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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA Act, the WSR act, and NC state water laws protecting ORW waters. Environmentally damaging parking cannot be considered available capacity. (Ltr# 92, Cmt# 34) Subconcern # C The Chattooga Wild and Scenic River was designated to protect and enhance opportunities for public recreation. Mistakenly, the 1976 Chattooga Development Plan published that “motorized use is impractical because of the shallow water and rocks.”(id FR 11849). Justified by faulted logic, the USFS banned access of motorized craft to any section of the Chattooga River in 1977. Similar to the complaints from American Whitewater, this 35 year-old statement is inaccurate. The Chattooga has always provided interim opportunities for motorized boating during times of higher flows, this natural flow regime would also limit motorized boating to those brief times that flows were high enough to accommodate motorized boating. Because of these natural limits, motorized boating use will be minimal. (Ltr# 126, Cmt# 1) Subconcern # D No new infrastructure is needed if all boats were allowed equal access. The boat ramp and parking facilities located on Section II and at Tugaloo Lake, already provide the necessary infrastructure to accommodate launching boats onto the Chattooga. These are public boat ramps that were built to accommodate boating for citizens using taxpayer dollars, restricting access to only groups suing the Forest Service would be arbitrary and capricious. (Ltr# 126, Cmt# 4) Subconcern # E How does the USFS plan to deal with the impact to this highly sensitive ecosystem of boaters accessing the river after heavy rains? No consideration is given in the EA to resource impacts after heavy rains. The Chattooga River above the Steel Bridge is one of the most fragile ecosystems in the entire Appalachians. Indeed, some of the trails that run through this terrain are home to rare and exotic plant species that are particularly susceptible to uprooting when displaced by foot traffic after heavy precipitation. Because this section of the Chattooga is unnavigable in low water and has extremely steep ledges and drops in high water, boaters will only attempt trips after heavy rains. Not only will this action result in likely rescue missions, but all activity will take place when the roads and trails are most easily eroded. The EA claims that use of these roads is the primary source of sediment into the river, while simultaneously increasing use of the roads at the time when sediment run-off is most likely. Furthermore, the Forest Service handbook recommends unpaved roads be closed while susceptible to erosion, while the proposed policy expands access during these time the roads are most likely to erode into the stream. Unlike hikers who park once, boating requires shuttling between access points, often doubling and tripling road and trail use per visitor. How can the Forest Service reconcile such contradictory policy? (Ltr# 136, Cmt# 2) Subconcern # F Boating is a different activity by orders of magnitude. Whereas hikers and anglers, who can move quickly with their minimal gear, or campers who are relatively stationary, can move to designated trails with relative ease, boaters have a lot of gear, and won’t be able to access egress points when the necessity comes on them such as in quickly rising waters. With the closing of user-designated trails, this only gets more complicated. The agency’s preferred proposal to initiate boating at or just below the confluence of the Upper Chattooga and Green Creek is fraught with problems, and likely would forever destroy the wildness of that area. (Ltr# 141, Cmt# 4) Subconcern # G #182- You acknowledge that USFS has not fulfilled its duty to assess conditions in the area, but you then turn the presumption of access on its head by claiming that boaters cannot be allowed on this section until an environmental assessment has been done. The ROD requires the opposite presumption. You must ALLOW access in these circumstances, and may restrict access “only with adequate evidence of the need for such restrictions.” ROD at 6. (Ltr# 193, Cmt# 174) Subconcern # H #202- public should have the right to float on public Wild and Scenic Rivers regardless of who owns the land along the river (Ltr# 193, Cmt# 194) Subconcern # H 142
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA #331- Floating on waterways that are National Wild and Scenic Rivers should not be prohibited regardless of who the landowners are along the river. (Ltr# 193, Cmt# 321) Subconcern # I #311- Some boaters get a thrill out of getting into their boat and sliding down the bank into the river. This creates areas that funnel water and promotes erosion of the river bank and concentrates drainage from the surrounding river bank. It also kills all vegetation where the boats slide down. (Ltr# 193, Cmt# 301) Subconcern # I #312- Dragging boats up and down the bank is as destructive as cattle drinking in the river. (Ltr# 193, Cmt# 302) Subconcern # J #385- Access to the Chattooga River Corridor should remain by foot only and only on numbered Forest Service trails. This is consistent with the original Wild and Scenic River plan for the Upper Chattooga which says that "[tJhere will be no construction of new roads. All existing roads will be closed and stabilized at the corridor boundary" for wild areas (Ltr# 193, Cmt# 373) Public Concern 59 The Forest Service should not permit commercial boating on the Upper Chattooga River. Response to PC 59 Commercial boating is not considered in any of the alternatives. See EA Chapter 2. Sample Public Comment(s) for PC 59: Please help us preserve the Upper Chattooga River at South Carolina and Georgia. We all enjoy this river and want to keep it as wild as possible to help protect wildlife and the environment. I hear that another 8+ miles of river may be opened up to public/commercial use. Please do not allow this. (Ltr# 15, Cmt# 1) Feel free to ban commercial rafting. (Ltr# 85, Cmt# 2) To further buttress this point, if solitude seeking were a fundamental and irreplaceable concern of the whitewater running experience among the overall user group, why doesn’t the American Whitewater Association’s lawsuit demand more restrictive commercial permitting on the lower Wild and Scenic Chattooga to eliminate the excessive number of folks (40,000 to 70,000 per year) using the river? This would reduce the number of unacceptable interpersonal encounters that degrades the sense of solitude on the lower Wild and Scenic Chattooga. Why not prohibit all commercial whitewater rafting on the lower Chattooga in order to restore the balance of solitude that the self-guided kayakers assert that they need from the upper Chattooga? (Ltr# 171, Cmt# 7) Do not degrade this outstanding resource by allowing commercial activity of any kind. (Ltr# 189, Cmt# 3) Public Concern 60 The Forest Service should not permit local outfitters to rent boats for use on the Upper Chattooga River (comment from 2009 EA comment period). Response to PC 60 The prohibition of commercial boating is continued in all alternatives. However, activities on private land are outside the scope of this analysis. Sample Public Comment(s) for PC 60: #583- To further protect the resources, add the stipulation that local outfitters should not be allowed to rent boats (inflatable or hard boats) for use on the upper Chattooga. (Ltr# 193, Cmt# 570) 143
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