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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA I would rather the preferred alternative had been Alternative #3 (continue current zoning of the river to provide high-quality whitewater opportunities on the lower segment and the West Fork/Overflow Creek of the Chattooga WSR and to provide cold water angling and other recreational opportunities on the North Fork without the impacts of boating use), but I can accept Alternative #12. More importantly, Alternative #12 upholds and preserves the ability to zone public recreational water corridors for all federal agencies (USFS, NPS, BLM and USF&WS) by section of stream, by time of year, by type of craft, and by maximum group sizes (for hiking, camping, angling & boating). To maintain the quality of experience for all visitors and/or protect riparian resources, zoning of public recreational water corridors is absolutely necessary now and in the future. (Ltr# 51, Cmt# 1) Subconcern # D In the EA cover letter dated July 15, 2011 you asked for feedback on the EA and preferred alternative. Following you will find my two suggestions: I believe the 2 boating sessions in the preferred alternative should be reversed. I suggest you make the boating from Burrell’s Ford to Lick Log Creek (SC – not to be confused with the Lick Log Creek below Highway 28 on the GA side) available from Dec.1 to Jan.15 and the boating from Green Creek to Burrell’s Ford available from Jan.16 to Mar.1. I believe there would be fewer in-stream angler-boater encounters if the sessions are flipped because backcountry angling activity below Burrell’s Ford begins to increase in February. Citation: EA Page 79 - “These same Use Estimation Workshop estimates show that anglers spend the least amount of time in the Chattooga Cliffs Reach from November through April; in the Ellicott Rock Reach from September through February; in the Rock Gorge from December through January and from June through September; and in the Delayed Harvest from June through September and January through February.” (emphasis added) I believe the average river water flow would be more favorable for boating if the sessions are flipped. The river reach below Burrell’s Ford is boatable in lower flows and has a wider range of boatable flows. The river reach above Burrell’s Ford needs more flow for boating and has a narrower flow range. On average, flow is lowest during the first session. Citation: EA Page 50 - Figure 3.1-1 Mean Monthly Flow (cfs) for the Chattooga River at Highway 76 (period of record from 1939-2010) Dec – 650 cfs; Jan – 770 cfs; Feb - 840 cfs Citation: EA Page 75 - Figure 3.2.1-1 Flow Range Bars for Fishing and Whitewater Boating Opportunities on the Upper Segment of the Chattooga WSR (Whittaker and Shelby 2007). “While more technical, low-flow boating is available as low as 200 to 250 cfs (depending on the river reach), whitewater boaters would rather paddle flows that have fewer boatability problems and more challenging whitewater.” I believe that there could be a parking problem at the Thrift Lake Trailhead on weekends because boaters coming from Burrell's Ford plus anglers, hikers and campers will be using the same small parking area. Flipping the sections/sessions will provide some relief (I believe fewer people will boat, camp, hike and fish the Dec - Jan 15 session). Citation: EA Page 76 – Lick Log confluence: “It is accessible by trail from the Thrift Lake trailhead (about 0.75 miles, all downhill) - - ” As a long time Chattooga backcountry angler, I know that the wild brown trout are above Burrell’s Ford and there are rainbow trout and brown trout below Burrell’s Ford. I also know that rainbow trout are more likely to feed in the middle of the day. Citation: EA Page 79 - Angling “- - - - in winter, the best times are the middle of the day when the sun has raised temperatures slightly.” Therefore, when we get those warm sunny days in February, I (and other anglers seeking solitude) like to go to the backcountry below Burrell's Ford, maybe down to the Island/Nugget area or The Steps or Big Bend if the water level is not too high. I believe there would be fewer in-stream encounters if the sessions are reversed. Reducing encounters from the outset by reversing the sessions would also be better for future generations. (Ltr# 51, Cmt# 3) Subconcern # D K L If the FS decides to move ahead with Alternative 12 as outlined in the EA dated July 15, 2011, we express the following concerns that should be addressed: We do not believe the FS can effectively enforce the plan as outlined. The meager $50 fine for violation is grossly insufficient and will not be effective in deterring violators. Penalties should include much greater fines and equipment confiscation. The two access scenarios should be reversed. We believe there would be fewer in-stream angler boater encounters if the sessions are flipped because backcountry angling activity below Burrell's Ford begins to increase in February. Parking for boater access is very insufficient at the Thrift Lake and Green Creek put-in's, and will lead to vehicles parking off designated areas. This will lead to erosion and to conflict issues with surrounding private owners and others. There are 2 Lick Log Creeks. The EA needs to be clear that this Lick Log Creek comes in from SC above Highway 28. The other comes in from GA below Highway 28. Winter road access for boaters will likely bring unprecedented stress to the roads and must be accounted 32
