A3815

May 21, 2002

Mr. Dan Cherry
Inter-modal Transportation Authority, Inc.
2325 Airway Court
Bowling Green, Kentucky 42103

Dear Mr. Cherry:

Mammoth Cave National Park appreciates the opportunity to review the document: Site Evaluation and Design Assistance for the Proposed Kentucky Trimodal Transpark, Preliminary Report. As stewards of a nationally and globally significant cave and karst resource, we must take every step to assure its conservation and protection. In addition to being a national treasure, Mammoth Cave National Park is also the core of an International Biosphere Reserve. Sustainable development within the Reserve is central to the Biosphere Program, providing it does not cause harm to the core area.

As caretakers of Mammoth Cave National Park we are mandated to conserve and protect park resources. Therefore, we must be assured that no harm will come to the park by activities within our air and watersheds. We also are concerned with karst groundwater conservation issues throughout the Biosphere Reserve. Far too often we have witnessed the degradation of watersheds by development that does not fully recognize the scope of affected natural resources and accumulative effects of incremental development at the landscape level.

There has, with good reason, been much emphasis in this report on possible impacts from the proposed Transpark on Mammoth Cave. Regardless of potential effects on the park's groundwater resources, developers must be mindful of impacts to the water quality of the Graham Springs basin. That is, although the report focuses on the possibilities of a spillover or flow reversals impacting Mammoth Cave, little attention was given to the one groundwater basin that is absolutely known to receive runoff from the proposed KTT site - the Graham Springs groundwater basin. We believe that if proper steps are taken to protect the water quality of Graham Springs, then any arguments pertaining to spillovers and flow reversals to Mammoth Cave are moot. We also believe that, although the report makes several commendable recommendations for reducing groundwater contamination, they are extremely costly, not required by law, and not estimated in the budget for the project. There are no assurances from the Inter-Modal Transportation Authority that any of these extra measures would be followed.

We are appreciative of the efforts the Center for Cave and Karst Studies (CCKS) in their evaluation of the karst hydrogeology in the Preliminary Report. However, we feel that a simple review and interpretation of existing data does not adequately answer the fundamental questions of impacts to the groundwaters of Mammoth Cave National Park or the Graham Springs watershed. The attached review of the Preliminary Report, prepared by Park Hydrogeologist Joe Meiman and staff of our Division of Science and Resources Management, addresses our specific concerns with respect to groundwater issues. We ask that this review be made part of the Administrative or Public Record of the Kentucky Trimodal Transpark Project. We look forward to working with the CCKS in the completion of this report and any future research.

Sincerely,

Ronald R. Switzer
Superintendent

Enclosure

cc:
Dr. Nick Crawford, WKU

JMeiman:jm:\ITA\Review of KTT prelim report V3.doc