Mammoth Cave National Park

In October 2001 IUCN received reports of a proposal to develop a large industrial estate (1,000 acres), airport (1,700 acres) and transport interchange node (1,000 acres) on Sinkhole Plain, Warren County, Kentucky, approximately 8 miles south west of the Mammoth Cave National Park and World Heritage site.  The development – Kentucky Trimodal Transpark (or Transpark) is planned to be developed in phases.  No Environmental Impact Assessment (EIA) has been prepared for the development, though the proponent – the Inter-modal Transportation Authority (ITA), an agency of the Warren County Fiscal Court and Bowling Green City Commission – has carried out an Environmental Assessment (EA).  This process is not as rigorous as an EIA and does not include analysis of alternative options, consideration of conflict of interest, or allow for public input.  Despite this, IUCN has been informed that moves to purchase land for the development are underway.

IUCN is aware that there is strong debate within the local communities and scientific circles about Transpark, and a coalition of concerned individuals, organizations and businesses, including scientists, cavers and academics, has joined to form the Karst Environmental Education & Protection Coalition (KEEP) and lobby against Transpark.

Many of these concerns are related to the lack of an EIA, including a comprehensive geo-hydrological study to establish the risk of spillover and backflow of water (and accompanying pollutants) between the Graham Springs Karst Basin, on which Transpark is located, and the Turnhole Spring Basin, in which Mammoth Cave is located.  These are needed to assess the risk to Mammoth Cave posed by Transpark.  For more information, KEEP has established a detailed website addressing the range of concerns with the Transpark proposal at: http://www.stoptranspork.org IUCN believes that potential impacts on the World Heritage site could include: Industrial runoff and oil spills associated with Transpark could pollute underground streams and cause irreparable harm to Mammoth Cave.  Pollution may threaten, through low level toxic accumulation, long-lived cave organisms, and threaten already endangered species.  More than 130 species use the Cave, including the blind shrimp, blind crayfish, cave cricket and endangered Kentucky Cave Shrimp, Indiana bat and Grey bat; Regional air quality may be negatively impacted.  Mammoth Cave National Park is designated as a Class 1 Airshed under the Clean Air Act, which allows no additional degradation of the air quality within 60 miles of the Park.

IUCN received information from the State Party in March 2002, which notes: That the approximate boundary between the Barren River watershed [Graham Springs basin] and the Green River watershed [Turnhole Spring or Mammoth Cave Basin] runs through the property.  Further data collection and analysis are needed to determine the precise boundaries between the two;  A letter of 2 May 2001 from the Superintendent of the Park, responding to the ITA EA, expressed concern that the EA was inadequate and an EIS should be completed prior to any decision by the ITA;  ITA has chosen to make decisions without the benefit of further research.  To date, no federal funding is committed to the Transpark, therefore an EIS is not yet required in the planning process; ITA is currently in the process of hiring a planning consultant for the industrial park.  ITA is discontinuing land acquisition for the airport until FAA finishes the risk analysis on the airport.

IUCN has also received a copy of an official letter by the Superintendent of the Park which expresses strong concern that decisions regarding the development have been made prior to compliance with environmental requirements and without adequate consideration of the environmental consequences.  It recommends that the ITA should “immediately suspend decision making and commit to the preparation of an Environmental Impact Statement in full adherence with Federal Aviation Administration environmental compliance guidelines.”  This letter also refers to a number of inadequacies in the EA including: Lack of analysis of potential air quality impacts for the airport and the business and industrial component of the project; Insufficient water quality analysis. Project should assume that all sinkholes on the site are inputs or tributaries for the major groundwater conduits; Lack of detailed information related to groundwater flow routes;  No consideration of the sound scope of the Park as an environmental value to be preserved and extent to which aircraft noise will be heard in the Park;  Lack of environmental analysis of the entire project and all types of commercial development involved; Lack of evaluation or consideration of cumulative effects of the development as a whole; Lack of adequate consideration and analysis of alternatives for the development, not just within the site, but options for sitting elsewhere.  IUCN has also been informed that a preliminary report entitled Site Evaluation and Design Assistance for the Proposed Kentucky Trimodal Transpark has been produced for the ITA.  The aim of the report (to be completed by the 1st January 2003) is to perform a hydrogeologic investigation of the Site selected for the Kentucky Trimodal Transpark.