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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA Chattooga for more than 35 years. Allowing boating on the Upper Chattooga will diminish the experience of those who already have been squeezed out of the Lower Chattooga due to overuse by boaters, and will spread the impacts of excessive boating access to another part of the River Corridor. Although the Environmental Assessment attempts to incorporate the concept of zoning into selection of the preferred alternative by limiting uses by space and by time, such zoning cannot be supported when, as discussed in greater detail, below, it does not consider the River as a whole. Georgia Forest Watch and Wilderness Watch contend that the current zoning, which allows boating on the lower Chattooga but not on the Upper Chattooga, is the appropriate zoning to address all users’ needs and concerns. (Ltr# 166, Cmt# 5) Subconcern # D E F All users may be asked to limit use in order to protect outstanding resource values. Wild and Scenic Rivers and wilderness areas are not recreational free-for-all zones. The need to protect the resource is adequate justification for the current zoning of recreational uses that the Forest Service has maintained over the years and for any of the other restrictions on user access proposed in the EA. The obligation of the Forest Service to protect the Wild and Scenic River and wilderness areas is so great that none of the alternatives to expand user access, including Alternative 12, has been justified adequately by the EA. Before any new recreational use may be made of one of these areas, management for the values for which they received these designations must be accomplished. Trailheads, trails, campsites, boating, and any other recreational use of the Forests may be limited to protect ORVs. Carrying capacity of a Wild and Scenic River is determined not only by the number of users, but also by the mixture of recreational and other public use that can be permitted without adverse impact on the resource values of the river area. Further, review of the biophysical aspects of the Upper Chattooga clearly indicates that steps must be taken to rectify the degradation that has been allowed to occur in the entirety of the Wild and Scenic River corridor. All of this should be addressed before new uses are allowed. The Forest Service should not permit any additional boating in the Chattooga River Corridor. The existing segmentation (zoning) of user groups should be maintained in order to protect the ORVs for all user groups, some of which are incompatible with boating. Existing boating opportunities are sufficient both regionally and on the Chattooga. On the Chattooga alone, boating dominates more than 60 percent of the corridor. On the other hand, opportunities for other recreational experiences (fishing, hiking, nature photography, swimming, hunting, solitude, bird-watching, botanizing and picnicking) on and along a whitewater river or stream of any significant size are limited. The boating prohibition has served the resource and its ORVs well for more than 35 years, during which time the Chattooga has become well known for backcountry fishing and interest in hiking into the Chattooga Cliffs, Ellicott Rock Wilderness and Rock Gorge backcountry has grown considerably. A unique fishing and wilderness experience would be lost if more intensive uses were expanded to the quieter portions of the River. The Forest Service must consider the legitimate needs of all users (and nonusers who value the existence of wilderness areas) in the Forest Service’s final decision--not just those of the most visible user groups (anglers and boaters). In considering the fairness of limiting one or another groups’ access, the Forest Service should consider how the needs of different user groups are met throughout the River Corridor, and not just on the Upper Chattooga. Boating on the Lower Chattooga may need to be significantly restricted, particularly if other users are driven off the Upper Chattooga and its tributaries. (Ltr# 166, Cmt# 6) Subconcern # E #481- These data suggest that private boaters actually have far less substitutes for the Chattooga River than do TU anglers and that banning boaters from the upper river serves to only further to limit the availability of quality recreation resources for this recognized and lawful user group (Ltr# 193, Cmt# 468) Subconcern # F #457- The EA clearly finds that encounter standards are already exceeded by existing users yet proposed no mitigation for these impacts. (Ltr# 193, Cmt# 444) Subconcern # G The Forest Service is unable to manage existing use of the River Corridor and Wilderness area without degradation. Pursuant to the Wild and Scenic Rivers Act, the comprehensive management plan is required to include actual measures of user capacities, such as limits on the number of visitors. Canoeing, rafting and kayaking use on the Chattooga River has already been identified as an example of where the “facilities and resources are being stretched to capacity.” Litter, sediment, and lack of solitude plague all parts of the River Corridor. If anything, the management of the Lower Chattooga should be modified to look more 232
