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To the ITA Board, Concerned Agencies, and Interested Citizens:

My name is Roger W. Brucker. I am co-author of four books on cave subjects and have authored or co-authored scientific articles on caves and karst subjects. I also have taught the Speleology course for Western Kentucky University for 20 years, although I do not represent WKU in the matter before us. I also am an Honorary Life Fellow of the National Speleological Society and a founding director and past president of the Cave Research Foundation.

Executive summary

This document will explain how the proposed Kentucky TriModal Transpark:

1. Will place citizens at risk of irreparable harm due to safety hazards, structural collapse, maintenance, repairs, potential liability, and property damage (see pages 1-7, 16-19.)
2. Will cause many kinds of irreparable harm by polluting the Mammoth Cave karst drainage basin and the Graham Spring karst drainage basin (see pages 9-11, 13-16), and
3. Will cost taxpayers millions of more dollars than anticipated, in the wake of $21 million of past blunders in southcentral Kentucky karst development (see pages 10-13).

Introduction

Development of the proposed KTT (Kentucky Trimodal Transpark), described in the ITA's Environmental Assessment (EA) and supporting Appendices, will cause many kinds of irreparable harm. It will irreparably harm Mammoth Cave National Park, the Graham Spring Karst basin, the Sinkhole Plain environment, and ultimately, the citizens of southcentral Kentucky and the United States.

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A study of the EA reveals that specific karst hazards remain minimized and unrecognized by the developers and their consultants. The karst hazards have been insufficiently studied as to risk. The project should be delayed until specific scientific information is available to safeguard the public from irreversible and irreparable harm. This region has already paid a heavy price - in excess of $21 million of taxpayer funds - to fix such projects in the past where the driving force was characterized by Ignore Karst; Build Now; Fix Later. There can be no reason in the public interest to go ahead with the KTT development without sufficient and professional study.

All of the karst hazard issues that justify a conclusion of irreparable harm are interlocked. That is, it is not possible for the ITA to pick apart and dismiss a karst hazard issue by saying, "Best practice will be followed" or "Mitigation measures will be taken after the land is acquired," or "We disagree." The existence of any one karst hazard issue justifies delay or abandonment of the project. Concurrently, the elimination of any one karst hazard issue cannot justify the ITA proceeding hastily with irreversible land acquisition and project funding.

Lost River chert weakness causes catastrophic collapse when loaded, an overlooked significant difference between this karst area and other karst areas

The EA's geologic analysis of the region and site are superficial and inadequate. A major geologic unit, the Ste. Genevieve limestone, is omitted from discussion of regional stratigraphy (page 3-11). Further, the site description characterizes the geology as interbedded limestones, shales, and siltstones, where, in reality, the limestones present - except for the chert - are among the purest limestones in the state.

The EA (Environmental Assessment) describes the Oakland, KY (Yellow Site) of about 4000 acres as lying on the Ste. Genevieve limestone and St. Louis limestone of Mississippian age (page 5-8). The EA briefly reports on the presence of chert nodules in both limestone formations (page 4-38) and the possibility of collapse (page 3-15; 4-50; 5-8).

The EA omits any discussion of the Lost River chert unit of the St. Louis limestone. This ten-foot thick bed lies near the top of the St. Louis limestone. The entire proposed site of 4000 acres is located atop the Lost River chert, which is brittle, fragile, and prone to collapse. By brittle I mean it has the same chemical composition as glass, which in materials strength terms is perfectly elastic up to its yield point. Collapses of the Lost River chert are not slow subsidences, but catastrophic, often sudden, and are amplified in severity by the presence of undetectable solution cavities and caves in the Ste. Genevieve limestone and St. Louis limestone units above and below the chert. A dramatic example of catastrophic collapse is Wolf Sink, located near the proposed site. A more recent example is Grant-Palmore cave nearby that collapsed in the 1970s.

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General plans for the KTT include structures: a complete airport, industrial and office buildings, roads and streets, and a storm water runoff collection system piped to one or more central impoundments of water (pages 1-4; 4-25-26). The ponds will be drained by injection wells. The ITA has done no study of the structural competence of the Lost River chert, saying that any structural investigation will be made after the project is underway.

How can the ITA locate a point to drill such an injection well? To accommodate runoff from the entire site the well would have to intersect a main trunk drainage conduit. Despite claims to the contrary, the exact locations of the principal flow routes are unknown, according to the ground water basin maps published by the Kentucky Geological Survey.

For an example of impending irreparable harm, consider the EA plan to catch and retain runoff from the 796 airport acres in a detention equalization pond structure (pages 4-24; 4-50-52; 5-7). A storm drainage system collects and directs this water to the pond (page 5-4). A three-inch rain on 796 acres will produce 8,660,000 cu ft of water, and require a pond 600 feet wide by 700 feet long x 20 feet deep to hold most of the water. The weight of this 540 million pounds of water will almost certainly collapse the Lost River chert into any cavities or caves beneath it or collapse overlying rocks and the Lost River chert into such cavities.

Even a more modest pond holding a 3-inch rain from 40 acres would add 27 million pounds to the load. A simple sinkhole 50 ft x 50 ft dammed as recommended by the plan would concentrate 1.56 million pounds on the potential collapse area. In other words, the total weight of any holding pond is likely to contribute collapse pressure where the rocks are the weakest. On page 4-52 the EA admits, "dropouts could occur" even without recognition of the role of the Lost River chert.

Rocks are stronger in compression than in flexure. Collapses place surrounding rocks in flexure, and the flexure strength of the Lost River chert is insufficient to support the principal structure(s) described to mitigate the alteration in drainage. The pond will collapse, and cause irreparable harm from sudden flooding of the karst system, probably backing up groundwater and any lighter-than-water pollutants into the Mammoth Cave drainage basin, where it will cause irreparable harm. (N.B.: Throughout this response, the term Mammoth Cave karst drainage basin includes all discharges at Turnhole Spring, Echo River Spring, and Pike Spring on the Green River.)

