontana Lake between Eagle and Forney creeks
(inclusive). All of these streams are located within the project study corridors (Figure 3-5). Text has been
updated in Section 3.4.3.1 to discuss the final ORW designation. If a partial-build or build alternative were
selected for implementation, NPS, through the permitting processes, would comply with the requirements of
l SA NCAC 02B.0225, depending on applicability at the time of permit submittal.
Current design costs reflect stringent water quality requirements, reflecting NPS's commitment to achieve
maximum protection of its water resources. Specific measures to address the ORW rules for the designated
Fontana Lake North Shore ORW Area would be developed as designs and detailed mitigation plans are
developed if a partial-build or build alternative were selected for implementation; therefore, specific costs for
implementing the draft rules are not included in the capital cost estimates. As discussed in NCDWQ-7,
mitigation costs that cannot be individually estimated should be included in a contingency amount. One of
the major cost elements for contingencies listed in FHWA guidance on estimating costs for major projects is
"other contingencies for areas that may show a high potential for risk and change, i.e., environmental
mitigation, right-of-way, utilities, highly specialized designs, etc." (FHWA 2004b). The capital cost
estimates for the partial-build and build alternatives include an allowance for engineering and contingencies
that has been established at a level that reflects the unique requirements of the study area, as well as project
unknowns or uncertainties.
5.15.2.8.16 NCDWQ-16
"In the event that a construction alternative is selected, substantial mitigation will likely be required. It is
unclear whether suffzcient mitigation sites are avar�lable within the 8-digit hydrologic unit code (HUC)
and/or eco-region. Little or no mitigation is available on-site, as the project lies within a Biosphere
Preserve, and most similar watersheds outside the park bo�undaries fall within National Forests. Please
provide a discussion ofpotential mitigation strategies for this project. "
Response: NPS is committed to limiting impacts to human and natural resources. In general, the
mechanism for limiting impacts is a three-step process: avoidance, minimization, and mitigation.
Avoidance of impacts would have the highest prioriry. Techniques to avoid, minimize, and mitigate for
impacts are provided by resource topic in their respective sections. These techniques would be applied as
appropriate during the final design, if a partial-build or build alternative were selected for implementation.
As stated in Section 4.1, "detailed mitigation plans would be developed before implementation of an
alternative."
For wetlands and other waters, as discussed in Sections 4.4.1.3 and 4.�.23, NPS intends to locate mitigation
sites within GSMNP. For potential wetland or stream mitigation, the following order of preference would be
used: (1) within the same immediate system as the impact, (2) within the same watershed, or (3) in another
watershed within the Park (NPS 1998b). The HCTC unit (06010202) containing the study area extends
Agency Consultation and Coordination — 5-48
North Shore Road Final Environmental Impact Statement

southward into northern Georgia. Given the large area included in this hydrological unit, it seems likely that
suitable sites for mitigation that could not be completed within the Park could be found within this unit, if a
partial-build ar build alternative were selected far implementation.
5.15.2.8.17 NCDWQ-17
"An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The
type and detail of analysis should conform to the NC Division of Water Quality Policy on the assessment
of secondary and cumulative impacts dated April 10, 2004. "
Response: A cumulative and secondary impacts analysis that conforms to NCDWQ's April 2004 guidelines
would be included as a part of the 401 Water Quality Certification application package, as appropriate, if a
partial-build or build alternative were selected for implementation (or other applicable cumulative and
secondary impact guideline in effect at the time of application).
5.15.2.9 North Carolina Natural Heritage Program (NCNHP) — March 3, 2006
5.15. 2. 9.1 NCNHP-1
"The Natural Heritage Program has a few records of rare species from the project area, and essentially
the entire North Carolina portion of Great Smoky Mountains National Park is a Registered NatuNal
Heritage Area. "
Response: Text has been added in Section 3.2.2.1 noting that the North Carolina portion of GSMNP is a
Registered Natural Heritage Area.
5.15.2.10 North Carolina Wildlife Resources Commission (WRC) — February 20, 2006
5.15.2.10.1 NCWRC-1
"Acute and chronic erosion and sedimentation at stream crossings in conjunction with losses,
fragmentation, and degradation of productive streams, riparian areas, wetlands, and rare terrestrial
communities fi^oin construction, hydrologic alterations, invasive species introductions, and other factors
are of sufficient magnitude to warrant elimination of build alternatives on an environmental basis. "
Response: Comment noted.
5.15.2.11 Tennessee Valley Authority (TVA) — March 10, 2006
No comment response required.
5.15.2.12 Tennessee Valley Authority (NA) — April 13, 2006
5.15.2.12.1 TVA-1
`Please include a Cover Sheet (40 CFR 1502.11). "
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North Shore Road Final Environmental Impact Statement

Response: A cover sheet has been included with the FEIS.