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA like that of the Upper Chattooga—not the other way around. Before even suggesting additional boating, degradation of outstanding resource values caused by boating on the Lower Chattooga should have been examined closely in the EA. The ban on boating should only be lifted if the Forest Service is able to demonstrate that boating would “protect and enhance the values” for which the River was designated. If existing resource stress cannot be alleviated, boating might need to be restricted in sections of the River and its tributaries where it is presently allowed. It is not enough to show only that a use will not “substantially interfere” with the public’s enjoyment of river values. No uses (boating, fishing, or anything else) are “grandfathered” just because they existed at the time of designation unless it is stated explicitly in the river-specific legislation. (Ltr# 166, Cmt# 10) Subconcern # G #253- The EA makes no attempt to determine the quantity of recreation that the Upper Chattooga can sustain without adverse impacts. Instead, it assumes that the current level of recreational use by existing user groups is sustainable, and then concludes that nearly all additional use by boaters is not sustainable. This is not a fair and objective analysis of the carrying capacity of the Upper Chattooga River corridor. (Ltr# 193, Cmt# 244) Subconcern # G #321- We certainly applaud the agency’s recognition of the need to limit visitor access overall through the proposed limits on many groups’ access. But until the agency can show that these measure are effective and that conditions on the ground are improving it should not be authorizing an activity that is certain to cause more harm. We should not sacrifice an increasingly rare resource like Wilderness in order to promote more use. (Ltr# 193, Cmt# 311) Subconcern # H Visitor controls are not adequate under the Environmental Assessment or any boating alternative. Georgia Forest Watch and Wilderness Watch applaud the Forest Service’s recognition of the need to limit visitor access overall, and especially for taking the initiative to comprehensively propose limits on many user groups’ access where it is necessary to protect the resource. To ensure that ORVs are protected, Georgia Forest Watch and Wilderness Watch suggest going beyond the new limits proposed in Alternative 12 by limiting access to the Chattooga Corridor within the Ellicott Rock Wilderness to a maximum of 6-8 individuals per group on trails and 6 individuals in designated campsites (without exceptions for group campsites). We agree limiting anglers to four per group is appropriate (whether back-country trout fishermen or front-country anglers). Boating should be further restricted on those portions of the River (the Lower Chattooga) where it is taxing resource capacity. Prohibiting boating, horseback riding, and ATV use in the Upper Chattooga Corridor has preserved the wonderful, secluded area that exists there today. Now, additional management limits for hikers and anglers are warranted to guard against loss of the very elements that make this place so attractive; it certainly is not the time to expand user groups and intensify use, or to create new access and egress points to and from the river. (Ltr# 166, Cmt# 28) Subconcern # I The EA fails to exhaust indirect use limits before imposing direct limits. On page 39 of the EA, a monitoring plan is described that would limit uses first with indirect measures and subsequently with direct measures as necessary. This statement proves that the USFS understands their mandate in the FSM. This mandated use limitation technique however is applied only to non-paddlers whose existing impacts mar the corridor, while paddlers suffer from harsh direct limits before they have ever floated the river in all alternatives. Arbitrarily, capriciously, and inequitably applying direct limits to only paddlers prior to exhausting indirect measures is a direct violation of the Appeal ROD, the FSM, and any concept of fairness or reason. (Ltr# 168, Cmt# 9) Subconcern # I #411- The EA must ensure that ""direct controls and restrictions" be minimized, and that controls are to be applied only as necessary to protect the wilderness resource after indirect measures have failed (FSM 2323.12)." The EA does not, as it proposed unjustified direct boating limits prior to trying indirect measures. (Ltr# 193, Cmt# 399) Subconcern # I #436- None of these impacts can be attributed to paddlers, yet the USFS targets only paddlers for use limits. Choosing to manage proven real impacts with indirect management while managing unproven and 233
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