I’m sure most of you are aware of this but I thought I would bring this discussion to the BWA Speak page. Not all of us including me get the BWA forum email updates any more so we come and check the BWA forum to get our info. I personally have not always checked the Keep Our Rivers Flowing Page so that’s why I’m bringing this up now. My selfishness had me only looking at wether my buddies were heading out after a good rain or not. Or whether George was making some new friends in the Lounge : - ) , shame on me.

There is serious need for all of us to submit our comments to National Forest Service regarding the Chattooga head waters. The comments are due before Friday August 1. That gives us less than 48 hours to get our comments in.

Go here: [www.americanwhitewater.org]

And here: [www.americanwhitewater.org]

To get more information on what to do.

Please if you have not taken the time to send in your comments do it right now. This affects us all as paddlers. After finishing the BWA video I finally took the time to send my comments in.

I personally want to thank Brent Austin, Allen Kirkwood, Wes Prince, and others for your efforts concerning this issue. You all are keeping this new conservation officer from loosing touch with what’s really going on in the paddling world that affects us all.

Ledgeman



Edited 2 time(s). Last edit at 08/21/2008 01:29PM by jasonfoley.

Update from the USFS...Comment Period Extension...

Quote:

Today the US Forest Service announced that they will grant the public another 2 weeks to submit comments on their "environmental assessment" of recreational use in the Wild and Scenic Chattooga River corridor. The new comment period ends August 18th

[www.americanwhitewater.org]

Thanks for posting this Brandon. Just noticed it. Another extension, this one until August 18, 2008. I don't know yet if it is due (again) to prolific boater letter writing, but, I suspect that played a role. Thanks to eveyone that did. Thanks Ledgeman for your comments. We need everyone's support on this BIG issue for all boaters. Stay tuned. If you haven't written a letter yet, please, please do.
Brent

Have you sent your letter to the USFS concerning the "boater ban" on the Upper Chattooga? The dead line approacheth....

Here's a sweet letter sent in by an old schooler...

July 22, 2008

Jerome Thomas
Forest Supervisor
Francis Marion and Sumter National Forests
US Forest Service
4931 Broad River Rd.
Columbia, South Carolina 29212

Attn: Chattooga Planning Team

Jerome, Thanks for the opportunity to comment on the draft EA for the Upper
Chattooga River. It appears that reasonable comments and input are sorely
needed. As a history, I boated the upper river in the early 70's, before the
arbitrary, capricious, and probably unlawful closure by the Forest Service in
1976. I obeyed the rule of law, and now, regardless of the eventual access
decision, at 70+ years I will never be able to boat those magnificent gorges
again.

Similarly, thousands of boaters have seen their prime years pass without ever
being able to legally use the river.

The closure issue, this decision and its casual flaunting of equity and rights has
been divisive and has produced major questions as to the Forest Service’s
objectives and ability to handle complex and adversarial issues. As an aside,
having a Trout Unlimited executive as the Forest Supervisor for an extended
period did not aid in the issue either.

At the start of this process, several years ago, I had conversations with several
whitewater clubs people. I assured them that today’s Forest Service would be
even-handed and give the boaters a fair hearing. It appears I was wrong. To put
my response in perspective, please note that I have consulted to Federal
agencies since 1969, served as a expert witness on water related issues, and
was the Mission Contractor for Region IV, USEPA for Environmental Studies of
the impact of Federal actions. The projects often involved public presentations. I
have done hands-on and design work for geohydrological restorations on the
Chattooga and other Federal projects. In all of these activities, fair and objective
consideration of alternatives before acting was essential, and even the
appearance of bias was to be avoided.

It is counterproductive to address one "use" of the corridor in flowery terms, while
starkly pairing the other use alternative with "conflict" or "loss" wherever it occurs.
Yet, the existing rainbow trout fishery is described in your letter and the three
pages of alternatives as:

● -"high-quality trout fishing experience"-
● -"one of the unique premiere trout fisheries for backcountry anglers
seeking remoteness and solitude in the southeast"-

● Boating? Boating is mentioned with the need to:

● "Minimize conflict between boaters and anglers by establishing flow and
season(al) restrictions for boating"
● Maintain a "boatfree recreational experience"
● Boating is considered a threat to "uniqueness" and to "unique
opportunities for enhanced solitude"

There’s more, but the simple fact is the fishery is a trout-farm based, put and
take fishery based on a species alien to the area, providing recreation to a very
few people. There are many questions raised in my mind by the verbal "color"
attached to each use. For instance;

● Where on the entire Chattooga River are fishermen excluded to provide
"solitude" and "uniqueness" of experience for boaters?
● Where do you note the differing impact of shoes of fishermen, hikers,
campers, bird watching groups, compared to the passage of a boat?
● There are trail problems noted in the alternatives. Are those trails the
result of boaters’ visits or of fishermen and hikers?
● There is frequent use of "uniqueness" to describe a put and take fishery,
and almost no notice for the incredible white water, and the truly unique
boating experience.

