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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA having been eliminated." Also refer to "CEQs Forty Most-Asked Questions" guidance document to issues related to alternatives (questions 1a and 1b). There is no requirement for the alternatives to represent a full range of "optimal preferences". The alternatives must meet the Chapter 1, Purpose and Need for Action stated on pages 1 to 5 of the EA. The alternatives proposed are intended to protect the "Outstandingly Remarkable Values" (ORV) of the Chattooga. This is proposed in a variety of ways across all user groups by varying encounters, group size, closing trails, dispersed camping, parking restrictions and user registrations. D) The need for the proposed action is stated on pages 1-5 of the EA. In addition, section 1.2 summarizes the proposed action and section 1.3 discloses the decision to be made. E) See Section 2.4 Alternatives Considered but not evaluated in detail, item B in the Environmental Assessment, Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River. F) The range of alternatives developed provides different ways to meet the purpose and need for management of recreation uses on the Chattooga WSR. Alternatives were designed with public involvement. The Forest Service held open houses at the beginning of the process. At these meetings, the results of the data collection and findings in the reports were presented and responses were made to the public’s inquiries. See Appendix F of the EA for detailed information on the public involvement process. G) Based on the “Limits of Acceptable Change” process, the public was given the opportunity to provide comments on recreation uses in the upper segment of the Chattooga WSR. See Appendix F of the EA for detailed information on the public involvement process. H) Opportunities for whitewater boating in other areas in the southeast do not meet the purpose and need described in the Environmental Assessment, Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor (Chapter 1). The EA analyzes several "boat free" alternatives (Alternatives 1-3) as well as alternatives with varying levels of boating. The effects of these alternatives are disclosed in Chapter 3 of the EA. One of the reports created during the visitor use data collection effort looked at characteristics of proxy regional whitewater boating rivers (http://www.fs.fed.us/r8/fms/forest/projects/proxy-river.pdf). Also, a pair of studies explored “substitutability,” “involvement,” and “place attachment” to other regional rivers for Chattooga non-commercial whitewater boaters and trout anglers (Backlund, 2002; Hammitt et al., 2004; Bixler & Backlund, 2002). These were documented on page 25 of the Integrated Report (Whittaker and Shelby, 2007). Sample Public Comment(s) for PC 14: Subconcern # A #453- The EA, by considering a skewed range of boating alternatives, does not consider a full range of alternatives and introduces inherent inequity (Ltr# 193, Cmt# 441) Subconcern # A B The alternatives in the EA consider a range of immediate direct limits on only paddling. This is arbitrary, capricious, and unreasonable. The EA fails to consider reasonable alternatives and limits on alternatives brought forward in our scoping comments. As we stated in multiple sets of past comments, reasonable alternatives must consider equitable limits to all similar uses, only when necessary, and proposing indirect limits first. The EA fails on all three counts. Even if the false assumption that paddling and angling conflict were assumed to be true, a reasonable range of alternatives would have considered limits to angling as well as paddling, since if anglers were absent there would be no chance of the presumed conflicts. Throughout these comments we will offer additional examples of how the EA fails to consider a reasonable range of alternatives. Singling out direct limits on paddlers as the only variable creates an unreasonable range of alternatives and thus the EA violates NEPA. (Ltr# 168, Cmt# 5) 54
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA Subconcern # A B G #443- The EA, by focusing on boating as the only management variable, does not consider a full range of alternatives and introduces inherent inequity. The EA considers paddling limitations as the only direct management tool, while all other larger and more damaging uses are allowed in every location, in every time, in unlimited numbers. The record of decision on our appeal ordered a user capacity analysis - not a paddling capacity analysis. Thus the EA does not meet the mandate of the appeal decision or of Forest Service guidelines. The USFS has biased the entire EA and left the river corridor and user experiences at risk of harm by analyzing the effects of various levels of paddling without simultaneously analyzing the effects of other use (Ltr# 193, Cmt# 431) Subconcern # C #169- The assessment does not show the entire “range” of optimal preferences. The assessment has used an “average” of optimal preferences and represented them as full statistical range of data. (Ltr# 193, Cmt# 162) Subconcern # D #348- You must propose a range of alternatives for protecting and enhancing whitewater boating on the Headwaters; (Ltr# 193, Cmt# 338) Subconcern # E #399- When the Draft EA is considered in this context, none of the boating alternatives is adequately supported, even on the Lower Chattooga and in the tributaries. Zoning, on the other hand, is specifically endorsed in the Forest Service Directives and the Forest Service's guidelines for management of Wild and Scenic River Areas. (Ltr# 193, Cmt# 387) Subconcern # F #432- Applying different standards to different management alternatives makes a comparison of management alternatives virtually impossible and introduces significant bias. For example, alternatives 3, 4, and 5 which severely limit boating have relatively loose encounter standards when compared to alternatives 8, 9, and 10 which have relatively tight standards. Alternatives 8-10 have significantly more encounter standard violations than Alternatives 4-5, however what is less clear is that these violations are largely caused by lower standards - not higher use. Therefore we (and the USFS) can not compare management alternatives on equal footing. (Ltr# 193, Cmt# 420) Subconcern # H #541- The EA lacks a listing of the nearby alternatives in the southeast. (Ltr# 193, Cmt# 528) Public Concern 15 The Forest Service received letters that contained comments that appeared to be a vote but the comment period for the 2011 EA is not a vote-counting process; the most useful comments are those that are unique, substantially different, provide rationale, and suggest specific changes to the EA, and therefore, these comment letters do not warrant further response: Letters 6, 11, 77, 159, and 170. Response to PC 15 No response is needed Sample Public Comment(s) for PC 15: Would prefer #3, but in the interest of compromise would accept #12. (Ltr# 6, Cmt# 1) Reject the boating lobby's insistence on unrestricted access (Alternative 8 of the EA); (Ltr# 11, Cmt# 1) Reject the Forest Service partial opening (Alternative 12 of the EA); (Ltr# 11, Cmt# 2) I have reviewed your latest plan for the upper Chattooga River and I'm not sure I support it. It may be the best deal you'll be able to make, but I still think leaving the river as it is now is the best plan. (Ltr# 77, Cmt# 1) 55
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