What else will "drop out" or collapse (page 5-8)? Farmers in the area report ground collapse under the weight of a tractor wheel. The EA says the drains and piping must be watertight (page 4-54). Watertight pipes in areas of collapse will rupture and leak. Extensive grading and stabilization measures, and seismic events, as described on page 4-54, will subject weak rocks and cavities to sudden and uneven loading.

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Can public safety be jeopardized by major structural developments on top this unstable, weak rock unit? Will a passenger aircraft survive the collapse of part of the airport? Consider this excerpt from the Bowling Green Daily News Archive, March 15, 2001:. . . Arthur Palmer, water resources director for State University of New York, expressed concern about the "structural stability" involved in building a 7,000-foot runway "on cavernous rocks" and about the potential ground water pollution from airplane fuel.

ITA Environmental Committee member Jim Dinning took issue with Palmer's concerns.

"(The current) Bowling Green airport is located on the same kind of rock, and it collapses all the time," Dinning said.

If this astonishing statement from an ITA official is accurately quoted, will insurance underwriters be willing to assume the risks of building and operating aircraft and other machinery in this structurally weak terrain? Are not potential bondholders and ultimately public funds at risk when structural collapse takes place?

Dr. Arthur Palmer, a distinguished karst geologist, called this hazard to the attention of the ITA in a letter sent them on January 23, 2001. I called it to the ITA's attention at the same time. The ITA did not include either letter in the Appendices to the EA. In the EA and in public comments, officials of the ITA have observed that other airports are built upon karst terrain. Page 3-13 mentions several airports built on karst, but only one of these is actually built upon the fragile, structurally unstable and hazardous Lost River chert. At Oakland the soil is relatively thin. The nearly flat land surface is closely underlain by the Lost River Chert. This chert is interbedded with "flint", which is brittle, and the entire unit fractures easily, even though it is resistant to weathering.

Lost River Chert forms a thin shell covering voids, solution cavities and collapse-prone areas that are not detectable

The Lost River Chert sometimes forms a thin shell concealing and bridging voids. Geophysical surveys may detect shallow voids, but uncertainties render the technique unreliable. No geophysical methods can reliably find deeper voids. Thin interstratal voids are often missed. Arthur Palmer, in his May 8 letter to ITA, concludes that the absence of geophysical clues therefore does not verify the absence of voids.

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Collapse in the region takes place from the bottom up, not downward. Cavities develop along the routes of underground water flows and they enlarge upward by ceiling collapses. Such collapse may occur instantaneously and without warning. The so-called main trunk conduit streams pass under the runway, as shown on the 1981 regional subsurface drainage map prepared by Joseph A. Ray and James C. Currens, KGS, in 1998, based on studies originally conducted by James F, Qunlan and Joseph A. Ray in 1981. In other words, the runway is sited precisely where the risk of catastrophic collapse is concentrated!

Grouting of voids is impractical because underground water flows cannot be rerouted without the expectation of equally devastating outbreaks elsewhere. The water table lies 190 feet below Oakland. The total relief above the river is 180 feet. According to Palmer, depth to the water table is one of the most significant factors in assessing the potential for collapse; the greater the depth, the higher the risk.

How, then, can voids be detected? I have spent nearly 50 years of my life detecting subsurface voids in Mammoth Cave National Park. Literally hundreds of cavers have discovered, explored, and surveyed about 365 miles of passages. Cavers engaged in this comprehensive void-locating effort have identified about 7.3 miles per year. Borden and Brucker in their book Beyond Mammoth Cave predict that the world's longest cave will be found to be 1000 miles long by the end of this century, and will extend from near Munfordville, KY to near Bowling Green, KY. In other words, they assert that Mammoth Cave will be found to extend directly under the 4000 acres of the KTT. There are only two proven ways to detect voids and know their size: 1. Wait until the end of this century when the cave explorers reach the yellow site, or 2. Hire competent cavers to find, explore and survey the voids. Uncertainty about the location of voids under the 4000 acres makes the KTT project too risky.

EA asserts that other airports are built on karst, but they omit the details that explain the differences between those airports and this risky proposal

The Bowling Green Airport is located on the same strata, but it is only 90 feet above the nearest river - less than half that of Oakland. The water table is even shallower. Sediment cover masks many sinkholes in the bedrock surface, although subsidence does take place.

The Glasgow Airport is a small airstrip located on entirely different strata, the Salem-Warsaw formations. These are noted for their lack of prominent karst features because of their high content of insoluble materials. The "Glasgow Upland" has no sinkholes or sinking springs. The Glasgow Airport is 80 feet above the nearest river.

The Lexington Airport is located on older Ordovician limestones that have only poor karst development. Caves and sinkholes are small, and collapse problems are minor. Vertical distance to the nearest stream is 120 feet.

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The Somerset Airport occupies a karst-rich location that is susceptible to collapse, with large caves nearby. It lies 160 feet above the nearest river. However, the airport is a small strip sited at the edge of an escarpment. This is a setting in which collapse is least common, compared to Oakland or anyplace else on the Sinkhole Plain. The Somerset karst is subdued by a thick cover of residual sand and gravel naturally eroded from uplands nearby.

The Oakland site is far less stable than any of these four. In fact, the Sinkhole Plain is widely recognized for sinkhole development and is used to illustrate the process in dozens of geology books.

Finally, subsoil voids under the Lost River Chert cannot be detected unless exposed to visual inspection by stripping off all the layers of limestone and uncovering all the voids, or by sending in cavers to explore and survey the voids large enough to permit access. Even then, many small voids would be missed, whose volume may exceed that of the accessible voids by several orders of magnitude.

The ITA is threatening irreparable harm to the public and to the karst environment by failing to investigate the Lost River Chert and its general structural unsuitability and dangerous proclivity to collapse into voids. How can the ITA sell industrial industrial sites on fragile karst land without performing due diligence to safeguard buyers from irreparable harm?

