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
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# 8)
Subconcern # J
The Forest Service described to the Federal Court why they withdrew the August 2009 Decision On page 5
of the USFS “Motion to Dismiss” filed by the USFS on December 30, 2009, the forest Service notes: “ the
decision notices were withdrawn because the analysis in both the Biological Evaluation and Biological
Assessment were based upon an alternative that was different from the selected alternative, resulting in
inconsistencies between the environmental documents. Specifically, the BE and BA assumed that there
would be a maximum of four groups per boatable day, but the selected alternative did not contain a
limitation on the number of groups allowed per boatable day. Therefore, more analysis needs to be
completed and new decisions made.” The ‘more analysis’ that the USFS argued was required to reach a
new decision, is absent from the 2011 EA. In fact, the latest preferred alternative would not only allow
unlimited quantities of boaters, it also proposes to eliminate any and all flow level restriction. Therefore,
“inconsistencies between the environmental documents” associated with more boats inflicting even more
impacts upon the resource remain. In fact, the inconsistencies between evaluations and proposed policy
should be even more acute with the proposed alternative. The EA reliance on a Biological Assessment, and
Biological Evaluation, that are admittedly deficient, cannot possibly be used to justify a FONSI or final
agency Decision. The USFS should either return to only allowing four limited boat groups per day at
higher flow levels during the winter, or accurately assess and document the impacts associated with the
preferred alternative. After monitoring for a few more decades, the USFS could then make an educated
assessment on if allowing more boats per day or boating during lower flows would be appropriate. (Ltr#
117, Cmt# 1)
Subconcern # J Q U-Z
The Chattooga Conservancy is Opposed to the Preferred Alternative (Alternative 12) Offered by the Forest
Service in the EA for the Following Reasons: The preferred alternative will create undue risk of
irreparable harm to the Outstandingly Remarkable Resource Values of the headwaters section of the
Chattooga River including the opportunity for solitude, and the rich natural resources and biological
diversity of the Upper Chattooga River backcountry, and especially the Chattooga Cliffs Reach. The
preferred alternative is arbitrary and capricious because it excludes boaters from the section of the
headwaters from Lick Log Creek to Highway 28, and during the boating season from March 1 to December
1 from Bull Pen Bridge to Lick log Creek, without just cause. The preferred alternative does not assure the
“non degradation” of the Outstandingly Remarkable Values (ORV) of the Upper Chattooga River, since no
comprehensive biological study has been conducted for the Upper Chattooga River. The preferred
alternative does not provide the public with all the necessary documents required to make an informed
decision about the proposed alternative. The preferred alternative is arbitrary and capricious since many
important conclusions rely on outdated, insufficient, faulty, or nonexistent information. The preferred
alternative states that any future damage to the resource will be monitored, and if erosion and
sedimentation occur from the unauthorized user-created portage trails, damage to the federally listed
Threatened & Endangered Species or other rare or sensitive biological resources, and/or if too many
encounters to meet compliance with the requirements to protect the back country experience are
documented, then at this time these threats will be dealt with by implementing “adaptive management.”
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