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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 />

management direction would “preserve the natural conditions, wilderness character, ‘outstanding<br />

opportunities for solitude’ and a ‘primitive and unconfined type of recreation’” as required under the<br />

Wilderness Act. Rather, if implemented, the Environmental Assessment will greatly diminish all of these<br />

characteristics of the three affected National <strong>Forest</strong>s. The selected Alternative 12 would for the first time<br />

since 1976 formally open these headwaters to boating and improperly intensify use of the Upper Chattooga<br />

Corridor. We thus request that the <strong>Forest</strong> <strong>Service</strong> maintain that portion of current zoning of the Chattooga<br />

River that prohibits all boating in the Headwaters above Highway 28, as well as continuing to prohibit all<br />

boating from tributaries on the Upper Chattooga. (Ltr# 166, Cmt# 1)<br />

Subconcern # R<br />

I do not agree with the findings of the Environmental Assessment, nor do I support the proposed<br />

"Alternative 12," the selection of which confirms, I believe, the inadequacy of the biological, economic and<br />

management analyses held up to support that alternative. (Ltr# 185, Cmt# 3)<br />

Subconcern # R S<br />

History and the administrative record support the current zoning of uses to different segments of the entire<br />

Chattooga River and indicate that new limitations for all users of the Chattooga Corridor and Ellicott Rock<br />

Wilderness are now appropriate and necessary to protect these resources, and are thus required by law.<br />

The most realistic, efficient, and workable solutions to address the need to protect the qualities for which<br />

the Chattooga Corridor is covered under the Wilderness and Wild and Scenic Rivers Acts would be to<br />

adopt those portions of Alternative 12 that would place greater limits on pedestrian and camper access –<br />

but continue the current zoning that prohibits all boating and floating on the entire 21 miles of the Upper<br />

Chattooga headwaters. Such a decision would be supported by the EA with a few modifications (such as<br />

improved management coordination and adoption of identical amendments to the Land and <strong>Resource</strong><br />

Management Plans of the three National <strong>Forest</strong>s, as suggested in the EA for management of Large Woody<br />

Debris). For the reasons explained above, Georgia <strong>Forest</strong> Watch and Wilderness Watch oppose the<br />

boating proposed in Alternative 12. The record reveals a lack of consideration or discussion by the <strong>Forest</strong><br />

<strong>Service</strong> of the biological, economic, and management impacts of the boating proposed in Alternative 12.<br />

For all the reasons discussed in these comments, the record does not support the boating proposed in<br />

Alternative 12 or any other alternative that would open the Upper Chattooga to boating or intensify use of<br />

the Upper Chattooga Corridor. As such, the <strong>Forest</strong> <strong>Service</strong> must either find that a “no boating” alternative<br />

is appropriate or find that Alternative 12 will have a significant impact on the quality of the human<br />

environment and that an Environmental Impact Statement must be prepared. (Ltr# 166, Cmt# 37)<br />

Public Concern 11<br />

The <strong>Forest</strong> <strong>Service</strong> should not select Alternative 13 because:<br />

A) User conflicts would be amplified;<br />

B) New access points and portage trails are not suitable;<br />

C) New parking areas are limited and a long distance from the Chattooga<br />

River;<br />

D) It will increase trespassing on private land as a result of overflow parking,<br />

and possible search and rescue incidents; and<br />

E) Expansion of the trailhead facilities on Green Creek Cemetery Road would<br />

be inconsistent with the purpose for which the land was donated.<br />

Response to PC 11<br />

A) Chapter 3 of the Environmental Assessment, Managing Recreation Uses in the Upper<br />

Segment of the Chattooga Wild and Scenic River Corridor includes effects to users from<br />

alternative 13 in Section 3.2.1 Recreation ORV, 1. Potential Recreation Use Conflicts and<br />

Boating Access, items a-d.<br />

B) The exact location of the designated trail would be decided with additional site-specific<br />

NEPA. The final decision on trails to be designated would be informed from public input and<br />

potential effects to resources. The effects analysis in the Environmental Assessment, Managing<br />

Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor has<br />

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