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
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# 9)
Public Concern 12
The Forest Service should consider that all alternatives that would have allowed
boating below Bull Pen Bridge have been eliminated from detailed study, therefore
purposely limiting the range of alternatives and violating NEPA.
Response to PC 12
The phrase "range of alternatives" refers to the alternatives discussed in environmental
documents. It includes all reasonable alternatives, which must be rigorously explored and
objectively evaluated, as well as those other alternatives, which are eliminated from detailed
study with a brief discussion of the reasons for eliminating them. Chapter 2 Section 2.4
Alternatives considered but not evaluated in detail are part of the range of alternatives.
Sample Public Comment(s) for PC 12:
The agency has removed all the previously considered alternatives that would have only allowed boating
below Bull Pen Bridge. The EA claims this alternative has “became redundant and unnecessary”(p41), but
that is not true. Eliminating Bull Pen as a proposed Put-in, the assessment misrepresents the available
options as a dichotomy to either allow boating into the most ecologically sensitive area, or allow no
additional boating at all. The reduced variety of alternatives considered in this EA appears deliberately
designed to produce a desired outcome of pushing boating upstream toward Greens Creek. Every scoping
and previous EA during the past four years evaluated alternatives that did not allow boating above Bull
Pen Bridge. In addition, the 1971 Study Report Recreational Development Plan lists Bull Pen Bridge as the
uppermost put-in indicating boating above the bridge is not a congressionally recognized value. By
deliberately limiting the range of alternatives available to the decision maker (after having done the
assessment), possibly the environmental alternative, is a NEPA violation. (Ltr# 92, Cmt# 10)
Public Concern 13
The Forest Service should consider the following regarding alternative
development and/or the development of new alternatives:
A) The environmental alternative in the 2011 EA is not labeled as such, nor any
explanation given as to why it is preferable over the other alternatives;
B) An alternative that would consider motorized boat use on the lower section
of the Chattooga during higher flow levels above 2.2 feet on the 76 gauge;
C) An alternative that would give limited boating access while protecting
resources and minimizing trespass on private property, such as permitting
boating below Burrells Ford at all stages and seasons and below the steel
bridge at Bullpen Road during the winter;
D) An alternative that would open the upper segment of the Chattooga WSR to
boating that is self-regulating, since the water levels required to boat make
the water deep, turbid, and unsuitable for fishing; and implement the
current permit system that is used on Sections II, III, and IV of the
Chattooga River;
E) Amend the preferred alternative to include the potential damage to
biological resources that have not been adequately inventoried, along with
a more detailed analyses of the potential effects of building new access
into the remote Chattooga Cliffs Reach, and potential portage trail damage;
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