Resource Name (Heading 1) - USDA Forest Service - US ...

Summary of Public Comments - Managing Recreation Uses in the
Upper Segment of the Chattooga Wild and Scenic River Corridor EA
right at the top of a waterfall, far below the road elevation. Downstream of the Bullpen Road is the Ellicott
Rock Wilderness. There is not even a trail along the river in most of this area, much less a boat launch. By
definition this area is a wilderness with very little built infrastructure, and should remain so. Below the
Ellicott Rock Wilderness, a trail follows the river, and there is a greater flow of water in it. The river itself
is more conducive to boating, but again there is no boating launch point. At Ellicott's Rock, the upper end
of the riverside trail system, it is over 3.5 miles by trail to the nearest road, hardly a good portage. The next
access downstream is Burrell's Ford, where more parking exists. The river downstream of this place is
more suitable for boating than any place upstream. Why will the US Forest Service not restrict boating to
the reaches below Burrells Ford and prohibit it upstream? Back upstream, beyond the Chattooga River
trail head, the next public access to the river is the small isolated parcel of public land at Grimshawes,
where the public uses the sliding rock falls on the river. It is not a suitable nor adequate entrance for
boaters either. Parking is very minimal here, and large overflows of parked cars often line Whiteside Cove
Road currently, even without boaters as additional users. It is not uncommon to see 30 to 40 cars on the
narrow shoulders. As for the use of the river for boating, the Chattooga between Grimshawes and Greens
Creek could hardly be deemed navigable. For example, I cannot imagine someone wanting to go over
Corkscrew Falls in any vessel. Nevertheless, if such daredevil stunts should be undertaken by boaters,
those activities will almost certainly result in injuries, if not deaths. How could the US Forest Service and
rescue personnel access a boating accident site to transport victims effectively and without trespassing on
adjacent private lands? (Ltr# 147, Cmt# 6)
Subconcern # G-M
Alternative 8 fails to consider paddling and other uses on the Chattooga River between Grimshawes Bridge
and Green Creek and thus violates the Appeal ROD and WSRA. Alternative 8 arbitrarily bans paddling on
the tributaries which violates the WSRA, NEPA, and a variety of other laws and regulations. Alternative 8
fails to require all corridor users to register. Analysis of Alternative 8 includes “scenic boaters” which do
not exist, and “boat-based anglers,” an activity that can and should be managed separately. It is not clear
that Alternative 8 would equitably institute direct limits only after indirect limits have been exhausted.
Alternative 8 includes Licklog Creek as a put-in, which was not part of the paddlers’ requested alternative
and should not have been included. It is unclear in the EA what the current status of the trail into Green
Creek is, and if that trail is necessary or even desired by paddlers, and thus it may be inappropriate to
propose this trail as part of the boating alternative. (Ltr# 168, Cmt# 31)
Subconcern # K P
#427- Alternative 8, while erroneously described by some as unlimited boating, does in fact contain a
boating closure. It would ban boating on the upper 2-4 miles of the river and multiple tributaries, and thus
does provide the clearly stated legal access being sought by American Whitewater to the entire Chattooga
Wild and Scenic River. This closure exists in all alternatives and adversely affects access to the public river
as it flows through both public and private lands. The EA paints Alternative 8 as the paddlers’ preferred
alternative. It is not. It contains a ban on boating the uppermost several miles of the Wild and Scenic
Chattooga River with zero basis or discussion, and also contains a new ban on boating tributaries with
zero basis or discussion. Alternative 8 also fails to limit all uses equitably using all indirect measures first
followed by direct measures. (Ltr# 193, Cmt# 415)
Subconcern # N
I also ask the Forest Service to reject Alternative 8. Lifting the ban on boating will destroy the “esthetic,
scenic…features” that the National Wild and Scenic River Act explicitly mandates must be protected ahead
of any recreational use. 16 U.S.C. §1281(a). The degradation of the upper Chattooga’s “esthetic,
scenic…..features” can be reasonably foreseen because whitewater rafting and kayaking have already
contributed directly or indirectly to the degradation of these features on the lower Chattooga River. (Ltr#
171, Cmt# 2)
Subconcern # O
#407- TU is opposed to further consideration of Alternative 8, the unlimited boating alternative. It would
be impossible to preserve the Upper Chattooga under this type of management plan. (Ltr# 193, Cmt# 395)
Subconcern # Q
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