Frozen Head Statement


These comments are filed by the Harvey Broome Group of the Sierra Club, which operates in 26 counties in northeastern Tennessee, including Morgan County.

We thank Tennessee State Parks for engaging in long term planning for Frozen Head State Park and Natural Area (“the Park”), which we consider to be the jewel of Tennessee State Parks.  Although small compared to Great Smoky Mountains National Park, it provides many of the natural amenities of the Smokies without the hordes of tourists and automobiles.  Its single, developed campground and several backcountry campgrounds provide the wilderness solitude, quietness, and night sky darkness that is largely missing from other state parks.  The Sierra Club believes that it is important that the park system have some places that are not highly developed, to provide a wilderness experience far different from the development of hotels, golf courses, man-made lakes, and other developments so common at other state parks.

The Draft Management Plan states that the mission of Frozen Head State Park and Natural Area is “to protect and preserve the unique examples of natural, cultural, and scenic resources and to save one of the last vestiges of undisturbed landscapes in the Cumberland Mountain region,” and that Park management is intended to “restore and maintain the diversity and integrity of the resource.”  We fully agree with this mission statement and management objective.  

There is much in the draft Management Plan that furthers this mission, including support for and expansion of the feral hog management plan, the protection and conservation of neotropical and native birds, and protection of the native flora and fauna.  We also agree with the plan to make improvements to the existing toilet facilities, educational activities, and to build a new bathhouse at the Big Cove Campground.   The goal of ADA accessible campsites and toilet facilities can be accomplished in the Big Cove Campground and the existing picnic areas.

However, although it is not explained or justified in the draft plan, the major activity proposed for completion in the next decade appears to be to build an RV campground, with associated utilities, roads, and a check-in station at the Park’s entrance on Flat Fork Road in the Rocky Fork Field. We believe an RV campground is not appropriate anywhere in FHSP&NA, and particularly at this location, for the following reasons:
•    An RV campground is at odds with the stated mission of the Park since an RV campground will neither preserve nor protect the natural, cultural, and scenic resources.
•    Placement of the proposed RV campground and its infrastructure in Rocky Fork Field will directly interfere with current community use and enjoyment of the site as the staging area for the renowned and internationally recognized, annual, Barkley ultramarathon races, as a holiday event area for local community groups and churches, as a site for community volleyball games, as a frequent family use area for picnics and reunions, as a trailhead for a safe and quiet walking trail, and as an overflow parking area for the public during special Park events such as the annual Heritage Day.  For these reasons, the Rocky Fork Field is much valued by the local community and Park guests in its current state and should not be sacrificed.  If this RV park is built, it will seriously and negatively affect the goodwill the Park has developed with the local community, and it will be particularly annoying to the private homeowners who live near the entrance to the Park.
•    An RV campground in Rocky Fork Field will likely hamper access to the Ross Gap Trail for hikers not staying in the RV park, because the trailhead is at the east edge of the field and parking spaces may be taken up by RV spaces.  This will also hamper access to the Cumberland Trail because the Ross Gap Trail is a connector to the Cumberland Trail.
•    There is no sewer line servicing the Frozen Head State Park and Natural Area. It is unclear how sewage and wastewater from the recreational vehicles will be handled; the Rocky Fork Field soils are shallow, the area is prone to flooding, and either a dump station or a leach field will put the water quality of Flat Fork Creek at risk.  Flat Fork Creek adjacent to Rocky Fork Field is a TDEC water quality reference site for aquatic life in the Cumberland Mountains Ecoregion.  Sediment and other pollution from the RV site would put the integrity of this site at great risk.
•    A state-supported RV campground will compete with local private and commercial campground venues, several of which are developing near the Park.  A 75-unit RV park is under development at the former Brushy Mountain State Prison site.  A smaller RV park has recently opened on TN Highway 62 just south of the Park. Therefore, there is no need for one inside the Park.
•    A 20 to 25-unit RV park is not financially viable anywhere, let alone at Frozen Head.  Even if exorbitant fees are charged to rent a spot, the costs of managing and maintaining an RV park will cause the park system to lose money on this venture.  Park management has not presented any business plan for the RV park, let alone one that makes sense.  No analysis of benefits to costs has been presented to the public.
•    An RV campground anywhere in Frozen Head State Park and Natural Area will greatly disrupt the natural character and appeal of this rugged and primitive area that is mostly managed as Class I or II State Natural Area.
•    An RV campground anywhere in the park will add noise and nighttime light that will interfere with the dark-sky nature of the park.
•    An RV Park at the very entrance to the Park would be a gaudy example of commercialism at the entrance to what should be a wilderness experience for Tennessee citizens.

Instead of developing an RV park, the Sierra Club believes state money should be spent on other more urgent matters in the park:

One such need is an investment to restore the Tower Road Trail throughout its length. Tower Road provides essential connections to many trails throughout the Park but it is a gravel road that predates the Park.  It is frequently trafficked by Park vehicles and others. Although it is periodically graded, nearly all the drainage culverts are completely blocked.  Blocked culverts cause unregulated drainage in and adjacent to the roadbed, resulting in tremendous levels of erosion. Other culverts are far too long, resulting in dramatic erosional scars below them.  Also, the culverts often hang a foot or more above the drainage they empty into, making a barrier for migration of salamanders, reptiles, and small mammals.
The Management Plan notes that West Tower Road is in “poor” condition, and East Tower Road is in “fair” condition, but the Plan does not propose resolving their conditions in the next decade! The tremendous erosion of this road/trail undoubtedly contributes to sedimentation in the lovely streams that drain through Frozen Head State Park to Flat Fork Creek, which negatively affects habitat for fish and other aquatic species. We would like to see the RV campground funds redirected to remediating the dramatic erosion on Tower Road and creating a single-track trail to replace Tower Road in the hiking trail system.  

Some of the state funds should also be applied to restoration and partial re-routing of the Ross Gap Trail, which is also highly eroded and ridiculously steep.  This trail could be an important access to the new segment of the Cumberland Trail between Bird Mountain and the town of Wartburg, but in its present state, it is very unpleasant to traverse.  It should be rerouted with well-designed switchbacks and drainage culverts to prevent future erosion and sedimentation into the streams that drain that part of the Park.

Instead of building a new trail from Rocky Fork Field to the Visitor Center, including a bridge over Flat Fork Creek, the Park should develop a trail from Rocky Fork Field to the amphitheater at Big Cove Campground at an elevation above the floodplain of Flat Fork Creek.  This would allow for loop hikes on the Ross Gap Trail, the Cumberland Trail, and the Bird Mountain Trail.  The proposed trail through the floodplain and across Flat Fork Creek would cause harm to the vernal flora of the floodplain and increase sedimentation to the stream.  If a walkway is deemed needed between Rocky Fork Field and the Visitor’s Center, it could be developed by crossing the creek on the existing bridge and developing a walkway on the south side of the entrance road, away from Flat Fork Creek.

Finally, some additional state money should be spent on demonstrating and celebrating the activities of the CCC in the Park.  The CCC camp area along the Nature Trail should be partially cleared and appropriate educational signage or kiosks should be added to explain the history of their activities.  The CCC explosives shack along the Panther Branch Trail should be raised because it is dangerous, but it should be replaced with appropriate historical signage.

Thank you for this opportunity to comment on the draft Management Plan.   We urge you to keep Frozen Head State Park and Natural Area as natural as possible without sacrificing it to the commercialism of an RV campground.

Respectfully submitted,

Gerald A. Thornton, Chairperson
Harvey Broome Group of the Sierra Club
413 Sugarwood Drive
Farragut, TN 37934