Soil piping - the silent variation on sinkhole collapse

On page 5-9 the site is described as containing plastic soils with extensive grading contemplated. Plastic soil resting on collapse areas can be expected to flow or shift. Grading can be expected to expose more plastic soils that are then available to drop out and perhaps clog natural internal drainage channels.

What is the experience of airports built on karst where the Lost River Chert is not a contributing hazard? The Capitol City Airport in New Cumberland, PA was built on limestone. It was almost abandoned in the 1980s because of the danger of sinkhole collapse (Wilbur Smith and Associates, 1983, Belesky, Hardy, and Strause, 1987). In other words, neither the ITA nor its environmental consultants appear to recognize the danger and irreparable harm of building atop the Lost River chert unit of the St. Louis limestone, or any limestone karst for that matter. The Greenbrier airport in West Virginia is built on top of a karst plateau. That airport has experienced a continual and expensive effort to repair collapses and washouts. A karst area is a bad location for any airport.

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Cave passage pattern multiplies the collapse risk but is ignored by the EA

The EA states that cave passages in the vicinity of the KTT are restricted to three major conduits (pages 3-15; 4-50-51). This assumption is based on a misinterpretation of the 1989 regional subsurface drainage map prepared by Joseph A. Ray and James C. Currens, based on studies originally conducted by James F. Quinlan and Joseph A. Ray in 1981. While major cave conduits are vulnerable to collapse, Ray and Currens' arrows are conjectural guesses about where the water might flow, based on a small sample (less than 0.1%) of the actual flow as revealed in caves near Oakland. In other words, dye injection and recovery have identified the beginning and end points of the flows, but the water filled caves themselves have not been found, explored, nor surveyed.

Ray and Currens state explicitly in the explanation published with their 1989 map: "Although ground water flow routes shown here have been established by tracer studies, with the exception of mapped cave streams, the precise flow paths are unknown and are inferred or interpreted using water level data, geologic structure, or surface features." The fact that these cave passage locations cannot be pinpointed without study leads to the inevitable conclusion that the ITA has not performed due diligence to prevent irreparable harm due to potential catastrophic collapse, and has not understood the characteristics of cave patterns that create such weakness at this site.

Mammoth Cave, 6 miles away (not 8), has about 365 miles of explored and surveyed passageways (Borden, James D. and Roger W. Brucker, Beyond Mammoth Cave, SIU Press, 2000, p. 325). The cave passages are characterized by a dendritic pattern. Dendritic means "tree like" - with twigs, branches, and a trunk. No caves in the region exhibit a single conduit pattern, as the ITA describes for the Oakland site. The absence of tributary conduits and caves, as interpreted by the ITA from the karst ground water basin map, simply means that not every conduit was traced. It does not mean there are no caves or conduits in the area. In fact, every square inch of surface drainage is conducted through cave passages to the trunk conduits,

Distinctive and ubiquitous dendritic cave patterns render the site several orders of magnitude more likely to collapse than a single unknown conduit. Dendritic or branching pattern cave drainage has small conduits, as well as tributaries and diversion passages in addition to main trunk passages. Such passages are generally arrayed on several levels and constitute a three dimensional interconnected network of openings from the top of the limestone at the site to the lowest water filled passages in the St. Louis limestone. The potential for catastrophic collapse and irreparable harm might be partially verified in the field by a systematic program of geophysical core drilling, but no such prudent preliminary investigation has been undertaken nor is such proposed by ITA, prior to the irreversible step of land acquisition.

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KTT threatens irreparable harm to Mammoth Cave National Park

The ITA's EA mentions the possible threat to the environmental quality of MCNP (Mammoth Cave National Park) on pages 3-16; 4-27-28; and Sec. 4(f) of the DOT Act. In every case the ITA minimizes or dismisses outright threats to the underground environment with the statement that the Mammoth Cave drainage basin is upstream from the Graham Spring drainage basin.

The EA describes traditional methods of contaminant control of sudden spills. However, the greatest danger at airports and gas stations is the gradual buildup of contaminants from small, scattered spills that slowly degrade local water quality.

In this regard it is difficult or impossible to develop adequate containment, monitoring, and remediation strategies. The simplified diagrams provided in the EA of sinkhole plugging may work in a few karst areas, but are least likely to work in the Oakland area. Most sinkholes in the Oakland area formed by collapse and are floored by piles of leaky rubble. Sinkhole walls consist of thinly bedded strata that have highly transmissive bedding plane partings. Each is capable of leaking water. This leakage can be verified in caves of the region where every major bedding plane has hosted cave development at one time or another. Oakland sinkholes behave as rough stacks of assorted and warped plywood that do not stop water, instead of the sealable tight bedrock implied by the EA's diagrams.

The groundwater map by Ray and Currens shows the Oakland site to be at least 4 miles from the nearest divide to the north. This may seem a wide safety margin to protect against leakage into basins to the north. But divides determined only from piezometric data are valid only at the water table. Seepage above the water table is highly concordant with the bedding. Seepage follows the bedding plane partings rather than fractures. As the water drains downward it follows the dip of the beds, which the geologic map shows to be toward the northwest at Oakland.

However, very precise geologic leveling conducted by Arthur Palmer in Cave Springs Cave, near Smiths Grove, shows that the actual dip varies enormously in its local direction and degree of tilt. These variations cannot be detected from surface mapping because the rock outcrops are sparse and the elevations normally used by geologic mappers are generalized from contour lines on topographic maps. Descending water of this sort can travel down the tilt of the strata for several miles. Examples have been mapped in caves in this area.

