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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA guilty. Due process of the law. Heard of those concepts? They’re only some of the principles that the fabric of this nation is made up of. (Ltr# 193, Cmt# 93) #103- All impacts of boating were painted in a VERY negative light, whereas the continued impact of all fishing related activities were glossed over. (Ltr# 193, Cmt# 96) #120- In the study, it becomes readily apparent that any time where boaters may have even a remote chance of using the resource when an angler may be present that the angler is given unfair preference. (Ltr# 193, Cmt# 113) #124- Recognizing that boating is a legitimate form of recreation where it is appropriate, it must be noted that if it seems unfair for some sections to be open to boaters and fishers while some are open only to fishers, it must be noted that the activities of fishermen do not interfere with boating. In contrast, the activities of boating on waters of the size of the upper sections of the Chattooga would totally disrupt a fisher’s recreation for a major portion of a day. (Ltr# 193, Cmt# 117) #197- Even a cursory review of the EA reveals a strong bias against boating. Throughout, the EA treats the existing profile of user types and levels as the baseline for the upper river, and makes no serious effort to reexamine whether this profile is fair or sustainable. Instead, it presupposes that the existing user profile will remain unchanged, and then asks and answers the wrong question: Can boating can be added to the existing user profile without adversely affecting the resource or the user experience of existing users? (Ltr# 193, Cmt# 189) #207- The EA arbitrarily singles out "fishing" as a best use of these waters to be supported, ignoring other best uses including secondary and primary recreation (for the waterbody segment in North Carolina) which includes boating uses. This 'weighting' of one use, and subsequently one user-group, is unfounded particularly in light of the fact that all of these uses were considered to contribute to the value of naming this segment as a National Wild and Scenic River segment which also subsequently contributed to its designation as a North Carolina Outstanding Resource Water. (Ltr# 193, Cmt# 199) #229- This seems inequitable and unacceptable to single out one user group for exclusion from a public forest and Wild and Scenic waterway. (Ltr# 193, Cmt# 220) #268- I, as a private, self-guided whitewater paddler, have been displaced exclusively to the lower river since 1976 where I must contend with some 40,000 commercial users a year! Where’s my opportunity as a paddler for the cherished back country experience and solitude provided by the upper Chattooga River? (Ltr# 193, Cmt# 259) #328- Unjustified restrictions and bans are illegal according to the Wild and Scenic Rivers Act and the Wilderness Act. Restricting and banning boating without similar measures being applied equally to other user groups is simply unfair and discriminatory. Boaters deserve equal protection under the laws. (Ltr# 193, Cmt# 318) #329- Nothing in the Wild and Scenic Rivers Act supports discrimination in favor of one user group against another. While it is true that anglers consider the upper reaches of the Chattooga River to be unique, offering pristine environmental conditions, beauty, and solitude, those very characteristics are among those that whitewater paddlers seek and enjoy. To maintain this public resource for the benefit of fishermen, and the exclusion of paddlers, has no basis in fact, law, or public policy. (Ltr# 193, Cmt# 319) #356- I don’t claim to know the "capacity" of the Chattooga River for boating use but I do know it is not zero! It is far greater than zero. Any decision that bans or limits boating is simply not defensible based on the data in the record. (Ltr# 193, Cmt# 346) #357- You cannot make a decision to continue the illegal boating ban based purely on local public sentiment (or outcry) over this issue. This is not a local issue and this is not a private resource. This is a National Wild & Scenic River! (Ltr# 193, Cmt# 347) #419- The EA, the alternatives, and the preferred alternative are not equitable. Each alternative proposes to radically limit or ban paddling use while other uses are virtually unlimited. The preferred alternative is predicted by the Forest Service to allow only six days of boating, and acknowledges that only 3 of them would actually be available to paddlers. Three days of paddling versus 365 days for other uses is not equitable. Even worse, the preferred alternative totally bans boating on two thirds of the river, while 174
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA allowing other uses unlimited access. In addition the only boating that is allowed is in the winter while other uses are allowed year round access. (Ltr# 193, Cmt# 407) #420- Inequity and bias permeates the EA, and is stated up front in section 1.1.2. The need for action states that "The unique angling opportunity that exists on the upper Chattooga needs to be carefully managed" whereas "Opportunities on the upper Chattooga for whitewater floating need to be evaluated as an enhancement to the whitewater boating recreation experience and its effects evaluated." Angling is painted as something "unique" to be "managed" whereas boating is seen as an "enhancement" which needs to be scrutinized. This is not equal treatment and forms the basis for the entire flawed EA. In the end, angling is not limited at all and boating is virtually banned. (Ltr# 193, Cmt# 408) #421- Boating is addressed as a binary question of whether or not to institute the harshest possible management or not: "Should there be additional boating opportunities in the Chattooga River Corridor (above Highway 28)?" This is misleading in itself, as the word "additional" implies that there is already some boating, when in fact there is none. All other recreation, including larger and more damaging uses, are addressed only through considering indirect limits in the case that boating is allowed. This difference can only lead to inequitable treatment of user groups. The EA does not ask, "should there be hiking, camping, angling, or stocking," nor does it ask "what is the capacity for each of these individually, or collectively." (Ltr# 193, Cmt# 409) #444- "Although [dispersed and developed recreation opportunities] can have potential impacts to riparian corridors, they are allowed because the majority of forest users prefer to recreate in or near bodies of water. (EA 29). The EA’s answer is essentially that some recreational impacts are OK because recreation is generally good for society - except apparently paddling. This double standard permeates the EA and is arbitrary and capricious. (Ltr# 193, Cmt# 432) #447- Figures 3.3-1 and 3.3-2 exemplify the EA’s misdirected focus on management of only paddling. (Ltr# 193, Cmt# 435) #448- The bias of the EA is perhaps nowhere more obvious than Figures 3.3-1 and 3.3-2. These figures label impacts of non-boaters as "boating does not cause standards to be exceeded" while labeling boating’s potential contribution to standards as "boating causes standards to be exceeded." Instead, the labels should read: "non-boating uses’ contribution to days of standards exceeded," and "boating’s contribution to days of standards exceeded." This is critical for two reasons. First, the EA attempts to focus attention exclusively on the (miniscule) role of paddling on causing encounters, while ignoring the (massive) role that existing users play in causing encounters. Second, the EA ignores the fact that no one person, group, or recreational type of use "causes" encounters: encounters occur when two individuals or groups meet. (Ltr# 193, Cmt# 436) #488- The Record of Decision on our appeal confirms that if use is to be limited it must be limited equitably. The EA, the alternatives, and the preferred alternative are not equitable. (Ltr# 193, Cmt# 475) Public Concern 67 The Forest Service should consider the following regarding the Bullpen Road Bridge frontcountry area: A) Prohibit boating above this area; B) No trails should be built above the bridge; C) Permit boating below this area and restrict by flow levels; and D) Fly fishing is acceptable at flows as high as 600 cfs in this area. Response to PC 67 A) See Environmental Assessment, Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River, Chapter 2 for alternatives that prohibit boating above Bullpen Bridge, and Chapter 3 for the analysis of these alternatives. B) Any trail construction would be done under a separate and site specific analysis (including additional public involvement) to mitigate impacts to the social and natural environment. 175
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