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 />
Ellicott Rock Wilderness, a trail follows the river, and there is a greater flow of water in it. The river itself<br />
is more conducive to boating, but again there is no boating launch point. At Ellicott's Rock, the upper end<br />
of the riverside trail system, it is over 3.5 miles by trail to the nearest road, hardly a good portage. The next<br />
access downstream is Burrell's Ford, where more parking exists. The river downstream of this place is<br />
more suitable for boating than any place upstream. Why will the <strong>US</strong> <strong>Forest</strong> <strong>Service</strong> not restrict boating to<br />
the reaches below Burrells Ford and prohibit it upstream? Back upstream, beyond the Chattooga River<br />
trail head, the next public access to the river is the small isolated parcel of public land at Grimshawes,<br />
where the public uses the sliding rock falls on the river. It is not a suitable nor adequate entrance for<br />
boaters either. Parking is very minimal here, and large overflows of parked cars often line Whiteside Cove<br />
Road currently, even without boaters as additional users. It is not uncommon to see 30 to 40 cars on the<br />
narrow shoulders. As for the use of the river for boating, the Chattooga between Grimshawes and Greens<br />
Creek could hardly be deemed navigable. For example, I cannot imagine someone wanting to go over<br />
Corkscrew Falls in any vessel. Nevertheless, if such daredevil stunts should be undertaken by boaters,<br />
those activities will almost certainly result in injuries, if not deaths. How could the <strong>US</strong> <strong>Forest</strong> <strong>Service</strong> and<br />
rescue personnel access a boating accident site to transport victims effectively and without trespassing on<br />
adjacent private lands? (Ltr# 147, Cmt# 8)<br />
Subconcern # J<br />
The <strong>Forest</strong> <strong>Service</strong> described to the Federal Court why they withdrew the August 2009 Decision On page 5<br />
of the <strong>US</strong>FS “Motion to Dismiss” filed by the <strong>US</strong>FS on December 30, 2009, the forest <strong>Service</strong> notes: “ the<br />
decision notices were withdrawn because the analysis in both the Biological Evaluation and Biological<br />
Assessment were based upon an alternative that was different from the selected alternative, resulting in<br />
inconsistencies between the environmental documents. Specifically, the BE and BA assumed that there<br />
would be a maximum of four groups per boatable day, but the selected alternative did not contain a<br />
limitation on the number of groups allowed per boatable day. Therefore, more analysis needs to be<br />
completed and new decisions made.” The ‘more analysis’ that the <strong>US</strong>FS argued was required to reach a<br />
new decision, is absent from the 2011 EA. In fact, the latest preferred alternative would not only allow<br />
unlimited quantities of boaters, it also proposes to eliminate any and all flow level restriction. Therefore,<br />
“inconsistencies between the environmental documents” associated with more boats inflicting even more<br />
impacts upon the resource remain. In fact, the inconsistencies between evaluations and proposed policy<br />
should be even more acute with the proposed alternative. The EA reliance on a Biological Assessment, and<br />
Biological Evaluation, that are admittedly deficient, cannot possibly be used to justify a FONSI or final<br />
agency Decision. The <strong>US</strong>FS should either return to only allowing four limited boat groups per day at<br />
higher flow levels during the winter, or accurately assess and document the impacts associated with the<br />
preferred alternative. After monitoring for a few more decades, the <strong>US</strong>FS could then make an educated<br />
assessment on if allowing more boats per day or boating during lower flows would be appropriate. (Ltr#<br />
117, Cmt# 1)<br />
Subconcern # J Q U-Z<br />
The Chattooga Conservancy is Opposed to the Preferred Alternative (Alternative 12) Offered by the <strong>Forest</strong><br />
<strong>Service</strong> in the EA for the Following Reasons: The preferred alternative will create undue risk of<br />
irreparable harm to the Outstandingly Remarkable <strong>Resource</strong> Values of the headwaters section of the<br />
Chattooga River including the opportunity for solitude, and the rich natural resources and biological<br />
diversity of the Upper Chattooga River backcountry, and especially the Chattooga Cliffs Reach. The<br />
preferred alternative is arbitrary and capricious because it excludes boaters from the section of the<br />
headwaters from Lick Log Creek to Highway 28, and during the boating season from March 1 to December<br />
1 from Bull Pen Bridge to Lick log Creek, without just cause. The preferred alternative does not assure the<br />
“non degradation” of the Outstandingly Remarkable Values (ORV) of the Upper Chattooga River, since no<br />
comprehensive biological study has been conducted for the Upper Chattooga River. The preferred<br />
alternative does not provide the public with all the necessary documents required to make an informed<br />
decision about the proposed alternative. The preferred alternative is arbitrary and capricious since many<br />
important conclusions rely on outdated, insufficient, faulty, or nonexistent information. The preferred<br />
alternative states that any future damage to the resource will be monitored, and if erosion and<br />
sedimentation occur from the unauthorized user-created portage trails, damage to the federally listed<br />
Threatened & Endangered Species or other rare or sensitive biological resources, and/or if too many<br />
encounters to meet compliance with the requirements to protect the back country experience are<br />
documented, then at this time these threats will be dealt with by implementing “adaptive management.”<br />
42