Here is a summary of my concerns regarding the JWP DEIS. I hope that others may also contribute their concerns, thus enabling an open discussion of the DEIS.

I use an appreciate the many South Knoxville parks and natural areas including Meade’s Quarry, Ijams Nature Center, William Hastie Natural Area, Forks of the River, Marie Myers, and the greenways. Of the four total options presented in the DEIS, I support the “no build” alternative. My rationale is described below.

1. I am unconvinced that the JWP will not impact Meades Quarry or other cave systems in the area. The Federal Register listing of the Berry Cave salamander (link...) identifies Meade’s and (potentially) Cruze Road cave systems as prime habitat, and the greatest risk as the proposed JWP. Cut-and-fill for this road will produce massive volumes of sediment, and it is possible that sediment could contaminate beautiful Meades Quarry. TDOT has worked with US F&W to perform a dye trace to understand connections between sinkholes in the uplands with Meades Quarry, by committing to a number of remedial actions, and by re-routing.

TDOT’s own dye trace and the infamous Coster Shop dye trace both suggest recharge in the vicinity of the road, and discharge in the vicinity of the French Broad (p. 165). The DEIS, however, strongly states that the dye trace proved NO connection between sinkholes near the proposed roadbed to Meades Quarry (p.111), i.e., the exact location of discharge does not involve Meades Quarry. But, the two primary documents on dye trace and karst (TDOT 2009 a,b) are not publicly available, and TDOT has yet to provide them because of the risk of disclosing sensitive locations. TDOT has agreed to bring the authors and the studies to the public meeting, but if the studies cannot or will not be made available to the public, in my opinion the lack of transparency invalidates the use of their findings for the purpose of the DEIS, i.e., violates the spirit, intent, and possibly the letter of the NEPA process.

Aside from transparency, I wonder if TDOT has overstated the significance of the dye trace. Dye tracing is a technique designed to prove connections, by being input in one location, and observed at another, but it is not a technique capable of DISPROVING connections (Benischke et al. 2007; Quinlan, Ewers, and Field). Water flow through karst systems can change radically with different water table elevations (Göppert and Goldscheider, 2008; Quinlan et al., 1991), and one test is unlikely to be representative of all possible conditions, or even average conditions, over the expected life span of the road or the period of construction (Goldscheider et al., 2007; Quinlan et al., 1991). The critique by Quinlan (1986) further demonstrates how dye tracing should be done carefully and scientifically, because of the risk of misinterpretation or inadequate understanding of the system. The DEIS is completely lacking in acknowledgement of uncertainties of dye tracing in general or this study in particular. In short, the presentation in the DEIS is completely unscientific.

2. With the plans to increase and enhance recreational opportunities, South Knoxville has found its wild and scenic identity, and the resources to develop it! The highway will have negative impacts to South Knoxvillians right to self-determination – a mixed-use, well-connected urban-wildland recreational area.

3. I disagree with the de minimis finding for Hastie park, as the road will likely be visible and audible from much of the park. Now, Hastie is quiet and peaceful. That solitude will be destroyed by JWP.

4. I appreciate that the proposed JWP is limited access, but the access point with Sevierville Pike will suffer from commercial development. Because of the steep slopes and sinkholes, development or road building will require extensive cut and fill, which will greatly increase the footprint, the cost, and the overall impacts. Further, the public may be on the hook for providing expensive and damaging infrastructure for developers.

5. The recent Smart Growth America report ((link...)) details that TDOT has approximately 9 times more projects proposed than funding available. Local opposition, the high cost per mile ($20 million/mile), damage to the connectivity of wildlands and recreational opportunities, and risks to the various cave systems make the JWP an excellent candidate for elimination from TDOT’s workload. For South Knoxville, funds would be better spent improving Chapman Highway.

References:
Benischke, R., Goldscheider, N., and Smart, C. 2007. Tracer techniques. In: Methods in Karst Hydrogeology: IAH: International Contributions to Hydrogeology 26. Goldscheider, N., and Drew, D.P., (Eds.), Taylor and Francis, pp.147-170.

Göppert, N., and Goldscheider, N. 2008. Solute and Colloid Transport in Karst Conduits under Low‐and High‐Flow Conditions. Ground Water, 46(1), 61-68.

Goldscheider, N., Drew, D.P., and S. Worthington. Eds. 2007. Chapter 1, Introduction. In: Methods in Karst Hydrogeology: IAH: International Contributions to Hydrogeology 26. Goldscheider, N., and Drew, D.P., (Eds.), Taylor and Francis, pp. 1-8.

Quinlan, J. F. 1986. DISCUSSION OF “GROUND WATER TRACERS,” by Davis et al. (1985), with Emphasis on Dye-Tracing, Especially in Karst Terranes. Ground Water, 24: 253–259. doi: 10.1111/j.1745-6584.1986.tb01004.x

Quinlan, James F., et al. 1991. Recommended administrative/regulatory definition of karst aquifer, principles for classification of carbonate aquifers, practical evaluation of vulnerability of karst aquifers, and determination of optimum sampling frequency at springs. Hydrology, Ecology, Monitoring, and Management of Ground Water in Karst Terranes Conference (3rd. Nashville. Tenn. 1991). JF Quinlan and A. Stanley, Editors. National Ground Water Association. Dublin, Ohio. (link...)

Quinlan, J.F., Ewers, R.O., and Field, M.S. Washington, D. С. "HOW ТО USE GROUND-WATER TRACING TO" PROVE" THAT LEAKAGE OF HARMFUL MATERIALS FROM A SITE IN A KARST TERRANE WILL NOT OCCUR." (link...)

TDOT, 2009a. Tennessee Department of Transportation. Hydrogeologic and Dye Trace Study Report. James White Parkway Extension: Meades Quarry Cave Area, Knox County, Tennessee. September 2009.

TDOT, 2009b. Tennessee Department of Transportation. Geologic Brief on Karst and Caves. Prepared by TDOT Geotechnical Engineering Section for the Agency Field Review Meeting. James White Parkway, Knox County,Tennessee. April 2009.