Dear Editor, Mayor and City Council Members,

As a resident of Lookout Mountain, I am writing to express my deep concerns regarding the upcoming vote on the zoning text amendments (Ordinance No. 292) intended to permit aerial ropeway passenger conveyance systems. While Rock City has publicly stated its intent to cap annual visitorship at around 800,000, the official engineering data and infrastructure design submitted to the town tell a completely different story about the true scale of this project.

I urge the Council to carefully scrutinize the data within the Kimley-Horn Traffic Assessment, explicitly titled "Rock City Gardens Gondola Development," which was prepared for PGAV Destinations. The sheer volume of traffic (and thus visitors) modeled in this report suggests an infrastructure built for massive commercial expansion, far beyond what our mountain community can absorb.

In the report, on Page 21, the site owner [Rock City Enterprises - Doug Chapin] provided the average weekday traffic that was estimated to be 3,150 trips to and from Rock City on Ochs Highway - with 2,800 trips to be diverted to St. Elmo/Hwy 193.  When annualized, the daily trip numbers presented in this assessment break down into the following capacity matrix (calculated using the, below, industry standard of 1 vehicle = 2 trips, and an average of 3 passengers per vehicle):

Kimley-Horn Traffic Study Volume Matrix

The 3,150 Daily Trips Metric: Rock City/Ochs Hwy Total

1. Total Annual Trips: 3,150 daily trips × 365 days = 1,149,750 annual trips

2. Total Physical Vehicles: 1,149,750 trips ÷ 2 (1 trip ascending, 1 trip descending) = 574,875 unique cars

3. Total Annualized Visitors: 574,875 cars × 3 people per vehicle = 1,724,625 annual visitors

The 2,800 Daily Trips Metric: Rerouted to St Elmo/Hwy 193

1. Total Annual Trips: 2,800 daily trips × 365 days = 1,022,000 annual trips

2. Total Physical Vehicles: 1,022,000 trips ÷ 2 (1 trip ascending, 1 trip descending) = 511,000 unique cars

3. Total Annualized Visitors: 511,000 cars × 3 people per vehicle = 1,533,000 annual visitors

Mathematical Validation Loop (The Reverse Proof)

To ensure mathematical absolute consistency, the totals derived above are run in reverse to perfectly close the statistical loop back to the exact initial metrics without rounding decay.

Verification Status: Closed and Verified. The mathematics reconcile perfectly.

Justification of Planners’ Standards & Industry Citations

The formulas applied above are not arbitrary; they rely strictly on established state and federal transportation engineering criteria:

• The 2-Trip Rule (Complete Circular Loop): As defined by the Institute of Transportation Engineers (ITE) and the Federal Highway Administration (FHWA), a vehicle "trip" represents a single, one-way movement. Because a commercial attraction is a primary destination, every inbound vehicle inherently produces an initial "Attraction Trip" entering the corridor and a secondary "Production Trip" exiting it. Therefore, daily trips must always be divided by 2 to yield the true number of physical vehicles.

• The 3-Person Tourism Occupancy Standard: Data compiled by the National Household Travel Survey (NHTS) demonstrates that while daily commuter vehicle occupancy sits closely to 1.1 persons, Social and Recreational travel spikes to a national average baseline of 2.1 to 3.0+ persons per vehicle. For family-centric paid tourist landmarks (such as See Rock City), transportation planners routinely employ an Average Vehicle Occupancy (AVO) of 3.0 to appropriately scale parking and safety infrastructure.

This traffic matrix proves that the proposed infrastructure is structurally designed to handle up to 1.72 million annual visitors - nearly triple Rock City's current 600,000 baseline. Furthermore, it plans to systematically route 1.53 million annualized visitors directly through the St. Elmo and Highway 193 corridors to Blowing Springs Farm. Six critical factors prove that this project is heavily over-engineered for more than a 800,000 visitor cap, indicating a clear, long-term blueprint for an highly expansive transit/amusement park:

• The Unreleased 9-Phase Master Plan: Local media reports indicate that this gondola project is merely Phase I of a 9-Phase Master Plan for the attraction. Rock City has not publicly disclosed the remaining eight phases of their long-term development to our residents, even though they have retained theme park design firm PGAV Destinations to spearhead the layout. By crunching Rock City's numbers, we get a glimpse of the magnitude of how many visitors RCE wants allowance for and to attract in those next phases. 

• The Standalone "Gondola Only Ride" Strategy: Rock City’s plan to offer "Gondola-Only" standalone tickets proves this is a transit network and by decoupling the ride from the garden trails, they can scale passenger volumes indefinitely without being limited by the physical capacity of the gardens and walking trails. Furthermore, by terminating their contract to operate CARTA's Incline Railway, Rock City is actively clearing the competitive landscape to capture, funnel, and profit off volumes well beyond their stated 800,000 tourist cap.

• Massive 180+ Acre Land Footprint: Rock City controls over 180 total acres primed for commercial development across Lookout Mountain City/Walker County lines. This includes 151 acres in Walker County, Georgia (encompassing the Blowing Springs Farm/Mountain) and over 30 acres within Lookout Mountain City. This sprawling acreage provides more than enough physical space to build a full-scale amusement park complex equipped for sightseeing, shopping, dining and entertainment.

• The Parking Lot Scaling Math: Blowing Springs Farm is slated for an initial 1,200 parking spots, with acknowledged plans to expand up to 2,500 spaces. When you consider that Rock City’s current upper mountain lot already contains more than 700 parking spaces (2100 visitors), adding a 2,500-space valley footprint represents an astronomical jump in capacity. At 3 people per car, a 2,500-space lot holds 7,500 people at a single moment or if flipped twice, 15,000 daily visitors on a busy weekend day.  Can Rock City Gardens and our community handle this many visitors when it dwarfs anything the current infrastructure has ever had to accommodate? 

• The Expandable Doppelmayr Gondola System: While Rock City states the system will launch with only 12 cabins (900 people per hour), the foundational machinery is physically overbuilt and engineered with the technical capacity to seamlessly scale up to 40 cabins or 2000 people per hour. This allows them to nearly quadruple mechanical transit capacity at any time without needing new tower approvals. 

• The Broad Zoning Text Amendment Loophole: The proposed rule change is a permanent text amendment adding "aerial ropeway passenger conveyance systems" as a permitted use. Because the law uses broad, plural terms like "systems" and "infrastructure," any future additions, expanded terminals, or extra cable lines would be permitted automatically. Rock City would never have to return to the City Council for approval for future expansions nor would any future corporate owner.

While traffic engineers use high variables as a baseline, passing a permanent zoning text change based on these massive metrics grants a structural green light to a project scaled for 1.72 million annual tourists. Why is this Council voting on a zoning amendment for an infrastructure footprint that scales nearly double their public tourist number of 800,000?  Why would a council after reviewing the evidence of "scaling up infrastructure" choose to vote "Yes" on an amendment with unlimited "systems" and "infrastructure" when it would not only take away the voice of friends, family and neighbors but our respected City Council Members of today and tomorrow as well?

The Planning Commission already voted 5-2 against recommending these zoning updates and since then even more convincing information has become available. I ask that the City Council honor that recommendation in order to protect our community and the historic character of Lookout Mountain. Vote "NO and vote NO with no conditions" on the proposed zoning text amendments.

Thank you for your time, leadership, and dedication to protecting our community.

Sincerely,

Penny Simmons
Turnberry Lane