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With more than 180 feet of depth to the water table around Oakland, contaminated water could travel down the less-than 0.5 degree dip slope with a horizontal component of 20,000 feet. This is roughly the estimated distance to the northern limit of the Graham Spring basin. In other words, contaminated sewage could cross over the rather uncertain divides between basins. Although such seepage might not enter the Mammoth Cave basin during low water flow, National Park hydrologists have amply noted that the divides shift with the stage of water. Low flow divides do not coincide with those at higher level flows. The EA's statement that the drainage from the Oakland site is confined to the Graham Spring basin is not appropriate without further dye traces at a variety of flow stages. Further biological implications of down-dip seepage of contaminants are described on page 14 of this response.

The Central Kentucky Karst, embracing about 150 square miles of this part of Kentucky, receives about 50 inches of rainfall annually. Rains of two or three inches are frequent. Six to eight inch rainstorms produce twenty-year flood events. Both the Barren River and Green River flood. During a flood, a surface stream reverses its gradient relative to water barriers. Underground streams similarly reverse their gradients during floods. The Graham Spring underground drainage basin floods and spills over into the Mammoth Cave drainage basin, carrying with it whatever pollutants may be mingled with the ground water. As the ITA's EA points out on page 3-15, pollutants can travel ten or more miles underground, without benefit of filtration or purification. However, in the specific case of Mammoth Cave National Park, the underground drainage basin has been studied extensively, its characteristics investigated and partially understood, and the potential for irreparable harm due to basin spillover established scientifically. Spills destroy underground life (pages 4-37-38).

Basin drainage spillover between Graham Spring and Mammoth Cave basins is verified by two dye tests

In addition to the seepage migration down dip, the EA mentions the existence of two dye tests that verify two-way spillover between the Mammoth Cave basin and the Graham Spring basin on pages 4-36; 4-50-51. Thus, it is only correct to say that the Mammoth Cave basin is "upstream" from the Mammoth Cave basin when there are no rainstorms. For a full discussion of basin interconnectivity and spillover see: Caves and Karst of Kentucky, Special Publication 12, series 11, 1985, Kentucky Geological Survey, University of Kentucky, Donald C. Haney, State Geologist and Director, Chapter 7 by Arthur N. Palmer, pp 98 and 104.

In summary, the regional underground drainage map prepared by Quinlan and Ray in 1981 shows a conjectured underground watershed "divide" between Smiths Grove, KY and Park City, KY. The dotted line shows their best guess of the location of basin boundaries during normal low water flows. This divide does not define the behavior of the watersheds during flood conditions, nor does it tell anything about the potential for down-dip seepage, but the two dye tests prove conclusively that two-way spillover does takes place.

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Spillover is a certainty, probability does not apply

The fact is spillover has happened, because at least two dye traces confirm occurrences. The evidence places the issue beyond possibility. A thorough scientific investigation of the behavior of this demonstrated spillover is required to safeguard against the irreparable harm caused by polluted Graham Spring basin drainage backflooding or seeping into and destroying underground life in the Mammoth Cave basin.

Arthur N. Palmer confirms this proved spillover damage potential on page 104 (Haney, 1985). Palmer has observed that the basin divide is migrating toward Graham Spring. Three facts are implicit in this observation: 1. The divide is being lowered and is becoming more prone to spillover than in the past, 2. The rate of lowering is greater near the divide than at any other location along the discharge route, and 3. The likelihood of catastrophic spills adversely affecting a larger area of the underground environment is increasing as time passes.

The bottom line is the basins do spill over, the divides do migrate, the divides are being lowered at an increasing rate, the bedding dip allows seepage for long distances. The EA ignores the fact that MCNP is within the hydrological sphere of influence of the proposed development site every time a heavy rain occurs.

All airports spill, dump, and contaminate

Airports have a long record of accidental or deliberate spills of fuel, anti-icing fluids, and other contaminants. Industrial plants have a similar history of spills of machinery cleaners, solvents, and other hazardous materials. The EA on pages 4-24-26; 5-55-56 describes the need for containment measures and rapid spill response and control capability, further confirmation of the environmental sensitivity and potential for environmental harm due to normal airport and industrial operations (page 4-50-57). However, no plans are mentioned beyond calling the local fire department.

In this karst region of Kentucky there have been spills of gasoline and explosive propane (page 3-15). A propane pipeline crosses the KTT site and must be buried deeper (figure 3-6; page 4-25-26). There have been petroleum product spills, a cyanide spill, and a massive dumping of whey and also electroplating heavy metals into the underground environment. Spills are the rule in this region, not the exception.

Spills in karst terrain can do irreparable harm. We cannot afford to pollute the Graham Spring basin ground water, Graham Spring basin karst environment, and by spilling or seeping over into the Mammoth Cave basin, cause irreparable harm to the MCNP underground environment.

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It is notable that in the Appendices to the ITA's EA, a letter from the Natural Resources and Environmental Protection Cabinet, Division of Water Review, page 4 specifically advises the ITA to use a karst hydrologist. No such expert appears on the preparer list in Appendix A. Karst terrain poses such severe fragility and unavoidable hazardous potential for irreparable harm that responsible planning requires specific expertise and disciplines that are not found in the content of the ITA's EA. Indeed, agency after agency cautioned ITA about karst problems, hazards and sensitivities. In terms of this karst site, and the mitigation proposed in the EA, agency advice has been largely ignored. It is absolutely uncertain that biological recovery could occur if and when damage takes place. Further documentation of ITA's ignoring of agency advice will be found in "Response to ITA's Environmental Analysis Appendices" (Hopper, H.L. and D. Bledsoe).

Examples of irreparable harm - a regional perspective on karst projects costing $21 million to "fix"

One does not have to go outside the region to find examples of karst environmental disasters. These major preventable projects cost an estimated $21 million to fix, far more than the initial project costs. In addition, there is a long list of regional spills and their consequences, two gasoline, one cyanide, one whey, one explosive propane. Each wiped out a major string of biodiversity in the underground environment. How long will it take to recover? In fact, recovery is uncertain. (Borden, James D. and Roger W. Brucker, Beyond Mammoth Cave, SIU Press, 2000, pp 223-25.)

