Resource Name (Heading 1) - USDA Forest Service - US ...
Resource Name (Heading 1) - USDA Forest Service - US ...
Resource Name (Heading 1) - USDA Forest Service - US ...
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Summary of Public Comments - Managing Recreation Uses in the<br />
Upper Segment of the Chattooga Wild and Scenic River Corridor EA<br />
reflect a new decision based on findings”. In Chapter 1 of the EA, Section 1.4 Decision To Be<br />
Made, it notes that the decisions are specific to the upper segment of the Chattooga WSR.<br />
Management of the Chattooga WSR below Highway 28 was not challenged in the appeal of the<br />
2004 Sumter RLRMP and is not subject to further review. Management activities are considered<br />
within the context of the entire Chattooga WSR and are analyzed in the cumulative effects<br />
sections in Chapter 3.”<br />
Sample Public Comment(s) for PC 41:<br />
Subconcern # A<br />
Responding to American Whitewater’s 2004 administrative appeal, the <strong>US</strong>FS published the 2005 Appeal<br />
Decision. The Decision directed the Regional <strong>Forest</strong>er to “conduct the appropriate visitor use capacity<br />
analysis, including non-commercial boat use, and to adjust or amend, as appropriate, the RLRMP to reflect<br />
a new decision based on the findings.” The 2005 Decision acknowledged that “No capacity analysis is<br />
provided to support restrictions or a ban on recreation use or any type of recreation user. While there are<br />
multiple references in the record to resource impacts and decreasing solitude, these concerns apply to all<br />
users and do not provide the basis for excluding boaters without any limits on other users.” The Regional<br />
<strong>Forest</strong>er was directed to consider all users and any type of recreation, not limit assessment to those<br />
initiating the appeal. The Decision did not limit the Visitor Capacity Analysis to non-motorized boats, this<br />
was an arbitrary decision made by Sumter <strong>Forest</strong> <strong>Service</strong> in an arbitrary and capricious manner without<br />
public review. The Decision directed the Regional <strong>Forest</strong>er to “ensure that all potential users have a fair<br />
and equitable chance to obtain access to the river.” The initial 2007-2008 NEPA scoping did not adhere to<br />
the Appeal decision because some users were not represented in the capacity analysis that was conducted<br />
in conjunction with, and at times by, American Whitewater. (Ltr# 126, Cmt# 5)<br />
Subconcern # A, F<br />
#486- American Whitewater has reviewed the environmental assessment (EA) titled: "Managing<br />
Recreation Uses on the Upper Chattooga River" in detail and offers comments in this document. The EA<br />
does not comply with NEPA on very basic levels. The EA does not meet the mandate of the Record of<br />
Decision (ROD) for our appeal of the 2004 Revised Land and <strong>Resource</strong>s Management Plan (RLRMP), and<br />
fails to contain a user capacity analysis as required by the ROD. The EA is deeply biased and makes many<br />
massive leaps in logic with no supporting information. The EA and its preferred alternative violate the<br />
Wilderness Act and the Wild and Scenic Rivers Act. American Whitewater does not support the EA or its<br />
recommendations. (Ltr# 193, Cmt# 473)<br />
Subconcern # A, F<br />
#495- The EA does not comply with NEPA on very basic levels, and all alternatives violate the Wild and<br />
Scenic Rivers Act and the Wilderness Act. The EA does not meet the mandate of the ROD for our appeal of<br />
the RLRMP, and is not, nor does it incorporate, a user capacity analysis. The EA is deeply biased and<br />
makes many massive leaps in logic with no supporting information. The EA follows closely in the footsteps<br />
of the discredited RLRMP in that it offers few facts, many opinions, much discussion, finds no significant<br />
impacts of allowing unlimited paddling, and then proposes to ban virtually all boating anyway. Also like<br />
the RLRMP, the EA is not equitable in its treatment or proposed management of Wilderness compliant<br />
recreational uses. American Whitewater does not support the EA or its recommendations. (Ltr# 193, Cmt#<br />
482)<br />
Subconcern # B<br />
In addition, the Decision did not limit the analysis of to the Chattooga above highway 28, in fact it required<br />
the <strong>Forest</strong> <strong>Service</strong> to ‘adjust or amend’ the entire RLRMP for the Sumter forest based on the findings of the<br />
analysis and to consider ‘nearby rivers’. A review of boating most certainly includes the Chattooga below<br />
highway 28. (Ltr# 126, Cmt# 6)<br />
Subconcern # C<br />
By limiting analysis to the kayakers ‘request for relief’, the <strong>US</strong>FS has conducted their assessment in an<br />
arbitrary and capricious manor, in contradiction to the 2005 Agency Remand Decision, and outside of the<br />
NEPA statutory guidelines. (Ltr# 126, Cmt# 8)<br />
Subconcern # D<br />
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