The level of skill and perception required to enter and use this wilderness area
for white water boating are high. There is a reason that boaters have fought to be
allowed to use this segment of the Chattooga, and it is the truly unique white
water, not the artificial fishery.

The blatant attempt to make boating more dangerous or impossible by
prohibiting removal of " large woody debris" apparently came from a Forest
Service sycophant’s input. The removal ban would be laughably absurd if it were
not so dangerous and unscrupulous. It would be appropriate to list the name of
the individual suggesting the protection of woody debris against the loss of life of
a hapless fisherman, hiker or boater. I think this suggestion is the height of
absurdity.

There is a curious inconsistency about a purportedly fair review that touts fishing
as though it were unique and had no impact, vilifies boating as destroying
uniqueness and solitude, ignores hiking, birding and other uses with their
impacts, and wishes to leave trees across the stream to the risk of injury and
death for boaters, hikers, swimmers, and other users. So much for an objective
study.

The two different descriptions of the regulatory trigger flow for alternative 4 are
curiously unknowable and perhaps not even capable of attempts to calculate,
except retroactively. I can visualize boaters detained by Forest Service
personnel, standing at some gauge until midnight in the dead of winter, at which
point the Ranger say "Aha. Got you. See, the average flow was 451 cfs, but the
mean daily average flow level was only 448.5 cfs." It is interesting that a
basically incalculable number would have to be calculated before going to the
river in mid winter, where you park miles away, walk in with your gear, calculate
the river’s cfs accurately, enter the river, avoid touching the trees blocking the
channel at some point, cannot legally use the most attractive areas of the river,
and get out, only to find your calculations were for the "average mean daily flow
level", not the "mean daily average flow level" and that you are boating
unlawfully. If this sounds ridiculous, it is.

To this point, the Forest Service has been a friendly agency to users of the upper
Chattooga, except boaters. The proposed alternative 4 regulations for boating
display the same blind bias that has prevailed for 36 years. Surely, after years of
delay, we could expect a document without the inherent bias shown in the
current proposal.

Please accept these comments as a suggestion that I don’t think Alternative 4 is
objective, reasonable, fair, logical, or capable of actually achieving balanced
management of the Magnificent Upper Gorges of the Chattooga.

Very truly yours,
Claude E. Terry
Atlanta, GA

Here's a little more reading on the issue. Props to Ranger Rob(Rob Maxwell), my latest new hero...

[boatertalk.com]

Also from Rob Maxwell...

"Hi Everyone,

As most of you know, we are in the final days of fighting to open the
Upper Chattooga to boating. Things don't look that good for us. So I'd
like to take the fight to a national boating public. Here's where you
come in.

Below is a post I wrote for distribution to boater message boards and
boating e-mail lists. If you would please take a few minutes and post
this to every local, regional or national boating related message
board you use, I'd appreciate it. Also, please e-mail it to all your
boating buddies and ask them to do the same.

We are running out of time to put pressure on the Forest Service to do
the right thing. I can only do so much by myself. Your help would be
greatly appreciated.

If you have a minute, check out BoaterTalk.com and read my post about
how the Forest Service is allowing the East Fork of the Chattooga
River to be polluted.

Thanx -- Rob Maxwell

Here's the post*************************

TITLE:
USFS Considers Banning Boating in all Federally Managed Lands!

BODY COPY:
Whether you know it or not, on August 18th the Forest Service will
establish a precedent that can lead to the banning and/or severly
restricting boating in all Federally Managed lands. Yes, your favorite
rivers and creeks that are Wild and Scenic Rivers; Federal Wilderness;
or in National Parks and recreation areas may soon be off limits to
all boating.

What?s going on? Whitewater boating was banned on the upper sections
of the Chattooga River 30-years ago by a single rouge park ranger,
without public comment or impact studies. He simply waived his hand,
and it was so. Now 30-years later, politically powerful special
interest groups, with significant pull in Congress and the Forest
Service are fighting to maintain this boating ban, which should never
have been established in the first place.

How does this effect you? The Upper Chattooga ?Capacity and Conflict?
study, commitioned by the Forest Service, outlines rationale and
management practices for severely restricting or banning boating on
federal lands. The report is well footnoted with dozens of studies and
management techniques from across the nation. If things that happen in
the north, south, east and west can be used to continue the boating
ban on the upper sections of the Chattooga River, they can be used
against you and your rivers. You can check out the ?Capacity and
Conflict? study and its array of footnotes here:

[www.fs.fed.us]

Imagine a day when the Forest Service closes your favorite run and
says, ?They did it on the Upper Chattooga, we can do it here.? There
will be no impact studies. Public comments won?t matter. Political
pull or a single rouge park ranger is all it will take. The precedent
will have already been set on the Upper Chattooga.

