March 9, 2022
Mr. Alan Sumeriski
Superintendent, Great Smoky Mountains National Park
107 Park Headquarters Road
Gatlinburg, TN 37738
Subject: Comments on Revised Environmental Assessment for Proposed Wears Valley Mountain Bike Trail System
Dear Acting Superintendent Sumeriski:
I am writing on behalf of over 2,100 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 40,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
We are writing to offer formal comments on the Revised Environmental Assessment (EA) for the proposed Wears Valley Mountain Bike Trail System within Section 8D of the Foothills Parkway portion of Great Smoky Mountains National Park. The Coalition previously submitted scoping comments on this proposal on August 17, 2020; and we feel that several of the issues raised in those comments have not been adequately addressed in the Revised EA. To avoid repeating our earlier points in toto, we will summarize our continued concerns, along with concerns that arise from a careful reading of the revised EA and Appendices.
1) We remain very concerned about the precedent setting nature of this proposal. While we are aware of other national parks that allow limited mountain biking on existing bike routes, we are not aware of any other unit of the National Park System that has constructed a “purpose built” backcountry mountain biking trail system with associated support facilities, including roads, parking lots, rest rooms and a potential concession operation. National Parks were never intended to be all things to all people. Nor are they required to accommodate every new form of recreation that comes along.
2) We continue to believe this proposal is inconsistent with the legal requirements under the NPS Organic Act’s conservation mandate to err on the side of conservation in managing units of the National Park System, including that portion of GRSM where the Foothills Parkway is located. The Revised EA articulates significant impacts to park soils, surface waters, vegetation, visitor experience, and wildlife. While you may argue that these impacts do not rise to the level of impairment, they are none the less, significant and adverse. In plain terms, the Foothills Parkway portion of GRSM is not excluded from being managed under the NPS conservation mandate.
3) Despite your considerable efforts to address this point in the Revised EA and in Appendix A, we continue to think that there is very little, if any, consistency between this specific proposal and previous planning documents, all of which envisioned much more traditional recreational activities within the Foothills Parkway area, such as hiking, horseback riding, camping and fishing. It should go without saying that a proposal to introduce mechanized recreation into a backcountry area at GRSM, or any national park for that matter, is problematic.
4) We remain very concerned that an Appropriate Use Analysis has not been completed for this proposed activity as required by NPS Management Policies. Appendix D acknowledges that this process must be completed, but states “A decision regarding the appropriateness of this proposed use is pending completion of the NEPA process”. This seems completely backwards to us. Why spend several years and tens of thousands of dollars preparing an EA for an activity that may or may not even be appropriate in the park? The sequencing of these two steps certainly suggests the park has already concluded this activity is appropriate, without actually going through the proper process for making that determination.
5) We continue to take very strong issue with the Purpose and Need Statement in the Revised EA.
Again, you state that the purpose of the project is to “enhance the visitor experience”, but then only evaluate one form of recreation – a “purpose- built mountain bike trail system”. We are troubled by your statement in the Revised EA that the park ruled out any further consideration of activities like hiking, horseback riding, and camping within the Foothills Parkway “because those activities are already readily available within the park”. While not “within the park”, the Revised EA makes it clear that purpose-built mountain bike trails are available nearby – for example, at the Vee Hollow Mountain Bike Trail System in Townsend (14 miles of trails) and the soon-to-be-opened Hall’s Top Mountain Bike Trails in Cocke County (50-75 miles of trails). We would argue that the park’s planning efforts and view of “Need” be considered in a regional context and there is no need for an additional mountain bike trail system within the Foothills Parkway.
We are particularly troubled by the Need Statement which reads “proposed action is NEEDED (our emphasis) to take advantage of new and unique recreational activities that exist within the wears Valley portion of Parkway Section 8D”. Respectfully, NO, it’s not! The NPS is under no legal or policy requirement to “take advantage of” or accommodate every new recreational opportunity to come along. This EA appears to be written to justify something the park thinks is a good idea (or is being pressured into), despite the well-documented environmental and operational impacts.
We also remain concerned that the 3 meetings held between October of 2018 to October of 2019, which resulted in the park focusing on this proposal at the expense of any others, was not a public process and may have violated the Federal Advisory Commission Act. The Coalition would appreciate a written response from the park on this specific concern.
6) We continue to remain very concerned about the impact of this proposal on an already overburdened staff and infrastructure.
In reading the revised EA, we were surprised to learn that the park does not yet have funding for this project. We were further surprised to learn that the park has not decided how the trail system would actually be operated – such as by NPS staff and volunteers, through a partnership agreement or through a concession contract. These are operational costs and impacts that should reasonably be evaluated in the EA; and all three of those options appear to discount impacts on staff of conducting the visitor and resource monitoring called for in the EA, as well as impacts to law enforcement and emergency response staff. Again, it appears the park has already decided to build the trail, no matter the impacts to park resources or staff.
