Mr. John F. Ramey
Forest Supervisor
P.O. Box 275O
Asheville, NC 28802
 

Dear Mr. Ramey,

I am writing in regard to the March 2, 2001 Environmental Assessment arid request for comments regarding the proposal by WLOS-TV to place a high definition TV transmission tower on Mount Pisgah. The Western North Carolina Alliance is a non-profit grass roots organization whose 1,200 members reside in North Carolina's mountain region. Two different entities within the Western North Carolina Alliance, the Public Parks Task Force and the Forest Task Fore; have expressed concerns about this proposal, and this letter reflects the views of both entities.

The WNC Alliance is appreciative that the Forest Service performed an Environmental Assessment regarding this proposal. We do not feel that the document property addresses aIl of the issues raised during the scoping process, however. We are also extremely disappointed that only two alternatives were proposed, and do not feel that this is consistent with the intent of the National Environmental Policy Act.

The EA states that relocating the tower is outside the scope of the proposal. We do not see how this issue can be separated from the whole issue of the permit expiration in 2005. For one thing, it is obvious in any analysis of this issue, and based on countless experiences with private corporate precedents, that it is highly unreasonable to expect WLOS to make the huge investment of a new technology (the proposed tower) without fully expecting it to remain there for many years or decades. The Forest Service must acknowledge this fact. To ignore it, indicates an apparent unwillingness by the Forest Service to ever really consider the relocation issue when it comes time to discuss a new permit in 2005. On the other hand, if the possibility exists (which it should) that a new permit might not be issued in the future, then granting the preferred alternative in the EA would be unfair to WLOS which would have the extra cost of tearing down the new proposed tower in 2005 and rebuilding it elsewhere. Obviously, such an outcome could have legal consequences.

The EA notes that the present tower was strengthened in the past to accommodate new equipment, yet there is no proposed alternative that would look at further strengthening the existing tower to include the digital equipment. This possibility should be examined.

Regarding the visual impart issue, we feel that the Forest Service is violating its own regulations by denying the impact of the existing tower as being within the scope of the proposal, and then stating that "The proposed action is to replace the existing tower with a new one rather to modify the existing tower or configuration." The new tower, while the same height above sea level, is nevertheless of a different confIguration (274 feet in height as opposed a 271 feet) than the old tower, and is a de facto modification of the old tower because it is replacing the original altogether immediately ad adjacent the present site. Has the Forest Service considered that the tower will certainly appear to be a modification and change in configuration to distant or even nearby observers? The configuration and exact design was not even illustrated in the EA, so the public and agencies could flat possibly comment on its appearance should it be built. Further, the EA makes reference to the future addition of equipment by others to the tower an apparent admission that the "configuration" of the present tower will indeed be different at some unspecified time. Discussion of the visual impacts of such equipment, therefore, are within the scope of this proposal and should have been included in the EA.

For those climbing the trail and using the observation platform on Mt. Pisgah, the existing tower is, and any future tower will also be, highly incompatible with this form of passive recreation. From close up, the current metal framework tower; any future tower structure; the numerous accompanying cables, disk-like and drum-like structures, the extensive inclined rail system, and the continual noise produced by equipment a short distance down the rail are a gross intrusion to any kind of positive recreational experience on the mountain top. The ominous warning signs regarding radiation are equally out of character. BA discussion of these impacts is totally inadequate.

The existing tower was permitted before the current National Forest Management Plan was approved. The current Plan implies, in its special uses language, that such a tower would not be compatible with Management Area 13. This issue is inadequately discussed in the EA.

While the Blue Ridge Parkway is not currently included on the National Register of Historic Places, it is certainly eligible for that list. It is hard to imagine how the Forest Service could have overlooked this point when discussing potential impacts to this resource in the EA. This should be addressed.

Finally, on reading the EA, several references were made to the National Park Service/Blue Ridge Parkway, which clearly give the impression that Parkway staff were fully consulted over various issues. Upon contacting the Parkway with questions of our own, it is clear to us that some of these communications were in error or misrepresented in the EA, which gives us cause for concern. We feel that with matters so important as natural resource lands held in stewardship and in the public trust, it is imperative that the US Forest Service (or any federal or stare agency), make every effort to assure extensive and correct communications,

The WNC Alliance urges the Forest Service to produce an Environmental Assessment that addresses the above issues in greater detail and thoroughness.

Thank you for the opportunity to comment, and please keep us informed on the statue of this proposal.
 

Sincerely,
 

Bob Gale
Ecologist
Western North Carolina Alliance

For: Garrett Smathers and Dan Pittillo
Co-Chairs, Public Perks Task Force

Speed Rogers
Chair, Forest Task Force

cc: Gary Johnson, Blue Ridge Parkway