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 />
Subconcern # A B G<br />
#443- The EA, by focusing on boating as the only management variable, does not consider a full range of<br />
alternatives and introduces inherent inequity. The EA considers paddling limitations as the only direct<br />
management tool, while all other larger and more damaging uses are allowed in every location, in every<br />
time, in unlimited numbers. The record of decision on our appeal ordered a user capacity analysis - not a<br />
paddling capacity analysis. Thus the EA does not meet the mandate of the appeal decision or of <strong>Forest</strong><br />
<strong>Service</strong> guidelines. The <strong>US</strong>FS has biased the entire EA and left the river corridor and user experiences at<br />
risk of harm by analyzing the effects of various levels of paddling without simultaneously analyzing the<br />
effects of other use (Ltr# 193, Cmt# 431)<br />
Subconcern # C<br />
#169- The assessment does not show the entire “range” of optimal preferences. The assessment has used<br />
an “average” of optimal preferences and represented them as full statistical range of data. (Ltr# 193,<br />
Cmt# 162)<br />
Subconcern # D<br />
#348- You must propose a range of alternatives for protecting and enhancing whitewater boating on the<br />
Headwaters; (Ltr# 193, Cmt# 338)<br />
Subconcern # E<br />
#399- When the Draft EA is considered in this context, none of the boating alternatives is adequately<br />
supported, even on the Lower Chattooga and in the tributaries. Zoning, on the other hand, is specifically<br />
endorsed in the <strong>Forest</strong> <strong>Service</strong> Directives and the <strong>Forest</strong> <strong>Service</strong>'s guidelines for management of Wild and<br />
Scenic River Areas. (Ltr# 193, Cmt# 387)<br />
Subconcern # F<br />
#432- Applying different standards to different management alternatives makes a comparison of<br />
management alternatives virtually impossible and introduces significant bias. For example, alternatives 3,<br />
4, and 5 which severely limit boating have relatively loose encounter standards when compared to<br />
alternatives 8, 9, and 10 which have relatively tight standards. Alternatives 8-10 have significantly more<br />
encounter standard violations than Alternatives 4-5, however what is less clear is that these violations are<br />
largely caused by lower standards - not higher use. Therefore we (and the <strong>US</strong>FS) can not compare<br />
management alternatives on equal footing. (Ltr# 193, Cmt# 420)<br />
Subconcern # H<br />
#541- The EA lacks a listing of the nearby alternatives in the southeast. (Ltr# 193, Cmt# 528)<br />
Public Concern 15<br />
The <strong>Forest</strong> <strong>Service</strong> received letters that contained comments that appeared to be<br />
a vote but the comment period for the 2011 EA is not a vote-counting process; the<br />
most useful comments are those that are unique, substantially different, provide<br />
rationale, and suggest specific changes to the EA, and therefore, these comment<br />
letters do not warrant further response: Letters 6, 11, 77, 159, and 170.<br />
Response to PC 15<br />
No response is needed<br />
Sample Public Comment(s) for PC 15:<br />
Would prefer #3, but in the interest of compromise would accept #12. (Ltr# 6, Cmt# 1)<br />
Reject the boating lobby's insistence on unrestricted access (Alternative 8 of the EA); (Ltr# 11, Cmt# 1)<br />
Reject the <strong>Forest</strong> <strong>Service</strong> partial opening (Alternative 12 of the EA); (Ltr# 11, Cmt# 2)<br />
I have reviewed your latest plan for the upper Chattooga River and I'm not sure I support it. It may be the<br />
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,<br />
Cmt# 1)<br />
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