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA for in considering possible additional erosion in the Chattooga corridor. At least one boater access trail does not currently exist. If constructed, it must adhere to BMPs for trails along with all other affected access trails. (Ltr# 107, Cmt# 2) Subconcern # D K L P If you are bound and determined to approve Alternative 12 please amend it as follows: Amend the area for boating from January 15 to March 1 to from Burrell’s Ford Bridge to the downstream edge of the Gorge area at the falls where the Thrift Lake parking area trail in South Carolina reaches the Chattooga; Add a rule that at no time will boaters approach within 30 feet of fishermen, hikers, or other boaters who are already floating the river unless those already in the river (such as those who are capsized or have fallen out of their boats) are in distress and need rescuing. If they don’t want to wait for others to finish fishing a run and clear the water before continuing downstream they may portage around them. This will ensure the safety of wading fishermen and hikers, or boaters who are also resting or fishing and also provide less disruption to fishermen; and Please add a specific description of how you will address the current law enforcement needs and future increase in law enforcement needs on the Chattooga River above the Highway 28 bridge if boating is allowed. (Ltr# 135, Cmt# 5) Subconcern # D K M N O We suggest the following if Alternative #12 is implemented: Strict enforcement of all regulations to include significant increases in fines for all violations. More personnel are needed to patrol the river. In addition, all citizens should be provided with information to report suspected violations. Consider "reversing" the planned dates for boating to better avoid possible conflicts. Continue to monitor woody debris especially in the "newly designated" boating sections to insure that the health of the river is maintained. Closely monitor road and parking conditions during boating periods. Heavy road use during wet periods and limited parking space can lead to increases in sediment run off. (Ltr# 112, Cmt# 1) Subconcern # E I support Option 12 put forward by the USDA Forest Service for the Chattooga River. This is the fairest option for all concerned and has both fishers and boaters making sacrifices. (Ltr# 53, Cmt# 1) Subconcern # E G I believe the legislation governing the river supports a management regime that allows for significant providence of boater-free angling. Therefore, I support Alternative 12, as presented in the 2011 Draft Environmental Assessment. I believe it is a reasonable and lawful compromise that will allow both paddlers and anglers to enjoy this unique and beautiful reach. Further, I welcome the efforts to manage all uses in the river to reduce the impacts from social trails and camping areas. (Ltr# 105, Cmt# 2) Subconcern # E-I A key goal for many was protecting the solitude and wilderness experience as the current zoning for foot travel only above Highway 28 has for over 30 years. The SC Council of TU supports the many members and chapters that prefer that this successful zoning be continued (Alternative #3). However, the SC Council finds Alternative #12 from the USFS study as an acceptable compromise that is fair to all stakeholders and should not harm the fisheries. We hope that other resource users will join TU in support of Alternative #12 to help the USFS resolve this controversial issue and move on to more productive efforts. ...Establishing backcountry capacities to minimize encounters between boaters and anglers, reducing campsite density to maximize opportunities for a solitude experience for all, and providing boaters opportunities to float the upper river when flow levels are best suited for their interests are all well thought out solutions supported in Alternative #12. Equally important, is the wise prohibition of removal of large woody debris from the river which is very important to the health of the fishery as an integral part of the intricate food chain. Valuing the fishery over navigability concerns is to be commended as it is in keeping with the many years of work to improve the fishery by the USFS and others working together in the ‘Chattooga Coalition’ which has met annually since formation during the 3 year macro-invertebrate study in the late 1980s that TU was a major participant in, including providing funding and manpower. (Ltr# 127, Cmt# 1) Subconcern # F-I While most of our members would have preferred the continued operation with Alterative #3, we can accept the Alternative # 12, which will establish backcountry capacities to minimize encounters between boaters and anglers, reduce campsite density to maximize opportunities for a solitude experience for all, provide boaters floating the upper river when flow levels are best suited for their interests and most 33
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