5.15.2.12.2 TVA-2
"Section S-S, Environ�nental Consequences and S-6, Impairment Evaluation. The document could provide
greater clarity on whether additional tiered NEPA analysis is anticipated, if a build or partial-build
alternative is implemented. For example, would this take the form of a specific document on a specific
segment, or a document on mitigation alternatives? Also, if tiered NEPA analysis is anticipated, the
subsequent analysis might be a more appropriate place to determine the Least Environmentally Damaging
Practicable Alternative (LEDPA, Section S-8 and Section 2.8). "
Response: Tl�e EIS provides sufficient information to review the potential impacts of the detailed study
alternatives and support decision-making regarding ihose alternatives. The EIS covers a full range of impact
topics developed in an iterative public and agency scoping process following CEQ's NEPA guidelines. T'he
impact analysis methodologies are tailared for each resource and follow appropriate CEQ and NPS
guidelines and regulations. Details on the analysis of impacts for each resource are presented in Chapter 4 or
summarized in Chapter 4 from a corresponding appendix. The impact threshold determinations presented in
Chapter 4 have been made on a warst-case/maximum impact basis (e.g., maximum acreages affected,
assumption that 100 percent of disturbed rock and soil would have the potential to produce acid).
Notwithstanding, if a partial-build or build alternative were selected for implementation, final design would
include further avoidance and minimization measures and could include shifis in alignment. While analysis
is not likely to reveal an increased level of magnitude of impacts, final design and detailed mitigation could
reveal sit�specific impacts that are not currently known. Additional NEPA analysis would be required if
impacts were found to be greater than i��npacts identified in this EIS for any of the partial-build or build
alternatives.
Per USACE (March 27, 2006) comments and recommendations received upon their review of the DEIS
regarding the determination of the LEDPA, the Monetary Settlement Altemative is no longer designated as
the LEDPA in Section 2.8.
5.15.2.12.3 TVA-3
"Section 1.3, Cooperating Agencies, , first sentence. Reword as follows: `When more than one federal
agency is involved in approving a proposed project, NEPA regulations encourage the agencies to work
together to produce only one NEPA document. "'
Response: This text has been revised in Section 1.3.
5.15.2.12.4 TVA-4
"Section 2.11, Comparison of Alternatives, second paragraph. Reword as follows: `NEPA requires that
all federal agencies consider avoidance and rninimization measures when adverse effects on the
enviv�onment are identified. Mitigation and enhancement measures are also to be considered for
implementation to address potential impacts. "'
Response: This text has been revised in Section 2.11.
Agency Consultation and Coordination — 5-50
North Shore Road Final Environmental Impact Statement

5.15.2.12.5 TVA-5
"Section 3.4.2.3, Regulatory Requirements, fourth paragraph. Add to end of paragraph: `In addition,
bridges or stream relocations o� other obstructions on Tennessee River tr°ibutary streams would also
require Section 26a approval. "'
Response: This text has been added in the specified location in Section 3.4.23.
���F����Q�
"Sections S(Agency Consultation and Coordination) and 6(Public Involveme�t). A list of agencies,
organizations, and persons to whom copies of the statement are sent (40 CFR 1502.10) should be
developed. This could be done in the context of the format provided here. "
Response: The distribution list of agencies, organizations, and individuals who received copies of the EIS is
provided in Section 5.18 (previously Section 5.15). The initial list of agencies, organizations, and individuals
who will receive copies of the FEIS is provided in Section 5.19.
5.15.2.12.7 TVA-7
"Appendix Q, G�eat Smoky Mountains National Park Enabling Legislation. A large amount of text was
inadvertently inserted in this appendix, following Section 4. The text discusses pyritic rock and bridges,
which would not have been in the enabling legislation of May 22, 1926. "
Response: Extraneous text was included in Appendix Q on pages Q-2 and Q-3. This text has been deleted.
5.15.2.13 US Army Corps of Engineers (USACE) — March 27, 2006
5.15.2.13.1 USACE-1
"The Monetary Settlement Alternative appears to be the only of the studied alternatives that does not
involve iinpacts to waters of the IIS and thus does not require a Department of the Army (DA) permit.
Further, there are no other adverse environmental impacts identified for the Monetary Settlement
Alternative. We therefore concur, based on the information available at this time, that the Monetary
Settlement Alternative appea�s to be the least environmentally damaging alternative. We do not agree that
the issue of practicability has been adequately addressed nor that application of the 404(b)(1) guidelines
is appropriate here. We suggest that the Monetary Settlement Alternative be identified as the
`environmentally preferred' alternative and that reference to the 404(b)(1) guidelines be removed. "
Response: Comment noted. The text in Section 2.8 has been modified such that the Monetary Settlement
Alternative is no longer designated as the LEDPA and text discussing the 404(b)(1) guidelines has been
revised.
