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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA the rate of population increases for the region, which may exceed 20% over the next decade” (Whittaker and Shelby 2007). The forests are seeking to take appropriate action now to reduce existing or prevent future unacceptable impacts to the river’s values from increasing use levels, and thus preserve the river’s free-flowing condition, protect water quality and protect and enhance the river’s outstandingly remarkable values in addition to protecting its wilderness characteristics. Sample Public Comment(s) for PC 62: Subconcern # A The proposed alternative eliminates restrictions on boating in North Carolina, without assessing the associated impacts of such action. Where in the EA are the restrictions on boating in North Carolina? If there are none, where is the assessment associated with the elimination of the current boating restrictions? (Ltr# 92, Cmt# 24) Subconcern # B It's true that a minority of boaters drag their boats. I think making putting a ban on boat-dragging would be a wonderful idea. It really seems that so few people drag boats in the first place and the ones that do drag would honor a drag-ban. But if boat dragging really did turn out to be a problem, which I doubt it would, there are solutions to that. Some places use a pair of close-together hand rails (like those you see on stairs) that paddlers can place their boat across and walk to the river without the boat touching the ground or having to be carried. (Ltr# 97, Cmt# 2) Subconcern # C Given that, there are several compromises that can be made to allow access to boaters and the other traditionally allowed river users (fishermen and hikers). To protect the resource, the following criteria must be adhered to: No construction of additional trails to create new access points; No boating above Hwy 28 unless the Hwy 76 USGS gauge is >= 3.0 feet at some point on the day that the boating takes places; Boating parties should be kept to six people or less; No inflatable crafts that are designed to hold more than 2 people (i.e., no rafts, only inflatable kayaks); and No more than 50 boaters should be allowed per day – this could be enforced by having a sign in log in addition to the permit so that other potential boaters would know that the limit had been reached. If these restrictions are kept in place and enforced, the resource will be protected and the wilderness experience of other river users will be kept to an acceptable level. It is time to admit the no boating clause on these upper sections was done in arbitrary manner and that there acceptable uses on these sections other than just fishing and hiking. The primary goal should be to protect the resource, not just the current human experience. These restrictions allow both. (Ltr# 120, Cmt# 1) Subconcern # D The Preferred Alternative will encourage the expansion of existing unauthorized boating. The EA fails to consider the likely increase in unauthorized boating on the Upper Chattooga that will result if any boating is allowed. Were the Chattooga opened for some boating use, unofficial guidebooks and information on the Internet and by word of mouth about its course would become more commonplace. A known river is available to more skill levels because challenges can be anticipated. Also, as the River becomes more familiar to some boaters who use it legally, they may want to run it on other days of the year when it is illegal to do so. Anyone familiar with boating on the Lower Chattooga knows what unregulated (or unmanaged) boating is likely to look like: it would be comparable to Section 4 of the Lower Chattooga, where maximum use can exceed 180 boaters a day in the summer and reach as high as 100 boaters a day from January through April. Even “low use” days see anywhere from 10 to 50 boaters a day. This demand is particularly out of proportion to the boating proposed in Alternative 12, which sets no limits on the number of boating trips per day or the numbers of boaters that would be permitted on the Upper Chattooga or the possibility of boaters establishing new campsites along the more remote stretches of the headwaters. This will present a significant enforcement challenge and threat to the resource. The Forest Service must consider the likely increase in illegal boating under any alternative allowing boating in segments of the River where it is currently prohibited. If any part of the Upper Chattooga is opened to legal boating, some boaters will be spurred to greater use of the River, whether legally or not. As the River becomes more 148
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA familiar to some boaters who use it legally, some will likely want to run it on other days of the year when it is illegal to do so. If boaters become familiar with Headwaters sections, their desire to float it will also grow, and at least a few can be expected to give in to the temptation to float it on days when it is not permitted. Under no circumstances should the use of inflatable kayaks and tandem kayaks, as proposed under Alternative 12, be permitted, and illegal use should be severely fined. Inflatable craft are rented routinely to the public by commercial outfitters, and would introduce an inappropriate commercial element to the Upper Chattooga, particularly since it is the stated aim of the “preferred Alternative” to “prohibit commercial boating on the upper river.” To the extent any boating is allowed, such boating must be limited to single capacity hard boats to discourage use of more remote and technical segments of the River Corridor by less experienced boaters and will decrease the need for rescue and search-and-recovery efforts. (Ltr# 166, Cmt# 29) Subconcern # D #366- The Draft EA fails to consider the likely increase in unauthorized boating on the Upper Chattooga that will result if any boating is allowed. (Ltr# 193, Cmt# 356) Subconcern # E Boaters may choose to repeatedly run certain spots on the upper Chattooga. This further elevates the potential for undesirable encounters and hence displacement. There is no mention in the EA of this encounter problem or how it might be resolved. (Ltr# 171, Cmt# 31) Subconcern # F #69- The appeal decision did not limit that analysis to human-powered boats, why did the USFS make this arbitrary decision? (Ltr# 193, Cmt# 63) Subconcern # G #81- A new points we need to emphasize regarding the Headwaters of the Chattooga is that the anthropological and cultural evolution of the pirogue, dug-out, canoe, kayak, and sea-kayak are all culturally evolved as an adaptive behavior directly resulting from the need to travel, fish, and hunt in order to survive. It is illogical and contrary to the laws of nature to separate the essence of an adaptive creation, the kayak, from its actual intended use, which is as a fishing and hunting craft. Private boating on the Headwaters of the Chattooga is a logical human response to a genetic predisposition for boating, fishing, and hunting. A sound cultural basis directly links the worldwide co-evolution of these small types of personal boats with subsistence fishing, hunting, and travel, and they have been in continuous use worldwide for at least 12,000 years. It would be a crime against nature to deprive man of the use of publicly owned rivers for boating and fishing in such a small and unobtrusive conveyance as a kayak. (Ltr# 193, Cmt# 74) Subconcern # G #347- You must acknowledge the results of the boating study which clearly demonstrates that boating remains an important and outstanding form of recreation on the Headwaters that must be protected and enhanced under the law. (Ltr# 193, Cmt# 337) Subconcern # H #121- In reality, only a handful of boaters have the skills to paddle the upper reaches of the Chattooga, therefore limiting the population. (Ltr# 193, Cmt# 114) Subconcern # I #135- Using a commercially-rafted stretch of river (i.e. the lower Chattooga) as validation that allowing paddling (a fully Wilderness-compliant form of travel) on remote and hard-to-access (due to distance or variable flow) streams will cause resource degradation is absurd. (Ltr# 193, Cmt# 128) Subconcern # J #149- The USFS failed to complete a competent study of boating and its effects in the Chattooga Headwaters to support any ban or restrictions. (Ltr# 193, Cmt# 142) Subconcern # K #150- The assessment’s failure to adequately emphasize the huge amount of private boating allowed elsewhere during boatable periods leaves the decision-maker with the mistaken impression that there is 149
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