Resource Name (Heading 1) - USDA Forest Service - US ...

Summary of Public Comments - Managing Recreation Uses in the
Upper Segment of the Chattooga Wild and Scenic River Corridor EA
predicted to be significant, the EA discusses at length how the impacts vary with the amount of paddling
allowed under each alternative. For example see page 339. This is of course purely an artifact of how the
alternatives inequitably vary only paddling, thus masking the fact that the numbers of visitors is the
variable driving impacts, not the number of visitors paddling. An example of this flawed and biased logic
can be found on page 343, where the EA states that “All three alternatives [8, 14, and 11] have the
potential for more boaters and, therefore, the potential for more [ginseng] collection pressure than the
other alternatives.” Obviously boaters have no more interest in ginseng than anyone else, and probably
have less. Another example is the presumed impacts to black bears, which anglers and hikers are equally
or more likely to disturb, and hunters are allowed to chase, shoot, and kill in the same area. A similar
example is presumed impacts to brook trout which the USFS is wiping out through stocking non-native
trout, and anglers are allowed to catch and kill. It is unclear if any of the EA’s biased and unfounded
claims regarding biophysical impacts have anything to do with the USFS decision to select Alternative 12.
They should not, as they are each arbitrary and capricious, wholly unfounded, inequitably applied, and an
artifact of an inequitable range of alternatives. (Ltr# 168, Cmt# 34)
Subconcern # G L
#396- The Draft EA does not adequately address the impact of the various alternatives on the entire Wild
and Scenic River corridor, Ellicott Rock Wilderness, the Sumter, Nantahala, and Chattahoochee National
Forests, and the regional recreation experience. The narrow scope and segmentation of the project (see
below) present a misleading view of recreation opportunities in the region. Another type of segmentation
leading to inadequate environmental review pursuant to NEP A is the failure to consider the management
of the entire River Corridor in developing alternatives. As already discussed, the failure to adequately
emphasize the huge amount of boating allowed on the Lower Chattooga leaves the decision-maker with the
mistaken impression that there is some deficiency in boating opportunities in the Wild and Scenic River
Corridor. (Ltr# 193, Cmt# 384)
Subconcern # G L
#452- By not including other recreationists in the action alternatives the EA is in violation of NEPA. (Ltr#
193, Cmt# 440)
Subconcern # H I
The Forest Service EA does not address the reason for withdrawing the original decision for managing
recreation uses in the Upper Chattooga River in 2009. In the original decision, the Forest Service chose to
allow boating with no restrictions on the number of boaters allowed, whereas the original EA and
accompanying Biological Evaluation (BE) were based on a preferred alternative when boater numbers
would be restricted. These documents—the original EA & BE—were withdrawn, and are therefore moot.
Consequently, the USFWS and the public do not have a BE for the Upper Chattooga EA, to consider in
making comments on the current EA. While the biology of the Upper Chattooga is an extremely important
ORV, the fact is that the Forest Service never mentions or addresses this important inconsistency in the
current EA. If the USFWS cannot make a determination in the absence of a BE, then it is certainly a
violation of NEPA to ask the public to make this important decision and determination without all the
important information contained in a BE available. (Ltr# 172, Cmt# 9)
Subconcern # J
Even worse, the area between Sliding Rock and Green Creek is apparently ignored which guarantees
conflict between trout fishing and boaters. (Ltr# 188, Cmt# 2)
Subconcern # K
#157- The agency should make the final EA complete by adding the data collected but not included in the
assessment or document the assessment shortcomings. The agency should focus on the evidence in front of
them not just data from the AW recommended consultant, but also studies, facts and other credible
government documentation that is captured within the public record. (Ltr# 193, Cmt# 150)
Subconcern # L
#236- Biophysical impacts related to soil, vegetation, the riparian environment, river bottom, etc. from
existing users (trash, fire circles, trampling riparian areas, fishing lines and lures hanging in the trees etc.)
is not addressed. Existing uses are not subject to the same analysis as boating. This is a significant
technical flaw in the EA that results in an unbalanced assessment of recreational activities. (Ltr# 193,
Cmt# 227)
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