5.15.2.13.2 USACE-2
"The NPS should include all appropriate available information regarding Swain County's use offunds. "
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North Shore Road Final Environmental Impact Statement

Response: As noted in Section 2.2.2, the Monetary Settlement Alternative reflects the resolution passed by
Swain County on February 11, 2003, stating that the County would accept a monetary settlement of $52
million to settle the 1943 Agreement. Plans for the use of funds were not included in the County's
resolution, and no plans have been provided to the NEPA study team by the Counry. Currently it is assumed
that the Monetary Settlement Alternative would provide direct compensation to Swain County and that the
use of the settlement proceeds would be at the discretion of Swain County. Therefore, a range of potential
uses could exist. Public comments during the EIS process bave revealed divergent public sentiment
regarding how the funds should be used and potential benefits of such uses.
5.15.2.13.3 USACE-3
"The document states that wetlands will be further investigated to determine the exact impacts along any
corridor associated with a permit application. There may also be a permit condition that requires the
wetland boundaries be surveyed along any proposed corridor to facilitate compliance inspections. "
Response: NPS would comply with all permit conditions and requirements if a partial-build or build
alternative were selected for implementation.
5.15.2.13.4 USACE-4
"The LISACE is responsible for administering Section 404 of the Clean Water Act. This should be made
nzore clear in the second pa�agraph on page 3-39. "
Response: Text has been modified in Section 3.4.1.2 to reflect this concern.
5.15.2.13.5 USACE-5
"If a permit is required/issued, mitigation may be required for all impacts to streams and wetlands. A
final determination of mitigation requirements would be made as part of any permit evaluation. "
Response: Comment noted. NPS would comply with all permit conditions and requirements if a partial-
build or build alternative were selected for implementation.
5.15.2.13.6 USACE-6
"The use of bridges and/or bottomless culverts may reduce impacts and eliminate or reduce permit
requirements. If impacts could be reduced su�ciently, a Nationwide Permit may be available that would
reduce the time and cooNdination necessary for authorization. "
Response: Comment noted.
5.15.2.13.7 USACE-7
"If a permit is required/issued and mitigation is required, the iISACE ag�ees that restoration or
enhancement would be preferable to creation. Compensatory mitigation ratios may be increased if the
proposed mitigation is not within the saine watershed as the proposed impacts (off-site). "
Agency Consultation and Coordination — 5-52
North Shore Road Final Environmental Impact Statement

Response: Comment noted.
5.15.2.13.8 USACE-8
"Sections 4.4.1.4 and 4.4.2.4 state that there is no anticipated impairment of wetlands or streams
associated with the partial build alternatives. Impacts are possible with these alternatives as described in
Table 4-17a. Please clarify why there would be no impairment. "
Response: As discussed in the response to NCDWQ-11, text has been modified in various sections to
describe the difference between "impaired" waters as provided for by the Section 303(d) of the CWA and
"impairment" as provided for under NPS guidelines.
As noted in Section 3.2.5.1, "The NPS Organic Act of August 25, 1916, states that the fundamental purpose
of national parks is `to conserve the scenery and the natural and historic objects and the wild ]ife therein and
to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired
for the enjoyment of future generations'." As described in Section 4.l .3, NPS Management Policies define
"impairment" as "an impact that, in the professional judgment of a responsible NPS manager, would harm
the integrity of park resources or values, including the opportunities that otherwise would be present for the
enjoyment of those resources ar values" (NPS 2006b). NPS policies require an analysis of impairment to
resources as part of the environmental impact analysis process. Impairment determinations are treated as
separate findings from impact thresholds. NPS policy guidance does not define "impairment" as equivalent
to a "major, adverse impact."
In determining whether an impact would be likely to cause impairment, the NPS manager must consider the
extent that the impact affects a resource or value whose conservation is: necessary to fulfill specific purposes
identified in the establishing legislation ar proclamation of the park; key to the natural or cultural integrity of
the park or to opportunities for enjoyment of the park; or identified as a specific goal in the park's general
management plan or other relevant NPS planning documents. While impairment is discussed in the EIS, it is
a separate evaluation based on these considerations and in consideration of the impacts noted in the EIS. The
impairment analysis is not a NEPA requirement, but a DO-12 requirement.
5.15.2.13.9 USACE-9
"There should be no temporary stockpiling of materials in wetlands or streams. "
Response: Text has been modified in Section 2.3.2 of Appendix M discussing BMPs to reflect this concern
and prohibit the storage of equipment and stockpiling of materials in wetlands and streams.
5.152.13.10 USACE-10
Appendix M states that no distinction was made between perennial and intermittent steam segments.
Further fzeld work may be required to distinguish perennial and intermittent segments for determining
mitigation needs. "
Response: Comment noted. Additional field work would be conducted, as appropriate, to detennine
mitigation needs for permitting, if a partial-build or build alternative were selected far implementation.
