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 />
allowing other uses unlimited access. In addition the only boating that is allowed is in the winter while<br />
other uses are allowed year round access. (Ltr# 193, Cmt# 407)<br />
#420- Inequity and bias permeates the EA, and is stated up front in section 1.1.2. The need for action states<br />
that "The unique angling opportunity that exists on the upper Chattooga needs to be carefully managed"<br />
whereas "Opportunities on the upper Chattooga for whitewater floating need to be evaluated as an<br />
enhancement to the whitewater boating recreation experience and its effects evaluated." Angling is painted<br />
as something "unique" to be "managed" whereas boating is seen as an "enhancement" which needs to be<br />
scrutinized. This is not equal treatment and forms the basis for the entire flawed EA. In the end, angling is<br />
not limited at all and boating is virtually banned. (Ltr# 193, Cmt# 408)<br />
#421- Boating is addressed as a binary question of whether or not to institute the harshest possible<br />
management or not: "Should there be additional boating opportunities in the Chattooga River Corridor<br />
(above Highway 28)?" This is misleading in itself, as the word "additional" implies that there is already<br />
some boating, when in fact there is none. All other recreation, including larger and more damaging uses,<br />
are addressed only through considering indirect limits in the case that boating is allowed. This difference<br />
can only lead to inequitable treatment of user groups. The EA does not ask, "should there be hiking,<br />
camping, angling, or stocking," nor does it ask "what is the capacity for each of these individually, or<br />
collectively." (Ltr# 193, Cmt# 409)<br />
#444- "Although [dispersed and developed recreation opportunities] can have potential impacts to riparian<br />
corridors, they are allowed because the majority of forest users prefer to recreate in or near bodies of<br />
water. (EA 29). The EA’s answer is essentially that some recreational impacts are OK because recreation<br />
is generally good for society - except apparently paddling. This double standard permeates the EA and is<br />
arbitrary and capricious. (Ltr# 193, Cmt# 432)<br />
#447- Figures 3.3-1 and 3.3-2 exemplify the EA’s misdirected focus on management of only paddling. (Ltr#<br />
193, Cmt# 435)<br />
#448- The bias of the EA is perhaps nowhere more obvious than Figures 3.3-1 and 3.3-2. These figures<br />
label impacts of non-boaters as "boating does not cause standards to be exceeded" while labeling boating’s<br />
potential contribution to standards as "boating causes standards to be exceeded." Instead, the labels<br />
should read: "non-boating uses’ contribution to days of standards exceeded," and "boating’s contribution<br />
to days of standards exceeded." This is critical for two reasons. First, the EA attempts to focus attention<br />
exclusively on the (miniscule) role of paddling on causing encounters, while ignoring the (massive) role<br />
that existing users play in causing encounters. Second, the EA ignores the fact that no one person, group,<br />
or recreational type of use "causes" encounters: encounters occur when two individuals or groups meet.<br />
(Ltr# 193, Cmt# 436)<br />
#488- The Record of Decision on our appeal confirms that if use is to be limited it must be limited<br />
equitably. The EA, the alternatives, and the preferred alternative are not equitable. (Ltr# 193, Cmt# 475)<br />
Public Concern 67<br />
The <strong>Forest</strong> <strong>Service</strong> should consider the following regarding the Bullpen Road<br />
Bridge frontcountry area:<br />
A) Prohibit boating above this area;<br />
B) No trails should be built above the bridge;<br />
C) Permit boating below this area and restrict by flow levels; and<br />
D) Fly fishing is acceptable at flows as high as 600 cfs in this area.<br />
Response to PC 67<br />
A) See Environmental Assessment, Managing Recreation Uses in the Upper Segment of the<br />
Chattooga Wild and Scenic River, Chapter 2 for alternatives that prohibit boating above Bullpen<br />
Bridge, and Chapter 3 for the analysis of these alternatives.<br />
B) Any trail construction would be done under a separate and site specific analysis (including<br />
additional public involvement) to mitigate impacts to the social and natural environment.<br />
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