My blog last week on the National Park Service?s economic impacts of its Final Environmental Impact Statement has generated some interesting comments and a good discussion.
I wrote last week that the Outer Banks Chamber of Commerce is seeking businesses that participated in an economic survey on impacts. The businesses contacted by RTI International were kept confidential, and the chamber would really like to know more about them.
You might be interested to know that the chamber has heard from one business that confirmed it participated, and two that think maybe they did, that someone called them a long time ago and asked economic questions.
Maybe more will surface.
The discussion on the blog eventually branched out to include how the Park Service will pay for the new infrastructure that is required under the FEIS ? new ramps, parking areas, pedestrian trails, soundside accesses, and interdunal roads.
The question was raised by Dennis Gray, aka Denny in Dayton, who asked:
I think the bigger question now is with the Federal budget cuts, what happens if the proposed alternative?s facility/roads/ramps construction can?t be funded? The proposed budget now has an $81 million cut in NPS construction (yet includes an additional $360 million for land acquisition, what does that tell you about the NPS direction?) Will they propose something they can?t execute?
Ted Hamilton, aka Salvo Jimmy, wrote:
You?ve raised a good question.
Can NPS legally put the restrictions of Alt F in place with no plan to provide in a timely manner the funded improvements required by Alt F such as additional ramps, interdunal roads, parking, etc.?
And Mike Berry responded with this:
The new ORV Management Plan (CFR Regulation) calls for new construction?parking, ramps, etc. Without that new costly construction the NPS is in violation of its enforceable regulation. Funding for such projects in NPS nation-wide looks pretty bleak these days. This funding issue is going to get interesting and Judge Boyle and SELC just might be in the national seashore management business for a while to come?now there?s a happy thought. Plenty of work for lawyers at taxpayer expense.
Actually, the issue of how these improvements ? and other requirements called for in the FEIS ? will be funded is still very murky, and does raise many interesting questions, not all of which the Park Service can answer ? or wants to answer ? at this point.
At a meeting with reporters in mid-December, Cape Hatteras National Seashore Superintendent Mike Murray talked in general terms about the new infrastructure and how it would be funded.
?We have designed the plan so that we don?t need additional base funding,? Murray said. ?We got a good increase (in base funding) after the consent decree.?
Murray said the park was now developing information about infrastructure improvement costs.
?The director (of the National Park Service) and the assistant director are aware that we need one-time start-up costs?It seems that we have support from Washington and Atlanta for the funds.?
Murray acknowledged the problem with ?tight budgets,? but added that the Park Service has tried to design a ?realistic? infrastructure improvement plan and that some of it can be accomplished at a low cost.
Deputy Seashore Superintendent Darrell Echols followed up that December conversation with an e-mail yesterday.
?We continue to operate under a Continuing Resolution until March 4, and as a result, we do not have details related to either the FY11 or FY12 budgets,? Echols said. ?Both are being reviewed and discussed by Congress and the President, but until they determine final budgets, we are unable to provide any specifics. We simply do not know.
?As for the infrastructure improvements identified in the FEIS, the NPS continues to pursue various funding opportunities to implement these,? Echols continued. ?We continue to anticipate that a combination of base funding and primarily ORV permit funds will be used to implement the improvements??
Now comes the really interesting part.
Echols also wrote that ?additional environmental compliance in the form of an EA (Environmental Assessment) is needed before these improvements can be made.?
And he said the actual improvement costs will be determined during the EA development.
So, there must be yet another environmental study before the park can make the infrastructure improvements that are required by the FEIS ? or even know how much they will cost.
At the December meeting, Murray said park officials are hoping that one Environmental Assessment can be done to cover all of the improvements.
Also at the meeting, Cyndy Holda, the park?s public affairs specialist, added that the requirement for another environmental study was an irony not lost on park officials.
If this entire process had been completed when it was first required in the 1970s, another Environmental Assessment would not have been required.
It?s worth noting that an off-road vehicle plan was written and sent to Washington in 1978. But it was never finalized and published in the Federal Register.
Echols also answered a question about ORV permits and fees in his e-mail.
?Final ORV permit costs have also not been determined due to the budget uncertainty,? he said. ?Whenever we have a final budget and obtain a clearer picture of the future, we can finalize the permit costs.?
Murray is still saying publically that a proposed ORV regulation will be made public this winter, that there will be 60 days of public comment, that the Park Service will take several months to assemble and respond to public comments, that a final rule will be issued late this summer, and that the rule, including permits, could be implemented as soon as fall.
Personally, I agree with Mike Berry when he says that federal Judge Terrence Boyle and the Southern Environment Law Center will be managing the seashore for a while to come.
There seems to no end to this rulemaking nightmare.