North Shore Road (5)

A ?
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Land Resources
James D Simons, P G , P E Land Quality Section Michael F Easley, Govei
Director and State Geologist William G Ross Jr, Secri
March 2, 2006
MEMORANDUM
TO Melba McGee
FROM T Gray Hauser, Jr,;K
State Sedimentation Speci list
SUBJECT North Shore Road
Draft Environmental Impact Statement
Great Smokey Mountains National Park
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 All the streams that would be impacted are classified by the
Environmental Management Commission as Class C, Trout, with portions of some streams also
classified as WS-IV NCGS § 113A-57 allows land disturbance within 25 feet of the top of the
bank of trout waters only when "the duration of said disturbance would be temporary and the
extent of said disturbance would be minimal " Bridging the stream crossings would be
necessary, with extensive provisions for sedimentation and erosion control The best available
technology would not prevent violations of the water quality standard for turbidity in trout
waters
Permanent impacts would result from both the paved or gravel road Continued sedimentation
from gravel roads is a well-documented problem The impervious surface of a paved road would
result in increased stormwater runoff volume and peak discharge, resulting in streambank
erosion of receiving watercourses
Attempts to establish ground cover on acidic soils often fail, as evidenced by highway projects in
North Carolina through Black Creek Clay soils No confidence should be placed in proposals to
mitigate or neutralize acidic drainage Notable are the failed attempts to provide ground cover
and control acid mine drainage from Ore Knob in Ashe County Exposing acidic soils in Great
Smokey Mountain National Park would be an ecological disaster 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
1612 Mail Service Center, Raleigh, North Carolina 27699-1612 • 919-733-4574 / FAX [phone]
512 North Salisbury Street, Raleigh, North Carolina, 27604