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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 trail/road itself on sedimentation, and with regard to the traffic patterns any change in use or re-design may cause. (Ltr# 166, Cmt# 26) Subconcern # B I #368- The Forest Service has unlawfully artificially segmented its analysis of proposed management activities resulting in an insufficient NEPA analysis. The most serious omission from each of the alternatives--but particularly those where boating put-ins and take-outs would be necessary--is the lack of any analysis of access roads and trails and parking facilities. (Ltr# 193, Cmt# 358) Subconcern # C In regards to creating a trail to access a put in for kayakers being destructive to the environment, well how much complaining occurred when the environment was "destroyed" to put in an access trail for hiking, biking, camping, and fishing? Here is a simple idea: why not remove the access trail for fishing, hiking, camping and biking so that everyone including kayakers does not have a trail? That is fair isn't it? If an individual truly stands behind their beliefs that there is a negative impact to the environment by creating a new trail they would agree. There is actually a term used for it called zero trace hiking and camping. No trail, no sign that a person was ever even there. The Earth, this Nation, the states of Georgia and South Carolina, and the Chattooga River is for all of us to share, enjoy and protect and we each do it in our own way as individuals and sometimes as groups. (Ltr# 95, Cmt# 2) Subconcern # C #276- Existing trails within the riparian zone that accommodate current users will be closed but new trails to accommodate boating will be built and designated, AND additional user-created portage trails required -in ever shifting locations within the riparian zone-to accommodate boating will be added into the system. 27. This proposed trail policy is that Boaters get new trails of ever changing location and unlimited quantities, while other users get BANNED from many river sites. (Ltr# 193, Cmt# 267) Subconcern # D The EA proposes boating initiates at Greens Creek, without providing the details on how boats will arrive at this location. Without assessing the impacts associated with paddlers influx to the confluence of Greens Creek, it is impossible to comment on the proposed new access point. (Ltr# 109, Cmt# 2) Subconcern # D The last mile downhill to the Green Creek access point is described as “mostly an old road bed going down the river,” according to Nantahala District Ranger Mike Wilkins, who made public a map of this proposed access. Nothing could be further from reality. The “old roadbed” is totally overgrown with both underbrush and tall trees, and presents as an impassable and steep gully heading downhill. In sections, it is so deeply entrenched and cut down to bedrock as to have morphed into an ephemeral stream, with attendant sedimentation heading toward the Upper Chattooga. An angler’s rough trail also heavily covered by underbrush and downed trees and limbs, switchbacks over the old roadbed and does reach a smallish, steep rock jutting into the Upper Chattooga. It, too, is eroded down to bedrock along some portions and is visibly causing erosion downstream. The Green Creek Access proposal is a recipe for building a new trail access “in the reasonably foreseeable future” (EA, page 53) at an undetermined cost that would inevitably kill more wildness in this area. It does not appear to be well thought out. (Ltr# 141, Cmt# 6) Subconcern # D The EA depicts the Greens Creek entrance way as a “secondary road” located mostly on private property all the way to the mouth of Greens Creek (Figure 2). This leads to the question of whether the Forest Service intends to condemn a right of way for the public use. Moreover, there actually are roads that exist along the route shown, but they extend only for about one-third of the length. Part of this entrance way seems to be my driveway and its extensions through property belonging to the Cranston Family Partnership. Does the US Forest Service intend to provide any new road access at the Greens Creek putin? If so, where will it be located and what are the details of the facilities? (Ltr# 147, Cmt# 12) Subconcern # D The undated map and brief description titled “Potential Green Creek Access” that was distributed on August 5, 2011 attempts to offer some clarification, but fails in that regard, because it is incomplete and raises additional questions. The document is not presented as an amendment to the EA, but as the basis for 188
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA a “reasonably foreseeable future action,” as if the changes to the area do not rise to the level of importance that might influence the selection of an alternative in this EA. I believe that it does so rise, and complete analyses of the new put-in and its vicinity should be considered in this EA. (Ltr# 147, Cmt# 13) Subconcern # D The write-up states that the Greens Creek put-in “would probably be located slightly downstream of the confluence of the Chattooga WSR and Green Creek, the exact location would need a site-specific analysis and separate decision.” Depending on which “exact location” is selected, this issue might be pivotal in the current decision process. For example, if the route shown at the upstream (northeast) side of the crosshatched area on the map were to be utilized, it could follow an existing logging road and meet the river at an easy launch site with minimal impact. Routes elsewhere would be much steeper and difficult. Why does the US Forest Service not consider the effects of the new Greens Creek put-in in the Environmental Assessment? (Ltr# 147, Cmt# 14) Subconcern # D The map introduces further confusion. It does not show the present trail head and parking at all, nor the first mile or so of the trail itself. To my relief, it does not show the “secondary road” on my property to the mouth of Greens Creek as the EA does, but it does show a road from the Whiteside Cove Church (actually schoolhouse) through other private property. Does this mean that there will be a new access point from Whiteside Cove Road at that location? In addition, the map shows an access road to the river on the east side of Greens Creek through private lands (through the Cranston Family Partnership driveway and around Potato Knob on the Rust land). (Ltr# 147, Cmt# 15) Subconcern # D The EA proposes boating initiates at Greens Creek, without providing the details on how boats will arrive at this location. Without assessing the impacts associated with paddlers influx to the confluence of Greens Creek, it is impossible to comment on the proposed new access point. (Ltr# 174, Cmt# 2) Subconcern # D Ironically, the Forest Service asks for comments on this proposal to push boating up to Greens Creek without providing the public with any detailed information on the location of the new trail and/or parking facilities, and only provided to those so requesting a trail map terminating 100 yards from the river and 250 yards below Greens Creek. The paucity of information regarding this new access raises numerous questions. Where is the new trail? What parking facilities would be needed? Is the proposed site suitable for access? Where is the cost/benefit analysis of extending a new trail up river to Greens Creek from the current trail? What are the direct, indirect and cumulative effects of this part of the agency’s proposed alternative? And the obvious question, how can the public comment on a proposal it knows so little about? (Ltr# 175, Cmt# 3) Subconcern # D #160- The draft EA is inconsistent with the upper put-in. Some sections of the EA state the upper put-in will be “4/10 of a mile below private property” others state “just below private property”. This needs clarification. (Ltr# 193, Cmt# 153) Subconcern # D F K There are several significant problems and issues with the new Green Creek access, not the least of which is that the Agency has issued two different maps of this proposed access. The first, made public by Nantahala Ranger Mike Wilkins at the behest of the Sumter National Forest Supervisor, starts at the existing Forest Service parking lot on Whiteside Cove Road. The second, quietly added to the Sumter website with no public notice on August 5, shows the access emanating from private property at Whiteside Church (also known as the Summer Chapel) on Whiteside Cove Road. There are problems with either proposed access. The Whiteside Cove parking lot, where boaters would park to begin their portage to the river, is so small with only room for about seven or eight vehicles. As a result, hikers and other pedestrian visitors would bump into the many boaters who would come to this area under the Alternative 12 proposal. The second map proposes to have access coming from private lands at the Summer Chapel along a usercreated trail behind the church. There is no public parking available at this location. Whatever access point on Whiteside Cove Road is used, the last mile downhill to the river access below Green Creek is described as “mostly an old road bed going down the river,” according to Wilkins, in a private e-mail communication with Georgia Forest Watch of July 18, 2011. Nothing could be further from reality. The 189
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