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 />
like that of the Upper Chattooga—not the other way around. Before even suggesting additional boating,<br />
degradation of outstanding resource values caused by boating on the Lower Chattooga should have been<br />
examined closely in the EA. The ban on boating should only be lifted if the <strong>Forest</strong> <strong>Service</strong> is able to<br />
demonstrate that boating would “protect and enhance the values” for which the River was designated. If<br />
existing resource stress cannot be alleviated, boating might need to be restricted in sections of the River<br />
and its tributaries where it is presently allowed. It is not enough to show only that a use will not<br />
“substantially interfere” with the public’s enjoyment of river values. No uses (boating, fishing, or anything<br />
else) are “grandfathered” just because they existed at the time of designation unless it is stated explicitly in<br />
the river-specific legislation. (Ltr# 166, Cmt# 10)<br />
Subconcern # G<br />
#253- The EA makes no attempt to determine the quantity of recreation that the Upper Chattooga can<br />
sustain without adverse impacts. Instead, it assumes that the current level of recreational use by existing<br />
user groups is sustainable, and then concludes that nearly all additional use by boaters is not sustainable.<br />
This is not a fair and objective analysis of the carrying capacity of the Upper Chattooga River corridor.<br />
(Ltr# 193, Cmt# 244)<br />
Subconcern # G<br />
#321- We certainly applaud the agency’s recognition of the need to limit visitor access overall through the<br />
proposed limits on many groups’ access. But until the agency can show that these measure are effective<br />
and that conditions on the ground are improving it should not be authorizing an activity that is certain to<br />
cause more harm. We should not sacrifice an increasingly rare resource like Wilderness in order to<br />
promote more use. (Ltr# 193, Cmt# 311)<br />
Subconcern # H<br />
Visitor controls are not adequate under the Environmental Assessment or any boating alternative. Georgia<br />
<strong>Forest</strong> Watch and Wilderness Watch applaud the <strong>Forest</strong> <strong>Service</strong>’s recognition of the need to limit visitor<br />
access overall, and especially for taking the initiative to comprehensively propose limits on many user<br />
groups’ access where it is necessary to protect the resource. To ensure that ORVs are protected, Georgia<br />
<strong>Forest</strong> Watch and Wilderness Watch suggest going beyond the new limits proposed in Alternative 12 by<br />
limiting access to the Chattooga Corridor within the Ellicott Rock Wilderness to a maximum of 6-8<br />
individuals per group on trails and 6 individuals in designated campsites (without exceptions for group<br />
campsites). We agree limiting anglers to four per group is appropriate (whether back-country trout<br />
fishermen or front-country anglers). Boating should be further restricted on those portions of the River (the<br />
Lower Chattooga) where it is taxing resource capacity. Prohibiting boating, horseback riding, and ATV<br />
use in the Upper Chattooga Corridor has preserved the wonderful, secluded area that exists there today.<br />
Now, additional management limits for hikers and anglers are warranted to guard against loss of the very<br />
elements that make this place so attractive; it certainly is not the time to expand user groups and intensify<br />
use, or to create new access and egress points to and from the river. (Ltr# 166, Cmt# 28)<br />
Subconcern # I<br />
The EA fails to exhaust indirect use limits before imposing direct limits. On page 39 of the EA, a<br />
monitoring plan is described that would limit uses first with indirect measures and subsequently with direct<br />
measures as necessary. This statement proves that the <strong>US</strong>FS understands their mandate in the FSM. This<br />
mandated use limitation technique however is applied only to non-paddlers whose existing impacts mar the<br />
corridor, while paddlers suffer from harsh direct limits before they have ever floated the river in all<br />
alternatives. Arbitrarily, capriciously, and inequitably applying direct limits to only paddlers prior to<br />
exhausting indirect measures is a direct violation of the Appeal ROD, the FSM, and any concept of fairness<br />
or reason. (Ltr# 168, Cmt# 9)<br />
Subconcern # I<br />
#411- The EA must ensure that ""direct controls and restrictions" be minimized, and that controls are to be<br />
applied only as necessary to protect the wilderness resource after indirect measures have failed (FSM<br />
2323.12)." The EA does not, as it proposed unjustified direct boating limits prior to trying indirect<br />
measures. (Ltr# 193, Cmt# 399)<br />
Subconcern # I<br />
#436- None of these impacts can be attributed to paddlers, yet the <strong>US</strong>FS targets only paddlers for use<br />
limits. Choosing to manage proven real impacts with indirect management while managing unproven and<br />
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