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 />
A native fishery will be encouraged. Fish stocking will be permitted at the<br />
Highway 28 Bridge, Burrells Ford, Bullpen Bridge, Long Bottom Ford on the<br />
river, and Warwoman and Overflow Bridges on the West Ford [sic].<br />
The effects of the different alternatives to the different resources are discussed in Chapter 3.<br />
Specifically, impacts from the different alternatives to the aquatic community are discussed in<br />
Section 3.2.2A Aquatics. The fish species diversity of the Management Indicator Community in<br />
the Chattooga River watershed has not changed in more than 20 years of sampling the main stem<br />
of the river (SCDNR unpublished data).<br />
Sample Public Comment(s) for PC 18:<br />
Ban stocking of non-native species. (Ltr# 91, Cmt# 1)<br />
And why are non-native trout stocked in there in the first place? (Ltr# 97, Cmt# 6)<br />
While the Environmental Assessment provides for no fewer than 14 different use scenarios, all of these<br />
scenarios revolve around limiting paddling opportunities in one manner or another. Not a single scenario<br />
studies the possible effect of eliminating or reducing the stocking of non-native fish species. Eliminating<br />
stocking would likely reduce the impact anglers have on the river while at the same time improving<br />
conditions for native fish and other aquatic species. Despite the potential positive impact this scenario<br />
might have on returning the river corridor to a more natural state, this possibility is never mentioned or<br />
discussed. In a previous round of comments when asked why this issue was not addressed, the forest service<br />
stated it was out of scope while providing no reason for not exploring the impact of a significant activity<br />
within the river corridor. The validity of this approach can be assessed by looking at the streams in the<br />
Great Smoky Mountains National Park, where stocking was discontinued in 1975. According to the fishing<br />
FAQs section of the National Park’s website: “The only stocking practiced today seeks to restore<br />
endangered and threatened native species like the Smoky Mountain madtom and the spotfin chub to waters<br />
where they once thrived. Fisheries monitoring activities in the park have clearly shown that stocking is not<br />
needed. This information shows that many park streams have 2,000-4,000 trout per mile.” Stocked rainbow<br />
trout are like the kudzu of mountain streams, outcompeting and driving out native aquatic wildlife.<br />
Discontinuation of artificial stocking of non-native species that out compete the native brook trout might<br />
improve the survivability of the native brook trout. (Ltr# 150, Cmt# 2)<br />
The EA fails to consider the ecological and recreational effects of stocking. The EA fails to consider the<br />
recreational and ecological impacts of the stocking program. Likewise the EA fails to propose to limit<br />
stocking as a means of indirectly limiting use prior to instituting direct limits. The EA mentions that the<br />
upper portions of the Chattooga are better for fishing, but fails to mention the stocking that causes this<br />
condition (page 58). The EA opines on recreation use patterns, resource characteristics, and seasons but<br />
fails to mention the significant role of stocking (page 73). The EA casually acknowledges that stocking can<br />
cause congestion and crowding (page 85). The EA ponders impacts to countless aquatic species, most or<br />
all of which are eaten by stocked trout, however the EA never considers these impacts. Stocking was<br />
excluded from the analysis of existing impacts (page 151). The water quality assessment in the EA totally<br />
overlooks the impacts of the hatchery on the East Fork. The EA fails to connect the area with the “greatest<br />
length of user created trails” with the obvious cause – Delayed Harvest stocking (Page 299, etc). The<br />
<strong>US</strong>FS stocking program significantly increases use. The <strong>US</strong>FS stocking program is responsible for the<br />
near extirpation of native brook trout. The <strong>US</strong>FS stocking program causes the “potential conflicts” that<br />
the EA bans paddling to prevent. Failing to analyze stocking while banning paddling to limit use is<br />
analogous to failing to analyze a program that releases bark beetles while mandating timber harvest in<br />
response to a bark beetle infestation. The <strong>US</strong>FS is causing the impact that the EA proposes to manage.<br />
Rather than considering limiting the cause, the EA irrationally proposes to eliminate the effect by banning<br />
paddling. Doing so fails to consider and implement indirect use limits prior to direct limits and thus<br />
violates the FSM and the Appeal ROD. It fails to equitably limit use which violates the Appeal ROD and<br />
FSM. It fails to consider a reasonable range of alternatives by ignoring a primary impact, which violates<br />
NEPA. (Ltr# 168, Cmt# 24)<br />
Fact of the matter is, you aren’t doing anything but making it worse with stocking fish. The non-native<br />
species feast on the native Brookies, furthering their demise. When you stock, everyone knows it, and<br />
people from all over come and stand around the bend and net scoop fish up and fill the coolers. What a zoo<br />
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