Agency Consultation and Coordination — 5-53
North Shore Road Final Environmental Impact Statement

5.15.2.14 United States Environmental Protection Agency (USEPA) — March 27, 2006
5.15.2.14.1 USEPA-1
"The DEIS identifzes the singular purpose for this transportation project as providing improved access to
cemeteries. "
Response: The purpose of the project is not to improve cemetery access. As stated in Section 1. l, the
purpose of the proposed action "is to discharge and satisfy any obligations on the part of the United States
that presently exist as the result of the July 30, 1943, Memarandum of Agreement (1943 Agreement) among
the United States Department of Interior (DOI), Tennessee Valley Authoriry (TVA), Swain County, North
Carolina, and the state of North Carolina." The 1943 Agreement contained a provision by which the DOI
was to construct a road through GSMNP, along the north shore of the newly formed Fontana Lake (generally
located between Fontana Dam and Bryson City, North Carolina), to replace the flooded NC 288.
Additionally, Section 1.1 states that "the need of the project is to determine whether or not it is feasible to
complete the road and to evaluate other alternatives that would satisfy the obligation."
5.15.2.14.2 USEPA-2
"The entire northern shore area is within the existing wilderness desz�gnation or the potential additional
wilderness area that extends southward to the north shore of Fontana Lake. A roadway thNOUgh the area
would not allow the wilderness designation to re�nain when the crite�ia set by the NPS are applied. "
Response: Comment noted.
5.15.2.14.3 USEPA-3
"EPA concurs that the Monetary Settlement Alternative is the least environinentally damaging, and we
str^ongly support this alternative. "
Response: Comment noted.
5.15.2.14.4 USEPA-4
"The Laurel Branch Picnic Area alternative would result in impacts varying from minor to severe, and
therefo�e we have some environmental concerns. ... Further information should be provided about
measures to avoid and mitigate environmental impacts if this alternative is pursued. "
Response: NPS is committed to limiting impacts to human and natural resources. In general, the
mechanism for limiting impacts is a three-step process: avoidance, minimization, and mitigation.
Avoidance of impacts would have the highest priority. Techniques to avoid, minimize, and mitigate for
impacts are provided by resource topic in their respective sections. These techniques would be applied as
appropriate during the final design, if a partial-build or build alternative were selected for implementation.
As stated in Section 4.1 "detailed mitigation plans would be developed before implementation of an
alternative."
Agency Consultation and Coordination — 5-54
North Shore Road Final Environmental Impact Statement

5.15.2.14.5 USEPA-5
"Based on the data in the DEIS, EPA has serious concerns regarding water quality impacts of the full-
build and partial build alternatives. The rnost pronounced adverse impacts would be to water qualiry
resulting from construction, given the probability of encountering acidic rock with high metals. "
Response: Comment noted.
F�i��[�:�II►Y�J�.�
`Due to the potentially severe iinpacts to the environment, we agree with the NPS that selection of either
the North Shore Road or the partial-build road to Bushnell would require supplen�ental site specific NEPA
analysis to determine whether any of these alternatives would be environmentally acceptable. The current
DEIS does not address these alternatives in su�cient detail to support their selection. "
"We note that due to the magnitude of the Northern Shore Corridor (baseline, full-build alternative), the
DEIS acknowledges that it is likely that additional NEPA documentation would be required to address site
specific impacts if that alternative is selected. "
Response: The EIS provides sufficient information to review the potential impacts of ihe detailed study
alternatives and support decision-making regarding those alternatives. The EIS covers a full range of impact
topics developed in an iterative public and agency scoping process following CEQ's NEPA guidelines. The
impact analysis methodologies are tailored for each resource and follow appropriate CEQ and NPS
guidelines and regulations. Details on the analysis of impacts for each resource are presented in Chapter 4 or
summarized in Chapter 4 from a corresponding appendix. The impact threshold determinations presented in
Chapter 4 have been made on a warst-case/maximum impact basis (e.g., maximum acreages affected,
assumption that 100 percent of disturbed rock and soil would have the potential to produce acid).
Notwithstanding, if a partial-build or build alternative were selected for implementation, final design would
include further avoidance and minimization measures and could include shifts in alignment. While analysis
is not likely to reveal an increased leve] of magnitude of impacts, final design and detailed mitigation could
reveal sit�specific impacts that are not currently known. Additional NEPA analysis would be required if
impacts were found to be greater than impacts identified in this EIS for any of the partial-build or build
alternatives.
5.15.2.14.7 USEPA-7
"The Northern Shore Corridor Alternative would increase the annual visitors to an estimated 463, 600
(Table 4-8) which appears to be in conflict with maintaining wilderness status. This should be an
important factor in decisions regarding the proposed action. "
Response: Comment noted.