By 1960 the National Park Service was operating a permitted sanitary sewage collection and treatment facility in Mammoth Cave National Park. Although, holding a valid permit, by 1975 the operator was violating all clean water standards. Eventually, after leaking untreated sewage into Mammoth Cave for years, the entire system was dug up and replaced. The biological consequences of this sewage system breakdown and bad design were that a few sewage-loving isopods thrived. Sewage generally benefits organisms that feed on such a rich diet who then proliferate and then, by predation, overwhelm and wiped out the natural species diversity of the affected locale. It should be observed that a "permit document" is an insufficient remedy for poor design. I estimate the cost of this remediation at $4 million. Ignore Karst; Build Now; Fix Later.

Starting in 1965 and continuing for 15 years, the National Park Service constructed and operated retainment ponds directly on top of the world's longest cave in Mammoth Cave National Park. Two of the ponds leaked raw sewage into the underground environment, killing cave terrestrial life in the effluent wake. When the damage came to light, the NPS demolished the ponds, killing trees and most remaining life in the ensuing flood. The NPS then constructed two larger ponds on the former site and described them as "sealed". These ponds also leaked raw sewage into the underground environment and were responsible for ongoing irreparable harm to the environment so long as they existed. Under threat of criminal contempt of court, NPS officials swiftly removed the ponds and surrounding developments to a less sensitive location on top of the Big Clifty sandstone. I estimate the cost of this remediation at $7 million. The developers and engineers of this expensive failure epitomized the dictum characterizing the region: Ignore Karst; Build Now; Fix Later.

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Also in 1965 the NPS decided to develop its own potable water supply for the Job Corps camp on Flint Ridge. They dammed Haney karst springs, built pump houses and a pipeline system to conduct water to several storage tanks. Karst scientists warned the NPS that the system would not work because it would provide an insufficient quantity of water in the summer when water demand was greatest. A biological census of the cave passage, Lower Gravel Avenue, before and after damming the springs showed a 70% to 90% reduction in biomass due to cutting off the water and its food supply. The above noted retention ponds leaked raw sewage into the spring system, contaminating the potable water supply. The NPS then abandoned the water collection system and paid to bring in a water line from outside the park. I estimate the cost of the abandoned water system at $1 million: Ignore Karst; Build Now; Fix Later.

The Glen Lilly Road Landfill site was operated by the city of Bowling Green between 1980 and 1992. This $4 million environmental disaster leaked into the underground environment from the beginning. The required remediation efforts are estimated to reach $6 million. The EPA requires monitoring of the leachate for 27 years, and the expense is born by the taxpayers of Bowling Green as a surcharge. The city developed the landfill site despite karst geologist and karst hydrologist warnings of karst contamination. The location was a political decision, and typical of the incompetence that has passed for engineering in Warren County, KY. Ignore Karst; Build Now; Fix Later.

The Louisville Road construction landfill received materials until 1987. CMD Federal Programs and TPM are completing a $1 million groundwater remediation filtration project. The location decision was political and typical of the incompetence that has passed for engineering in Warren County, KY. Ignore Karst; Build Now; Fix Later.

Lost River Cave, within the city limits of Bowling Green, served for years as a sanitary sewer system. Sinkholes in the city flooded and collapsed. Industrial discharges and explosive liquids polluted the cave system. I estimate $2 million has been spent in Superfund and other public money and private funds to clean up Lost River Cave, but it is still the main storm drain for the city. Sinkholes still flood and collapse. Ignore Karst; Build Now; Fix Later.

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East of Bowling Green, within the KTT site, lies a demolition landfill site grandfathered in under earlier land-use regulations. It was finally excavated to a depth of 65 feet. The ITA plans to place the demolished homes and outbuildings of 64 or 74 displaced families in this landfill located near the end of the proposed runway. The excavation reached a depth where it could encounter caves. Then, at the direction of concerned state agencies, the bottom was partially filled with loose rock to bring its bottom higher in the geologic column. This "filter" of leaky rocks without any liner guarantees that any leachate from the landfill will go directly into the cavern system below. No research has been performed to find the biota that will be affected when glass fiber insulation and other unknown substances are dumped there. What oversight is intended to monitor what is dumped at this location? We believe the answer is none, and when this landfill, too, pollutes the aquifer, who will pay for its remediation? Ignore Karst; Build Now; Fix Later.

Related questions may be asked and should be answered: Who owns the several landfills and their permits? Is there a conflict of interest relationship between owners and ITA personnel? If those with an interest in ITA are already developing and using these landfills, how does that square with statements in the EA about ITA doing all that is needed to protect the subterranean landscape? Hollow promises cannot protect the aquifer.

The question may arise as to whether "irreparable harm" cannot be repaired by removal of the offending development? We do not know, and herein lies the crux of the argument: Can we risk irreparable harm to the sensitive Mammoth Cave and the Sinkhole Plain karst environment, especially when our understanding of the risk is largely based on $21 million of bad engineering and non-engineering experiences suffered locally? What engineering "fix" could stop the unstoppable sewage leaks that plagued the storage lagoons in the park? The EA promises that various inevitable failures will be fixed by the best available methods. For this karst area, many identified problems simply have no practical fixes.

Ignorance of karst sensitivity and hazards is an unacceptable professional planning response by any developer -- but especially by a developer that has sought and already received public funds. The EA gives lip service to karst in general, but is woefully inadequate in discussing this particular karst and this specific set of hazards. It is not true that if you have seen one karst, you've seen them all. Doesn't a developer - private or public- have an obligation to safeguard the investment of its shareholders or the public against clearly revealed risk?