We are also concerned about the discussion of daily use limits (# People at One Time), and how the park would deal with adverse impacts from excessive use. The EA states “if crowding, congestion, visitor conflicts and safety concerns persisted, NPS ‘would consider’ initiating planning and environmental compliance process for implementing a reservation system to manage visitor access and improve visitor experience and/or increasing trail capacity by expanding the mountain bike trail system in adjacent portions of the parkway 8D Corridor. To be frank, “would consider” is not a reassuring statement. The reference to expanding the mountain bike trail system is very concerning and does not appear to have been addressed in the analysis of cumulative impacts. Since the Park is apparently opening the door to expanding the trail system via this language in the EA, even before a first phase has been constructed, this should be included in the analysis of cumulative impacts.
CONCERNS SPECIFIC TO THE ENVIRONMENTAL CONSEQUENCES
Under NEPA, an environmental consequence is defined as “Adverse” if it is a “change that declines, degrades, and/or moves the resource away from a desired condition or detracts from its appearance or condition”. After a careful reading of the Revised EA, we are very concerned about the following statements, all of which describe various levels of adverse impacts from this project.
1) Soils (pages 33-34). The Revised EA states:
• The project “would result is direct, short and long-term adverse impacts” resulting from soil compaction and erosion, conversion of native vegetation to bare soil and the creation of new impervious surfaces.”
• “When the incremental impacts are combined with the impacts from reasonably foreseeable actions, the overall impact on soils would be adverse.”
• “Bicycles and foot traffic associated with increased visitation would have adverse impacts on soils.”
2) Surface Waters (pages 37-43). The Revised EA states:
• “Operation of the mountain bike trail system could result in long-term sedimentation and water quality impacts to surface waters.”
• “Overall, the project’s construction and operation would result in short term (localized sedimentation during construction) and long-term (stormwater runoff from the impervious surfaces) adverse impact on water resources in Wears Valley.”
3) Vegetation (pages 43-49). The Revised EA states:
• “Project would result in (various acres depending on Alternative) of total vegetation removal and would adversely affect vegetation in the project area.”
• “Few invasive species grow in the portion of the project area south of the Katy Hollow Road. Construction and use of the mountain bike trails in this area would likely spread invasive species here.”
• Project “would result in direct, short and long-term adverse Impacts from the construction of road surfaces, trailheads, mountain bike trails and the potential spread of non-native invasive species.”
4) Visitor Use and Experience (pages 50-53). The Revised EA states:
• “Development of the mountain bike system could increase visitation, but it may also contribute to distributing visitation from the congested areas of the Park, such as Cades Cove, which could reduce visitation pressure in other areas of the Park.” We challenge this assumption that the new mountain bike trail system will disperse current park use. We believe the mountain bike trails will attract a largely different user group than the visitors that currently ride their bikes in Cades Cove and elsewhere in the park, resulting in increased park visitation.
• The EA also states “this analysis of impacts assumes that all visitors obey the rules and regulations of the Park and stay on the appropriately designated trails.” This assumption is naïve and disingenuous to the Park Ranger staff who will have to enforce the regulations and respond to emergencies.
• The EA acknowledges that the mountain bike trail system will have an adverse impact on birding in the area, but concludes the project, overall, would have a “noticeable beneficial impact.” The latter is true only if you are a mountain biker, and not a birder or a hiker that currently enjoys that part of the park. This conclusion seems terribly biased towards mountain biking.
5) Wildlife (pages 53-63). The Revised EA states:
• “Long-term impacts on birds and bird habitat would occur from the permanent loss of habitat.”
• “Project would result in direct and long-term adverse impacts to bats, including the Federally listed Indiana and Northern Long-Eared Bat.”
• The project “would result in adverse impacts to bears from increased visitor use and human presence.”
6) Karst (pages 63-72). The Revised EA states:
• The project would result in “potential impacts to karst resources by altering existing runoff patterns, changes to the groundwater system and introduction of an alteration of preferential subsurface flow paths.”
• It concludes that the “overall cumulative impact on karst resources would be adverse.”
Taken as a whole, the Revised EA clearly articulates a broad range of adverse impacts to the Park’s natural resources. In contrast, it only identifies one potentially positive impact from the project – enhanced recreational opportunities for mountain bikers. To be frank, it is hard to fathom how this project is consistent with the Park’s stewardship responsibilities under the NPS conservation mandate or that a Finding of No Significant Impact (FONSI) could be approved for this project.
In conclusion, the Coalition respectfully asks the park to abandon this proposal. While we could support additional backcountry hiking trails in this portion of the park, we cannot support a purpose-built mountain bike trail system and all of the associated facilities. The impact to park resources and park staff is just too great; and given the proximity of similar facilities, it simply is not needed.
Michael B. Murray, Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013