5.15.2.14.8 USEPA-8
"The DEIS does not remark on tr°ansportation deficiencies, except fo� stating a need to improve access to
old cemeteries. ... There is no documentation of how many trips would be taken specifically for visiting
Agency Consultation and Coordination — 5-55
North Shore Road Final Environmental Impact Statement

the ceineteries, but rather the estimated Average Annual Daily Ti^a�c (AADT, 64-475) for the various
alternatives considered in detail are mostly generated by recreational travelers. None of these t�^affzc
estimates comes anywhere close to justifying the project for general mobility. "
Response: As presented in Section 1.1, "The purpose of the proposed action is to discharge and satisfy any
obligations on the part of the United States that presently exist as the result of the July 30, 1943,
Memorandum of Agreement (1943 Agreement). ... The 1943 Agreement contained a provision by which
the DOI was to construct a road through GSMNP, along the north shore of the newly formed Fontana Lake
(generally located between Fontana Dam and Bryson City, North Carolina), to replace the flooded NC 288."
The need for the project therefore "is to determine whether or not it is feasible to complete the road and to
evaluate other alternatives that would satisfy the obligation."
While mobility and access are addressed as impacts to the study area and surrounding region in Section
4.2.1.2.7, access to old cemeteries, general mobility, and transportation deficiencies are not incorporated in
the Purpose and Need (Section 1.1) or the Project Goals and Objectives (Section ].2) for the North Shore
Road project. Traffic estimates have been evaluated for consideration in analyzing impacts including
mobiliry and access, air quality, noise, economics, land use, and natural resources.
The concern that traffic estimates do not justify the project for general mobility is noted.
�iF'�.�i[l���l►Y�J�'7
"The projected 1 S year construction period for the Northern Shore Corridor presents a substantial
adverse noise and visual impact to any recreational pursuit within the GSMNP. This should be
considered a chronic impact because of the duration. "
Response: As stated in Section 4.3.5.2, "Major soundscape impacts, specifically for the Northern Shore
Corridor, would not be expected to occur along the entire length of the project concurrently." As
construction progressed along the Northern Shore Corridar, so too would the location of these noise impacts.
Therefore, these were determined to be short-term impacts.
If a partial-build or build alternative were implemented, major, adverse impacts would occur to viewpoints or
areas from which the equipment, excavation, and road work activities for the section under construction were
visible. In addition, a plume from construction would be visible from various distances at certain times of
day. Construction plume visibility impacts have been analyzed for the Northern Shore Corridor and the
Partial-Build Altemative to Bushnell, as discussed in detail in Section 4.3.4.2. Text describing impacts to
views during construction has been added to Section 4.5.2. Major visibility impacts during construction,
including those for the Northem Shore Corridor, would not occur along the entire length of the project
concurrently. As construction progressed for the Northem Shore Corridor, so too would the location of the
visibiliry impacts. Therefore, these impacts were determined to be short-term impacts.
5.15.2.14.10 USEPA-10
"However, the DEIS also notes that even relatively s�nall increases in e�nissions and changes ir� air
quality could be important influe�ces in meeting CAA [Clean Air ActJ requirements. If one of the build
Agency Consultation and Coordination — 5-56
North Shore Road Final Environmental Impact Statement

alternatives is selected, the Final EIS should include further information regarding the monitoring of
impacts and result on air quality compliance status associated with that alternative. "
Response: NCDAQ and NPS maintain a network of ambient air monitoring units strategically located in and
around GSMNP that continuously measure air pollutants and other air quality parameters such as haze
(visibility). These data are routinely evaluated with respect to NAAQS or other relevant air qualiry metrics.
If a partial-build or build alternative were implemented, significant and measurable influences to air quality
in the region, if any, would be captured by this existing monitoring network.
5.15.2.14.11 USEPA-11
"The FEIS should include mobile input and output files and a summary of the assu�nptions and
methodology used. "
Response: The air quality assumptions and methodology have been provided in Appendix K. The relevant
detailed information for full agency and public review of the air quality analysis has been included. CEQ
regulations for implementing NEPA guide agencies to incorporate material by reference into an EIS "when
the effect will be to cut down on bulk without impeding agency and public review of the action" (CEQ
2005c) and that materials incorporated by reference should be made available for review. The mobile input
and output files are included in the project files and available for viewing at the Park by appointment.
5.15.2.14.12 USEPA-12
Also, please provide a summa�y of the transportation conformity reguirements for this area and how they
apply. ... A statement is needed in the FEIS that discusses that a conformity determination will be made
with the selected alternative included and will be achieved through the Interagency Consultation process.
... The FEIS should include a statement that the Great Smoky Mountains National Park and Federal,
State, and local partners will be convening to discuss and review the regional cor�for�nity determination
prior to signature of the ROD. "
Response: As described in Section 3.3.4.2, transportation conformity applies to federally funded or federally
approved projects in nonattainment or maintenance areas and is intended to ensure that a project's
implementation conforms to the State Implementation Plan (or other designated administrative authority) for
improving air quality to meet the NAAQS. A transportation conformity determination must be prepared for
any selected road consiruction alternative and must be completed prior to signing a ROD. Since the partia]-
build and build alternatives far this project are located in an ozone nonattainment area, a transportation
conformiry determination would be necessary before implementing a partial-build ar build alternative.