Corporate polluters declare bankruptcy and run away from cleanup

ITA must be required to post a significant bond to assure cleanup of bad engineering and karst water contamination. The reason for this is the disturbing history of corporations who pollute, then declare bankruptcy to escape responsibility for their misdeeds. In the case of the Glen Lilly Road landfill, the municipality could not declare bankruptcy, but since it also had a continuing revenue stream, citizens are bearing its cleanup cost directly. How many citizens are aware of this surcharge? Is the ITA a corporation or government authority? If it is a corporation, then it would be prudent to require it to post a multi-million dollar cleanup bond to hold it responsible. If the ITA is a governmental authority, then it needs to assure the public that taxpayers will ultimately fund the cleanup of an environmental disaster. If there is no bonding in place and if the ITA acts only as an intermediary, how will the public interest be protected when the finger pointing starts?

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Regional air quality already under stress

EA acknowledges (pages 3-13; 4-22-23) that the proposed site is deficient in meeting the proposed new EPA ozone requirements. Warren County and Edmonson County are 60 days in excess of current ozone standards. MCNP through its long range monitoring studies confirms the worsening air quality. MCNP's designation as a Class 1 Airshed allows no additional degradation of the air quality within 60 miles of the park. Will the KTT contribute to improvement of the air quality of MCNP, or further degrade it? At what point does deteriorated air quality become irreparable harm?

MCNP is the most popular national park and the only one wholly in Kentucky. It was bought and paid for by the citizens of Kentucky to preserve and interpret one of the foremost and finest collections of caves and other natural features in the world in perpetuity. Visitors to MCNP and the region contribute an estimated $100 million annually to the area economy. The prevention of irreparable harm to MCNP is a major national issue.

Irreparable harm threatened by low-level toxin pollution to long-lived cave organisms

A major threat to cave life is chronic low-level pollution, described elsewhere as little spills, the slow buildup of runoff contaminants, and the contaminants in air that descend to earth by dry deposition and rain. One such mechanism is described on pages 8-9 of this response. I will simplify Dr. Thomas Poulson's description of it to convey the main idea.

Toxin uptake by long-lived cave organisms involves ingestion, excretion, and detoxification. Since no organism is 100% efficient, there is a pyramid of energy from the base of the trophic level to higher trophic levels. As we move up the food chain of organisms that feed on other organisms, there is instantaneous biomagnification of toxin concentration along the chain. There is more toxin at the top than there is at the bottom of the food chain.

There is bioaccumulation through an organism's lifespan. Thus, toxins increase and accumulate higher in the food chain. Since cave organisms are long lived because of their need for efficiency with low food supplies, they are especially at risk.

The consequences of biomagnification and bioaccumulation can be seen long before the toxin builds up to lethal concentrations. Resistance to the environment decreases, reproduction suffers, and hormonal disturbances appear.

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Following a toxic spill or sewage introduction, there is a roller coaster of partial recovery and remobilization that can continue for many years. This adds to the biomagnification and bioaccumulation that occurs with chronic toxicity. In Hidden River Cave, at Horse Cave, KY, after the electroplating heavy metals dumping and whey dumping ceased, uncontaminated sediments buried the contaminated sediments. Some areas of the cave have been recolonized from upstream areas that were never contaminated. But with regular storms and 20 or 100 year floods, the buried sediments are re-exposed and again cause problems.

In summary, the long-range adverse effect of inevitable slow spills and big spills will be the degredation of the underground biota. This issue is never addressed in the EA.

State Environmental Assessment Officer, Timothy C. Kuryla, describes what the ITA must do BEFORE going after bond funding and land acquisition. The EA repeatedly says that such investigation and remediation will be done AFTER the bonding and acquisition. This is yet another example of the ITA's minimization or denial of agency guidance.

Irreparable harm threatens rare species already endangered and candidates under study

The EA discusses on pages 3-21; 4-37; 5-8 the existence of federally designated Endangered Species and also names species that are candidates for this designation (page 5-6). Letters from public agencies the Fish and Wildlife Service and other agencies attest to the concern regarding these species.

The troglobitic aquatic species on the endangered list is the Kentucky Cave Shrimp (Paleomonias ganteri), found by Leitheuser and others in the adjacent Mammoth Cave drainage basin and adjacent basins (http://endangered.fws.gov/i/k/sak04.html). Leitheuser specifically describes the underground environment in which the shrimp lives. The EA concludes on page 4-35-37, on the basis of a brief examination of the bottom of Mill Cave and Wolf Sink, that such environments do not exist in the Graham Spring basin. The ITA reasons that the absence of evidence that the shrimp's environment is present is evidence of absence of the shrimp. A thorough reading of Leitheuser's article reveals that he assigned top priority to investigating the range of the Kentucky cave shrimp in adjacent basins. He does not conclude that it is missing in the Graham Spring basin.

Researchers have found that suitable habitats for the Kentucky Cave Shrimp are present in the Graham Spring basin, contrary to what the EA asserts. Researchers have also observed organisms in those habitats that need to be identified. In other words, the EA assertion of missing habitat is neither sufficient nor competent regarding habitats known to be present..

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The point I make is that the basins regularly spill over, the same environments are present in several drainage basins including Graham Spring basin, and none of the EA preparers has ever seen the elusive Kentucky Cave Shrimp. A thorough and competent professional biological assessment by a person familiar with the shrimp and other organisms is required, and an EIS (Environmental Impact Statement) must be prepared if we are to avoid irreparable harm to this Endangered Species and any as-yet-unidentified new species. The ITA's EA falls far short of meeting the standards of an EIS in this regard. Section 16, USC 1540 G may provide the only remedy if the ITA proceeds without regard to proper professional investigation and contrary to the fact that organism habitats exist at or near the KTT site.

Other endangered and species under study threatened

Indiana Bats (Myotis sodalis), an Endangered Species, are found in caves in MCNP, six miles from the proposed KTT site. Would a competent, professional investigation reveal the presence of the Indiana Bat and Gray Bat within the proposed KTT site? We do not know, and the EA's assurance of "probably not" during August (page 4-39) is not sufficient safeguard where public money is being invested.

