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
there is for law enforcement expenses while more taxpayer revenues can be spent on fish and wildlife
habitat improvement. (Ltr# 135, Cmt# 4)
Subconcern # A
The biggest question I have is on the issues of monitoring and enforcement. Monitoring is the cornerstone
of how the agency is to manage the river and utilize adaptive management. Yet the monitoring plan consists
of four paragraphs on page 37 and 38. There is insufficient detail as to the who, what, where, and how it
will be accomplished. In order to do what the agency commits to here please lay out the plan in more
detail. The monitoring described in the appendices lacks specific detail (who, when, where, frequency).
How often will sampling occur to be statistically valid? Who will do the sampling, existing personnel on the
districts already have fulltime jobs. To totally do the monitoring required e.g.. large woody debris removal,
trail condition trends, campsite condition trends, conflict, etc. will additional personnel be hired/contracted
to complete the monitoring each year? (Ltr# 139, Cmt# 5)
Subconcern # A
Tied to monitoring is enforcement. If the take out is Lick Log how will it be enforced to restrict boaters
from floating on down to 28? Illegal boating is already occurring now on the upper Chattooga and in the
tributaries. If closures can't be enforced now how will it be seriously enforced at Lick Log? With limited
resources for enforcement the take out should be moved up stream to the Burells Ford Bridge. (Ltr# 139,
Cmt# 8)
Subconcern # A
Whitewater boaters already have access to the majority of swift rapids in the area, including the entire
West Fork of the Chattooga, and all of the Chattooga below the Highway 28 bridge. Overflow Creek all the
way to North Carolina is also already open to boating. Given the Forest Service’s shortage of personal to
police and protect this fragile and important ecosystem I see no way that adding additional users of any
type is helpful. (Ltr# 140, Cmt# 4)
Subconcern # A
Effective adaptive management depends on robust monitoring, and the EA places great faith in the ability
of monitoring to prevent harm to the fragile Upper Chattooga environment. The Forest Service must
establish and commit to a well defined and detailed monitoring plan that is reviewed and updated annually
and that is linked to management. Any alternative that adds boating to new segments of the Chattooga will
increase the need for law enforcement and increase the area over which it will have to operate. The EA
does not describe by what mechanism or authority changes will be made to the management of each of the
three Forests. The expected sources of funding, as mentioned above, to support management changes
should be identified and discussed. (Ltr# 166, Cmt# 8)
Subconcern # A
Georgia ForestWatch and Wilderness Watch are particularly concerned that proper steps should be taken
to monitor and “adaptively manage” the Upper Chattooga regardless of the alternative chosen. Any new
or continued boating access must be contingent upon the receipt annually of the budgetary resources
necessary to enforce use rules. The EA at Appendix B (Implementation Strategy and Monitoring Questions)
posits that it would require the equivalent of more than three full-time Agency staffers in the first four years
of an Alternative 12 proposal at a combined cost of $280,000, and more than one full-time staffer and
$50,000 in “years 5 and beyond.” The problem with this staff-budget construct is that there is no
commitment to actually commit the necessary manpower and taxpayer resources to perform what the
Agency estimates it would take to properly manage the Upper Chattooga under Alternative 12. We are
especially concerned that the three affected National Forests apparently would strive to accomplish these
minimal aims without hiring additional staff. Rather, the Note to Appendix B states that “numbers
associated with staffing and dollars should not be interpreted as additional staffing. They represent work
that will be accomplished with existing staff or additional hires, and may be associated with permanent,
seasonal or shared positions. Dollar amounts do not include costs associated with materials, supplies,
contracts, fleet, travel or overtime.” This truly is astounding! What the U.S. Forest Service is saying in
this instance is that it would like to provide for “adaptive management” of new limits and uses on the
Upper Chattooga, but cannot commit even to the minimal manpower and dollars estimated necessary to
doing so. (Ltr# 166, Cmt# 36)
Subconcern # A
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