An interagency consultation meeting for the conformiry analysis was held on July 17, 2006. Representatives
from NCDOT, NCDAQ, FHWA, USEPA, and NPS each provided input on key aspects for completing the
conformity determination. NCDOT issued a draft report titled Transportation Conformity Analysis for the
North Shore Road in the Great Smoky Mountains National Park (Haywood and Swain Counties) in
December 2006 (NCDOT 2006). The report addresses the Partial-Build Alternative to Bushnell and the
Northern Shore Corridor (Principal Park Roads) as potential worst-case alternatives. The procedures
required a comparison of future projected regional traffic emissions (2030) with a level estimated for a base
year of 2002. (The method of comparing future traffic emissions against levels for a base year was done for
Agency Consultation and Coordination — 5-57
North Shore Road Final Environmental Impact Statement

this conformity determination in the absence of a Motor Vehicle Emissions Budget for the area.) The draft
report indicates that the projected future vehicle emissions are expected to be lower than 2002 levels and,
therefare, the partial-build and build alternatives conform to the regional plan to attain the 8-hour ozone
standard. If a partial-build or build alternative were selected for implementation, a final conformity
determination would be completed prior to signing a ROD.
Text has been updated in Sections 33.4 and 5.10 to reflect the status of interagency consultation and
conformity coordination.
5.15.2.14.13 USEPA-13
"The DEIS discusses mitigation techniques for wetland compensation, but does not outline a plan for
mitigation for the build alternatives. If one of the build alternatives is selected, the Final EIS should
include information regarding the compensatory mitigation plan. "
Response: NPS is committed to limiting impacts to wetlands resources. The mechanism for limiting
impacts is a thre�step process: avoidance, minimization, and compensatory mitigation (such as wetland
restoration). Avoidance of impacts would have the highest priariry. Techniques to avoid, minimize, and
compensate for impacts to wetlands are provided in Section 4.4.1.3. These techniques would be applied as
appropriate during the final design, if a partial-build or build alternative were selected for implementation.
As stated in Section 4.1 "detailed mitigation plans would be developed before implementation of an
alternative."
5.15.2.14.14 USEPA-14
"Water quality (stream) impacts are presented in Table 4-18. Please clarify whether the linear feet of
�streamJ impacts are within the right of way rather than the habitat lost within culverts. "
Response: As noted is Section 4.4.2.1, "Length of stream impacts were calculated using ArcGIS software
by overlaying streams with the potential construction footprint for both the Primitive and Principal Park
Roads." The lengths of stream channel impacted are presented in Table 4-18. These are potential direct
impacts from a partial-build or build alternative, if implemented. Text in Section 4.4.2.1 has been modified
regarding this issue.
It should be noted that these impacts are prior to application of avoidance and minimization techniques, such
as bridging. These techniques would be applied as appropriate during the final design, if a partial-build or
build alternative were selected for implementation.
5.15.2.14.15 USEPA-15
"The DEIS states that mitigation and/or avoidance of acid runoff fi^om rock formations will be necessary
to avoid possible water quality violations (Page 4-172). If either the partial-build or full Northern Shore
Road alternative is selected, the Final EIS should include further infor�nation regarding the impacts and
mitigation associated with that alternative. "
Agency Consultation and Coordination — 5-58
North Shore Road Final Environmental Impact Statement

Response: Discussion of water qualiry in the study corridors, potential project-related impacts, and options
for avoidance, minimization, and compensatory mitigation is included in Sections 3.4.3 and 4.4.3.
Additional detail on these topics is provided in Appendix M.
NPS is committed to maintaining the water quality in the Park and does not intend to violate water quality
standards if a partial-build or build alternative is implemented. Prior to construction, if a partial-build or
build alternative were selected for implementation, a Section 404/401 (of the CWA) permit would need to be
obtained from the USACE and NCDWQ, respectively. The Section 40] Water Quality Certification process
by the state is the mechanism by which the state assures that a project will not violate the applicable water
quality standards and that appropriate measures are in place to avoid violations. Applications for the
appropriate permits would be completed and submitted far approval, if a partial-build or build alternative
were selected for implementation, upon completion of the final design. NPS would comply with the
conditions and requirements associated with these permits.
Techniques to avoid, minimize, and compensate/mitigate for impacts to water quality are provided in Section
4.4.3.3. These techniques would be applied as appropriate during the final design, if a partial-build or build
alternative were selected for implementation. As stated in Section 4.1 "detailed mitigation plans would be
developed before implementation of an altemative."
