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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA In subsection J. Cumulative Effects for All Alternatives of the Environmental Assessment, Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River, it concludes that “the alternatives would continue to protect this component of the Biology ORV in the Chattooga WSR Corridor.” Sample Public Comment(s) for PC 17: Subconcern # A #30- During summer months the trout have a high mortality and pollute downstream waters with increased biological waste and bacteria as they decay. (Ltr# 193, Cmt# 24) Subconcern # B #39- The Chattooga River supports several other fish species at or near the extreme southeastern periphery of their ranges. Included in this group are longnose (Rhinichthys cataractae) and blacknose (R. atratulus) dace as well as mottled sculpin (Cottus bairdi). (Ltr# 193, Cmt# 33) Subconcern # C D #40- The upper river is a more sensitive area for reproduction, especially around the cobble and rocks that are in higher concentrations in the upper elevations. Having boaters clanging and crashing around those areas will prevent the fish from achieving their spawning activities during the day time. As far as we know, fish don't spawn at night and fishing is not disruptive to their spawning action. In addition, portage trails will create entry paths for silt, which is detrimental to aquatic life, which include spawning trout. (Ltr# 193, Cmt# 34) Subconcern # E #95- With persistent drought, water flows are at an all-time low. It is during these times of low water that water temperatures become a major concern in protection of trout and the many other species that make up the river system. (Ltr# 193, Cmt# 88) Subconcern # G #96- Located at the edge of the Eastern Continental Divide, the Chattooga River exhibits faunal qualities that suggest geologic exchange among major river basins. The Chattooga River, in the headwaters of the Atlantic slope, harbors several fish species that otherwise occur predominantly in the adjacent Tennessee River basin on the other side of the Eastern Continental Divide. These include mirror (Notropis spectrunculus), Tennessee (N. leuciodus), and warpaint (Luxilus coccogenis) shiners. The Chattooga River is one of the few, if only, Atlantic slope drainages where these species are known to occur. (Ltr# 193, Cmt# 89) Public Concern 18 The Forest Service should reconsider eliminating and/or reducing the stocking of non-native species to reduce the impacts from fishing, to improve conditions for native fish and other aquatic species, and to indirectly limit use prior to instituting direct measures. Response to PC 18 Stocking of trout is outside the scope of this decision. Stocking of trout was occurring in 1971 and in the 1971 Wild and Scenic River Study Report, Chattooga River notes that stocking of catchable size trout was occurring in some of the Chattooga River in all three states. The 1971 Designation Study report includes an action plan for fisheries on pages 87-89, which notes that Game and Fish State organization recommend managing Chattooga as a “Wild River fishery”; stocking sub-adults and fingerlings in the wild and scenic sections, stocking any size fish in the recreation sections; and vehicular access for stocking is provided in the recreation sections. The Federal Register, Volume 41, Number 56 – Monday, March 22, 1976 (also known as 1976 Federal Register) not only includes formal descriptions of the wild and scenic river boundaries and classifications but also includes information on the fisheries: 64
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA A native fishery will be encouraged. Fish stocking will be permitted at the Highway 28 Bridge, Burrells Ford, Bullpen Bridge, Long Bottom Ford on the river, and Warwoman and Overflow Bridges on the West Ford [sic]. The effects of the different alternatives to the different resources are discussed in Chapter 3. Specifically, impacts from the different alternatives to the aquatic community are discussed in Section 3.2.2A Aquatics. The fish species diversity of the Management Indicator Community in the Chattooga River watershed has not changed in more than 20 years of sampling the main stem of the river (SCDNR unpublished data). Sample Public Comment(s) for PC 18: Ban stocking of non-native species. (Ltr# 91, Cmt# 1) And why are non-native trout stocked in there in the first place? (Ltr# 97, Cmt# 6) While the Environmental Assessment provides for no fewer than 14 different use scenarios, all of these scenarios revolve around limiting paddling opportunities in one manner or another. Not a single scenario studies the possible effect of eliminating or reducing the stocking of non-native fish species. Eliminating stocking would likely reduce the impact anglers have on the river while at the same time improving conditions for native fish and other aquatic species. Despite the potential positive impact this scenario might have on returning the river corridor to a more natural state, this possibility is never mentioned or discussed. In a previous round of comments when asked why this issue was not addressed, the forest service stated it was out of scope while providing no reason for not exploring the impact of a significant activity within the river corridor. The validity of this approach can be assessed by looking at the streams in the Great Smoky Mountains National Park, where stocking was discontinued in 1975. According to the fishing FAQs section of the National Park’s website: “The only stocking practiced today seeks to restore endangered and threatened native species like the Smoky Mountain madtom and the spotfin chub to waters where they once thrived. Fisheries monitoring activities in the park have clearly shown that stocking is not needed. This information shows that many park streams have 2,000-4,000 trout per mile.” Stocked rainbow trout are like the kudzu of mountain streams, outcompeting and driving out native aquatic wildlife. Discontinuation of artificial stocking of non-native species that out compete the native brook trout might improve the survivability of the native brook trout. (Ltr# 150, Cmt# 2) The EA fails to consider the ecological and recreational effects of stocking. The EA fails to consider the recreational and ecological impacts of the stocking program. Likewise the EA fails to propose to limit stocking as a means of indirectly limiting use prior to instituting direct limits. The EA mentions that the upper portions of the Chattooga are better for fishing, but fails to mention the stocking that causes this condition (page 58). The EA opines on recreation use patterns, resource characteristics, and seasons but fails to mention the significant role of stocking (page 73). The EA casually acknowledges that stocking can cause congestion and crowding (page 85). The EA ponders impacts to countless aquatic species, most or all of which are eaten by stocked trout, however the EA never considers these impacts. Stocking was excluded from the analysis of existing impacts (page 151). The water quality assessment in the EA totally overlooks the impacts of the hatchery on the East Fork. The EA fails to connect the area with the “greatest length of user created trails” with the obvious cause – Delayed Harvest stocking (Page 299, etc). The USFS stocking program significantly increases use. The USFS stocking program is responsible for the near extirpation of native brook trout. The USFS stocking program causes the “potential conflicts” that the EA bans paddling to prevent. Failing to analyze stocking while banning paddling to limit use is analogous to failing to analyze a program that releases bark beetles while mandating timber harvest in response to a bark beetle infestation. The USFS is causing the impact that the EA proposes to manage. Rather than considering limiting the cause, the EA irrationally proposes to eliminate the effect by banning paddling. Doing so fails to consider and implement indirect use limits prior to direct limits and thus violates the FSM and the Appeal ROD. It fails to equitably limit use which violates the Appeal ROD and FSM. It fails to consider a reasonable range of alternatives by ignoring a primary impact, which violates NEPA. (Ltr# 168, Cmt# 24) Fact of the matter is, you aren’t doing anything but making it worse with stocking fish. The non-native species feast on the native Brookies, furthering their demise. When you stock, everyone knows it, and people from all over come and stand around the bend and net scoop fish up and fill the coolers. What a zoo 65
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