The Cave Crayfish (Orconectes pellucidus)(page 4-39), a species under active study and possible candidate for Endangered Species listing, is present in the Oakland area. It is also found in the caves of MCNP. It is a taxa that is especially vulnerable due to bioaccumulation and biomagnification of toxins. In Hidden River Cave, for example, decomposeable organic matter (whey) led to the replacement of trolobitic cave crayfish by facultative crayfish species. Glycol de-icers would produce a similar effect. ITA says they can mitigate threats to endangered species, but there is not sufficient information about candidates for anyone to say they can mitigate the danger.

On page 4-37 is a contradiction suggesting that the Kentucky Cave Shrimp at the lower end of the basin would somehow be more vulnerable than widely dispersed cave crayfish because of a "highly unlikely" point source spill. The EA concludes a spill would affect a narrow part of the system. Thus the unaffected parts would provide recolonization. We hold that the entire food chain is under threat from the KTT.

EA minimizes karst drainage problems AND invites irreparable harm

The Sinkhole Plain between Bowling Green and Munfordville in Kentucky is the most studied karst plain in the world. All of the rainfall penetrates the soil and is conducted underground by openings and sinkholes as vadose water descending to the zone of discharge, which is the vertical range of the water table. Below the seasonal water table the openings are filled with ground water in a phreatic zone where water that is not flowing is saturated or supersaturated with minerals.

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Technically, in the vicinity of the proposed KTT, there is virtually no runoff component to rainfall, as found in some karst areas and in all non-karst areas. There are no surface streams and no wetlands. All rainfall is conducted downward swiftly until the volume and rates of rainfall overwhelm the openings and sinkholes. At that point the water begins to back up and pond, like an unstoppered bathtub with both faucets running full on. Residents of Bowling Green experience such flood water backup during two or three inch rains, and major damage or even collapse in that city has taken place under such conditions. The city method of disposing of rainfall runoff from roads and parking lots is to channel storm water toward natural sinkholes. The narrow openings to the underground drainage are often clogged with dirt or brush, a natural consequence of paving and diverting surface water toward sinkholes. The city of Bowling Green recently purchased a new drilling rig to try to keep open its storm water injection wells in sinkhole bottoms.

The point is that severe damage, if not irreparable harm, is caused regularly by storm water in those developed areas of Bowling Green where alterations have been made to natural karst drainage.

We have described the potential for catastrophic collapse in the ITA's 796 acre airport site single storm water retention pond on the Lost River chert unit. Elsewhere in the EA (page 5-8) the ITA describes hypothetical mitigation structures to plug sinkholes and retard their rate of discharge into underground channels by means of concrete plugs, sand, and perforated standpipes. Why do the preparers describe such structures if their proposed main holding pond is adequate? This section admits that new "dropouts may occur", as if a collapse of a holding pond was an acceptable occurrence.

The proposed impondment structures will not hold water. Thus, the principal mitigating tool for control of drainage where there is no storm sewer system, will not function as intended. Artificially diverted water into sinkholes will also accelerate their rate of collapse. Sinkholes are a "damned if you do - damned if you don't" obstacle to development, a "lose/lose" hazard to any proposed structures.

Individual sinkholes collapse catastrophically

Geomorphologists generally agree that collapse and solution, usually working in concert, are the dominant processes in sinkhole development. The EA does not discuss in detail the processes that create and enlarge sinkholes. Solution of the limestone enlarges the openings, weakens the structural strength of the rocks, and results in continuous change in the configuration of a sinkhole through rock removal, soil removal, and the dominant process near Oakland, collapse. The EA's simplistic cross-sectional diagrams of sinkhole remediation structures ignore these facts.

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James F. Quinlan has described the disappearance of a multi-acre pond within hours due to collapse. Such sudden events are a normal occurrence in karst areas, despite their dramatic news value.

Soil piping produces cavities swiftly

We have observed that sinkholes collapse upward from the bottom. A more subtle process is called "soil piping" in which water flowing in a conduit wets the soil above the channel cracks. Mud slumps into the underground stream, forming a cavity in the soil. The cavity enlarges quickly creating a hollow. There is no surface expression, as in a filled sinkhole. Rather, the entire surface falls in. In Bowling Green there have been several instances of soil piping. In December 1999 at an apartment complex being built behind the Kroger complex near Nashville Road/Campbell Lane, a 15 to 20 foot hole opened literally overnight. Whether from soil piping or collapse, the entire 4000 acre site of the KTT is susceptible to these expensive surprises. It must be kept in mind that soil piping and collapse are normal karst occurrences, not anomalies.

For scores of years farmers on the Sinkhole Plain have tried to plug sinkholes by filling them with junk and trees. Such attempts are always unsuccessful for the same reasons that the ITA's proposed sinkhole remediation will not be successful. These so-called plugs appear to be effective in engineering drawings, but water will always find a way around any sinkhole plug, establish a flow route, and carry away the overlying soil. This soil is the natural foundation support of the runway and buildings. Soil collapse into a sinkhole is unpredictable, sudden, and sometimes massive. Imagine an aircraft landing on a runway with a minor dip in the pavement or small breach in the concrete. Similarly, a pipeline break under a building might not be noticed for days or weeks, sending toxic chemicals west toward the Barren River and Bowling Green. Surely Bowling Green, with its ample experience with toxic fumes and explosive caves, must know better?

Every square foot of the site drains into sinkholes, without exception

A table on page 3-11 of the EA purports to show the number and area of sinkholes on a 6000 acre set of quadrants that encompass the 4000-acre site. A cursory examination of the table leads the untrained viewer to the conclusion that there aren't many sinkholes and their area is not a substantial percentage of the total acreage. The table shows 456 sinkholes covering 796 acres, only 12% of the total area. Page 3-12-13 makes a spurious case of karst being a relatively unimportant issue, one solved by plugging downward openings and filling the depressions with clay or sand. No mention is made of the possibility of these foreign deposits washing away. No mention is made of the likelihood of foreign deposits to liquefy in the event of a seismic shock, such as an earthquake.