5.15.2.14.16 USEPA-16
"The partial and full-build alternatives would result in the direct loss of habitat acreage. The DEIS
�nentions potential mitigation, but does not go into detail or commit to nzitigation. If one of the build
alternatives is selected, the Final EIS should give further information regarding mitigation and/or
avoidance of terrestrial habitat loss. "
Response: Techniques to a�oid, minimize, and compensate/mitigate for impacts to vegetation communities
and terrestrial wildlife and their habitats are provided in Section 4.A.53 and 4.4.6.3, respectively. These
techniques would be applied as appropriate during the final design, if a partia]-build or build alternative were
selected for implementation. As stated in Section 4.1, "detailed mitigation plans would be developed before
implementation of an alternative."
5.15.2.14.17 USEPA-17
"EPA defers to FWS regarding threatened and endangered species issues. However, we note on page 4-
233 that `informal' consultation is in process, but it is unclear how the `effects determinations' were
determined for the Bald Eagle and Indiana Bat. Because of the large extent of disturbance to habitat, the
Northern Shore Corridor could represent a May Affect-Likely to Adversely Affect determination which
would require formal consultation for either species. The EIS should include additional sui^vey
information that leads into a discussion of the effects determinations. "
Response: A determination of no/negligible (no effect) was made for the partial-build and build alternatives
per each federally protected species, whenever possible, based on known locations of populations,
availabiliry of habitat, and the potential for any project-related impacts. Based on best professional
judgment, if there was no potential far impacts to federally protected species habitat or individuals, the "no
effect" determination was made.
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North Shore Road Final Environmental Impact Statement

When there was a potential for impacts to federally protected species potential habitat or individuals, a
determination of "may affect" was made, accompanied by determinations of type, conteRt, duration, and
intensity to describe the potential impact. Per the Final Endangered Species Act Consultation Handbook
(USFWS and National Marine Fisheries Service 1998), "may affect" is "the appropriate conclusion when a
proposed action may pose any effects on listed species or designated critical habitat" (emphasis added). The
ESA provides for an informal consultation process between the USFWS and the lead federal agency to
evaluate a proposed action and determine if the effects may be adverse. Determinations of "-not likely to
adversely affect" or "-likely to adversely affect" for each for those alternatives with a"may affect"
conclusion have been deferred. If an alternative having an adverse effect on federally protected species were
selected for implementation, formal consultation would be required and the formal consultation process
would be completed prior to issuing the ROD.
As noted in Section 4.4.10.1.4, if a partial-build or build alternative were selected for implementation, NPS
would develop a comprehensive survey plan for the Indiana bat to determine this species' status in the
viciniry of the alternative. The objectives of the survey would be to evaluate potential habitat, especially the
summer materniry roosting potential, and determine the actual utilization of the area.
The USFWS has delisted the bald eagle in the lower 48 states of the United States from the federal list of
endangered and threatened wildlife, effective August 8, 2007. The Final Rule pertaining to the
determination of recovery and delisting of the bald eagle was published in the July 9, 2007, Federal Register
Part III 50 CFR Part 17. Information discussed in the FEIS was developed while this species was federally
listed as tbreatened. Text pertaining to the bald eagle has been retained for informative purposes. NPS will
comply with the Bald Eagle and Golden Eagle Protection Act and the Migratory Bird Treaty Act.
5.15.2.14.18 USEPA-18
"EPA recommends that the NPS coordinate with the State Historic Preservation O�ce regarding cultural
resources and historic preservation if one of the build alternatives is selected. "
Response: Consultation with the NC SHPO is ongoing, as evidenced by the NHPA Section 106 Consulting
Parties meetings (see Sections 5.5 and 5.7), the PA (Appendix H), and additional letters from NC SHPO
(Appendix P). As outlined in the PA, such consultation would continue if a partial-build or build alternative
were selected for implementation.
F� F� �i L� F� S I1 Cy � J� 6�' ]
"The FEIS needs to clarify the analysis regarding geology-related i�npacts (waste generation — acid rock)
in terms of severity. Northern Shore has between 1.7 and 2.9 million cubic yards, Partial Build has
between 693,900 to 948,100 cubic yards and the Laurel Branch Picnic Area alternative has 24, 700 cubic
yards. Yet all three are characterized as being �najor, adverse and lor�g-term. In terms of scale, they
represent a magnitude of d�erence. "
Response: Per the DO-12 Handbook (4S(g)(5)), "Impacts must be quantified as much as possible and
interpreted in terms of their context, duration and intensiry." Definitions of context, duration, and intensity
are tailored for each NPS project and far each individual resource. While context is integrated into the
intensity threshold definitions for some topics (e.g., economics, land use), for some resources, including
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North Shore Road Final Environmental Impact Statement

topography, geology, and soils, it is necessary to determine the intensity of the impact separate from the
context of the impact. This allows the impact to be analyzed relative to a standard that provides better
understanding of both the extent and relative significance of the impact. Providing the type, quantity,
duration, and intensiry of each impact allows for a clearer understanding of the potential effect to
topography, geology, and soils. Although these impact determinations are also used to compare alternatives,
the focus is on evaluating the impact of a given alternative, and threshold determinations are not developed
relative to other alternatives. Far impacts to topography, geology, and soils, the impacts of all of the partial-
build and build alternatives (even the Laurel Branch Picnic Area), have been determined to be major. The
magnitude of difference between the partial-build and build alternatives is represented by the volumes
(volumetric comparison).
