The Wild and Scenic Upper Chattooga River borders North Carolina, South Carolina, and Georgia, and has been banned to kayaking, canoeing and rafting for over 30 years - without any basis. The US Forest Service has prepared a new Environmental Assessment (EA) of the issue that recommends maintaining the ban - once again with no basis. AW has finished our initial review of the EA and we will be filing detailed comments on the EA prior to the August 1st deadline. We encourage paddlers nationwide concerned with the management and protection of rivers across the country to submit comments.

The proposed management action on the Chattooga will influence the management of rivers across the country and would create a selfishly motivated precedent that would negatively impact rivers, managers, and recreationists. Private landowners are seeking a monopoly on a Wild and Scenic public river, the Forest Service is seeking to strip basic protections from Wild and Scenic Rivers, and other stakeholders claiming zero-tolerance of paddlers are seeking to have paddling prohibited. Boaters are irrationally being singled out for adverse treatment, even while the Chief of the Forest Service directed that all users be treated equitably. Many river professionals and Forest Service personnel are behind us, but it is up to us to stop this nationwide train wreck.

The EA follows the same format as the Forest Service's past assessment of the issue: they list a string of ecological effects common to all recreation, then discuss abstract user conflicts that have never occurred and will never occur, and then make a recommendation that essentially renews the ban on floating the Upper Chattooga River, while allowing all existing recreational users unlimited access without providing any rational basis for the discrimination. There are a few differences though. They propose to allow a few people to paddle roughly a third of the upper river somewhere between zero and six days a year in the middle of winter at high water based on an impossible set of logistical hurdles. This miniscule paddling allowance is so small and bizarre it is realistically a total ban. The rest of the upper river and its tributaries remain totally off limits to paddlers. A second major difference is the exclusion of the uppermost section of the Chattooga and its tributaries from even a cursory discussion. In addition, this EA cost taxpayers several million dollars.

The EA is not viable and breaks many basic rules and laws for preparing such documents. It is quite clearly not a scientific document; it is a philosophical and political one. It flies in the face of the successful AW appeal decision that required a user capacity analysis (which has not been conducted) and equitable treatment of all users if limits are needed to protect the resource. The new EA essentially claims that the river has a capacity of zero boating and a capacity of infinite hiking, angling, and camping. That is hardly equitable.

PLEASE SUBMIT COMMENTS by August 1, 2008 [deadline extended to August 18, 2008] TO:

comments-southern-francismarion-sumter@fs.fed.us

or surface mailed to

U.S. Forest Service

Chattooga River Project

4931 Broad River Road

Columbia, SC 29212.

A copy of the EA and a summary of the alternatives is available on the Francis Marion and Sumter National Forests' web site at http://www.fs.fed.us/r8/fms.

A sample letter is provided below. Please consider writing your own letter from scratch if at all possible or personalizing the sample letter. PLEASE also send this letter (or a similar letter) to your Representatives and Senators in Washington DC - no matter where you live.

U.S. Forest Service

Chattooga River Project

4931 Broad River Road

Columbia, SC 29212.

comments-southern-francismarion-sumter@fs.fed.us

[INSERT DATE]

RE: Chattooga River Project Comments

Dear Sumter National Forest,

[INSERT description who you are, where you live, what you do, why you care, etc]

I have reviewed the Environmental Assessment regarding the recreational management of the Chattooga River. I disagree with your analysis and your proposal. Both treat me and my community of river enthusiasts unfairly and your proposal would not meet my interests. Please consider the following concerns I have regarding this issue:

[SELECT a subset of these bullet points or write your own - please personalize]

• The USFS has spent thirteen years searching for a reason to limit paddling on the Chattooga and has found none. It is time to open the river to boating.
• The EA is not a user capacity analysis and does not reference one. The AW appeal decision required a user capacity analysis. Where is it?
• No alternative is acceptable because they all include boating bans on the upper Chattooga Cliffs reach and on tributaries - without any justification.
• The EA and preferred alternative are not equitable or protective of the river because they considers boating to be the only management variable, while other larger more impactful uses are not seriously considered for limits.
• The USFS preferred alternative includes a total ban on 2/3 of the upper river, a ban on tributary boating, and allows only 0-6 days of limited boating on the remaining reach - while allowing all other wilderness conforming existing uses in unlimited numbers.. This is not equitable and not acceptable!
• The EA offers no basis for the boating bans and limits
• The EA lacks a full range of alternatives
• The EA is no better or different than the last one, is at least a year late and has wasted millions in tax payer money
• The USFS hired qualified consultants and then ignored their input
• The 450 CFS average daily flow trigger in the preferred alternative is a flawed measure that should be eliminated from any considerations. There is no way a paddler can know this number and will be an administrative burden for the agency.
• Paddlers prefer an alternative similar to Alternative 8 that 1) fully allows boating on the entire Chattooga River below Grimshawes Bridge, 2) allows paddling on tributaries, 3) includes encounter standards based on a real user capacity analysis, 4) will equitably limit total use only when encounter standards are consistently exceeded, and 5) will do so using all available indirect measures first.
• The public should have the right to float on public Wild and Scenic Rivers regardless of who owns the land along the river.
• All aspects of the "Outstanding Remarkable Values" of Wild and Scenic Rivers should be protected on the entire river, not just in some areas.

Thank you for considering these comments. Please consider conducting a real user capacity analysis and immediately allowing boating in the same numbers, places, and seasons that you allow existing users. Paddling should be allowed in a similar manner to your alternative number 8, except on the entire Upper Chattooga River and its tributaries.

Thank you for considering these comments,

Sincerely

[INSERT name and address]