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One might further conclude from data as presented in the EA, that sinkholes cannot be a major problem if they are small, few, and far between. The table is deceptive. Apparently the preparers counted sinkholes by the number of depression contours shown on a topographic map. The USGS topographic map's contour interval is 10 feet, and the claimed vertical accuracy of that map is ± 1-1/2 contour intervals. Sinkholes are relatively shallow basin-like closed depressions, so the accurate count of sinkholes depends on field checks, not map study. Sinkholes as shallow as 30 feet might be missed altogether in an inventory based on topographic map data alone. Even more important, its rim diameter does not define the drainage capture area of a sinkhole as shown on a topographic map, but drainage capture can be determined only by field measurement. For example, a sinkhole described as 100 feet in diameter may have a drainage capture of 200 feet in diameter, with four times the area of the smaller diameter sinkhole.

However, attempts to minimize the sinkhole drainage problems with this site - whether deliberate or mistaken - are subject to the larger truth that all of the 4000-acre area is presently drained by sinkholes. No area within this site drains to anyplace except a sinkhole. This fact reinforces the point made by almost all agencies concerned with ground water quality: karst ground water basins are susceptible to massive and rapid pollution and that no natural filtration or purification takes place between recharge and discharge.

The EA acknowledges that a sizeable amount of filling and stabilizing and blasting will be required to prepare industrial and structural sites. See page 4-57. Up to 20 feet of fill and 10 feet of cut may be required. The EA hopes blasting may be done in such a way as to avoid cavities. How can cavities be avoided if geophysical methods of detection are not reliable? Page 5-4 describes storm water handling, but without mention of the weakening of the fragile karst surface that will take place with filling, blasting, and cutting. It does no good to cite "best management practice" when there is such a dismal record of failure on similar projects in this region. If the ITA were honest, it would admit that "best engineering practice" would be to not place significant construction on this difficult and hazardous karst terrain.

I told an experienced construction manager about the KTT site. He said, "There are some places that are just not good to build on. Contractors minimize conditions like these and say there's no problem they can't handle… They don't tell the rest, which is '…as long as there's an open checkbook.'"

The EA makes the point that the ground water of the Graham Spring basin is already contaminated with chemical weed inhibitor (page 3-15). And yet the state funded Watershed Watch baseline study in 2000 indicated high quality ground water. The data are available from the Division of Water in Frankfort, KY. Why the discrepancy in conclusions?

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Furthermore, the EA reports that aquatic fauna are abundant in Wolf Sink Cave, including the allegedly absent blind cave crayfish. A professional ground water quality investigation is required to determine the baseline water quality. It may provide a standard against which the ITA's good intentions may be monitored before land acquisition takes place, 64 or 74 houses and accompanying buildings are demolished, and the resulting demolition debris dumped in a permitted landfill that already penetrates the Lost River Chert on the 4000 acre site (Page 5-8).

The potential for irreparable harm to regional water quality is built into the ITA's hasty timetable to proceed irreversibly with plans to dump debris directly into the unprotected aquifer.

ITA's public process is deficient, faulty, and deceptive

Letters calling many of the above discrepancies to the attention of ITA were proffered at a January 23, 2001 meeting called to accept public comment on the project. None of the letters from karst experts appear in the Appendices to the ITA's EA, and there is no reliable assurance now that the ITA will make available to the public any listing of instances of potential irreparable harm called to their attention. In fact, there seems to be no willingness on the part of the ITA board, its organizers, or elected officials to take time to understand the staggering risks and costs associated with an ill-conceived plan on this problem-ridden site. Fix Later is a poor attitude to bring to taxpayers already suffering under the expensive consequences of preventable mistakes.

Public utterances by officers and the organizers of the ITA seek to establish three points in the public's mind: The first is that opponents of the KTT must be against the benefits of progress and out of step with the goals of economic development. Nothing could be further from the truth. The second is that their hired consultants simply disagree with claims of irreparable harm by opponents. Nothing could be further from the truth. The third distortion is that the general public is overwhelmingly in favor of developing the KTT on the Sinkhole Plain near Oakland. Nothing could be further from the truth.

As to the first issue, that of the benefits of economic development in the region, I submit that the individual opponents of this project reflect the full spectrum of opinion from No Development Now or Never, to Wise Economic Development Can be Beneficial.

The second issue, that of disagreement, is critical. Everybody has a right to be wrong in his or her opinions, but nobody has a right to be wrong in his or her facts. The facts are that neither the ITA board nor their EA preparers are karst experts. It is a fact that every karst expert familiar with the ITA's plan has identified irreparable harmful effects with this general KTT plan and its faulty environmental assessment. Every karst expert familiar with the ITA's plan has described overlooked environmental problems. Every karst expert familiar with the ITA's plan has exposed minimized deficiencies, unrealistic mitigation or remedial measures, or has found fault with a so-called public process that prevents the public from understanding the dangerous aspects of the plan. For an EA that supposedly cost taxpayers more than $800,000, one can only question who got their money's worth?

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Finally, ITA supporters have claimed that the public is in favor of the Airpark, even if the "wackos" are not. This is false. A scientific probability poll indicates most residents of Warren County support the benefits of development in general, but are opposed to the KTT for environmental reasons, even though they do not understand the details and are skeptical of the cost and politics involved.

My appeal, as a citizen of the United States and as Kentucky taxpayer, is that the ITA undertake a genuine Environmental Impact investigation process with competent, professional consultants. ITA must also engage in a genuine public review process rather than continue to press forward on a dangerous course of action that will certainly cause irreparable harm or trigger a legal train wreck.

Thank you for inviting this extended response to the ITA's EA.

Sincerely,
Roger W. Brucker

Copies to agencies listed in Appendices

Roger W. Brucker
brucker@graphtronics.net