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