5.15.2.14.20 USEPA-20
`Page 4-255 states that `a partial-build or build alternative would require extensive construction; the
effects (i�npacts?) of which would be long-term and permanent. The alternatives would require ... that
would be irretrievable if impacted by the alternatives. ...' These statements are in direct conflict with the
conclusion statenzents on Pages 259 and 260 regarding the Partial-build and North Shore Corridor
alternatives.
After all of the described `major' effects in the discussions about the conflicts of the build alternatives
(other than the Laurel Branch Picnic Area) the conclusion statement on page 4-259 states that `. .. none
of the alternatives would harm the integrity or values of GSMNP or AT resources. ...' This statement
conflicts with information given elsewhere in the document. "
Response: As noted in Section 3.2.5.1, "The NPS Organic Act of August 25, 1916, states that the
fundamental purpose of national parks is `to conserve the scenery and the natural and historic objects and the
wild life therein and to provide for the enjoyment of the same in such manner and by such means as will
leave them unimpaired for the enjoyment of future generations."' As described in Section �.l .3, NPS
Management Policies define "impairment" as "an impact that, in the professional judgment of a responsible
NPS manager, would harm the integrity of park resources or values, including the opportunities that
otherwise would be present for the enjoyment of those resources or values" (NPS 2006b). NPS policies
require an analysis of impairment to resources as part of the environmental impact analysis process.
Impairment determinations are treated as separate findings from impact thresholds. NPS policy guidance
does not define "impairment" as equivalent to a"major, adverse impact."
In determining whether an impact would be likely to cause impairment, the NPS manager must consider the
extent that the impact affects a resource or value whose conservation is: necessary to fulfill specific purposes
identified in the establishing legislation or proclamation of the park; key to the natural or cultural integrity of
the park or to opportunities for enjoyment of the park; or identified as a specific goal in the park's general
management plan or other relevant NPS planning documents. While impairment is discussed in the EIS, it is
a separate evaluation based on these considerations and in consideration of the impacts noted in the EIS. The
impairment analysis is not a NEPA requirement, but a DO-12 requirement.
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North Shore Road Final Environmental Impact Statement

5.15.2.15 United States Fish and Wildlife Service (USFWS) — April 6, 2006
5.15. 2.15.1 USFWS-1
"The Service currently (March 29, 2006) considers Graham County to have 2�4J FSC and Swain County
to have 39 FSC. A copy of th�e most recent list for these two counties is enclosed. "
Response: Updates have been included in Table 3-11, Section 3.4.10, Section 4.4.10, and Appendix N to
reflect recent revisions to the USFWS' protected species list for Graham and Swain Counties, North
Carolina.
5.16 List of Preparers
The list of preparers for the EIS is included in Table 5-1.
Name
Table 5-1. List of Preparers
Title Education/Experience Primary Role
ARCADIS: EIS; Appendices B,C, E, I, J, K, L, M, N, and O; and Attachments M-7, N-2, and N-12
Hal Bain
Andy Batts, PE
Justin Beard, PE
Jerry Beckman, PE,
PLS
Steven Bondor, PE
Natural Resources
Manager, ARCADIS
Structural Design
Department Manager,
ARCADIS
Traffic Engineer,
ARCADIS
Land Resources
Business Practice
Manager, ARCADIS
Senior Engineer,
ARCADIS
Master of Science in Marine
Biology, Bachelor of Science in
Biology; over 17 years of
experience in the natural
resources field, including
environmental planning,
mitigation, conservation and
stewardship, and protected
species studies
Bachelor of Science in Civil
Engineering; over 17 years of
experience in bridge design
Bachelor of Science in Civil
Engineering, Bachelor of
Science in Environmental
Studies; over 7 years of
experience in all aspects of
traffic engineering
Bachelor of Science in
Industrial Technology; over 24
years of experience in civil/site
design, surveying, and project
and personnel management
Bachelor of Civil Engineering;
over 26 years of experience in
project management and
technical design of civil
engineering projects, including
highway drainage design,
stream restoration, site and
infrastructure desian.
Natural resource
investigations,
documentation, fieldwork,
document review, and
quality assurance
Investigated major bridge
types to determine which
might be appropriate on the
project
Traffic counts, traffic
projections, noise analysis,
transportation systems
capacity analysis, energy
Partial-Build Alternative to
Bushnell conceptual plan,
Partial-Build Alternative to
Bushnell and Laurel Branch
Picnic Area cost estimates
Floodplains, hydraulics,
and cost estimates
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North Shore Road Final Environmental Impact Statement