How can you help stop this? The deadline to send in comments to the
Forest Service is August 18th. If you are too busy to learn all the
details and craft the perfect comment letter, there is a link to a
well thought out form letter below. Simply add a few personal touches
and e-mail it to the Forest Service, the Chief of the Forest Service,
and your Senator and Congressman. Its simple, all of their e-mails are
also listed below. Let them all know you are against bans on any user
group, in federally managed lands, without proper justifications and
impact studies. Remember, the river you save could be your own.

A form letter:

[www.americanwhitewater.org]

For detailed facts on the Upper Chattooga boat banning check out these sites:

[www.americanwhitewater.org]
[www.americanwhitewater.org]
[www.americanwhitewater.org]
[www.fs.fed.us]

E-mail your letter, by August 18th, to the Sumter National Forest at:

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

E-mail the Chief of the Forest Service in DC at:

akimbell@fs.fed.us

Ask your Senator and Congressman to write a letter condemning this
unjustified boating ban.

Find your Congressman at: [www.house.gov]

Find Your Senator at: [www.senate.gov]

Help your boating brothers in the Southeast stop this unjustified ban
before you have to fight it in your own backyard.

Thank you
--Rob Maxwell
Atlanta, GA"

Forest Service Publishes Upper Chattooga "To Do" List New
Forum: BoaterTalk
Date: Aug 14 2008, 11:49 GMT
From: rangerrob

Since the Forest Service is a government agency, it is periodically required to report what jobs it plans to accomplish. You might call it a public “to do” list. Last night I came across the Francis Marion’s and Sumter National Forests’ 07/08 – 9/08 Schedule of Proposed Action (SOPA) report and found a rather interesting item. You can see the report here:

[www.fs.fed.us]

Check out the bottom of page 6 under the heading “Trout Stream Habitat Improvement” it says the Francis Marion and Sumter National Forest Rangers’ job will be the:

“Creation of pool habitat in brook trout streams by adding woody debris to the stream channel with the use of chainsaws.”

That’s really not much of a surprise since the Forest Service’s main ORV (Outstanding and Remarkable Value) for the Upper Chattooga is the artificially created wild fishery. Buzzing chainsaws and helicopters are just a bonus. But wait! There’s MORE………

What does the Final Draft EA say about woody debris?

SUMTER NATIONAL FOREST

• Perennial and intermittent streams are managed in a manner that emphasizes and
recruits large woody debris. The desired condition is approximately 200 pieces of
large woody debris per stream mile.
• The removal of large woody debris (pieces greater than 4 feet long and 4 inches in
diameter on the small end) is allowed if it poses a risk to water quality, degrades
habitat for riparian-dependent species, for recreational access, or when it poses a
threat to private property or National Forest infrastructures (i.e. culverts, bridges).
The need for removal must be determined (by the Forest Service) on a case-by case
basis. Except in unusual circumstances, woody debris embedded within the
channel materials will not be removed.

CHATTAHOOCHEE AND OCONEE NATIONAL FOREST

• The removal of large woody debris (pieces greater than four feet long and four
inches in diameter on the small end) is allowed only if the debris poses a risk to
water quality, degrades habitat for riparian-dependant species, or when it poses a
threat to private property or Forest Service infrastructures (i.e. bridges). The need
for removal must be determined on a case-by-case basis.

NATIONAL FORESTS IN NORTH CAROLINA

• The Desired Condition for LWD is 100 pieces per stream mile (9" min width and 6'
min length) reasonably distributed. Retain all LWD unless conditions exceed the
desired condition.
• Base decisions regarding retention, addition or removal of large woody debris on
site specific analysis. Coordinate with scenery and recreation objectives.

Yes, you read that right - the Forest Service can add or remove wood debris anywhere for any reason. Since wilderness preservation is (sometimes) their main objective, we’ll have to trust their judgment. But wait! There’s MORE…………

What does it say in Alternative #4, the preferred management plan?

"Maintain current management. (that is all the stuff above) No LWD (large woody debris) removal to accommodate boating."

Yes, you read that one right too! No wood removal, for any reason, if it pertains to boating. All other reasons are OK, just not for boating. Don’t expect the Francis Marion’s and Sumter National Forest Park Rangers to roll out the welcome mat for Boaters. Remember, they were forced by their boss, the Chief of Forest Service, to justify the 30 year old boating ban. Since they couldn’t we got the “de facto” boating ban in #4. It makes sense if you remember boating is banned/restricted without an impact study and fishing is allowed without an impact study. Ah, government!

I could be wrong, but wouldn’t cutting a dangerously placed section of log out of the river and leaving the cuttings in the river create “pool habitat in brook trout streams by adding woody debris to the stream channel”? I’m just a boater, what do I know?

Remember Claude Terry’s comment letter? He said:

“The blatant attempt to make boating more dangerous or impossible by
prohibiting removal of " large woody debris" apparently came from a Forest
Service sycophant’s input. The removal ban would be laughably absurd if it were
not so dangerous and unscrupulous. It would be appropriate to list the name of
the individual suggesting the protection of woody debris against the loss of life of
a hapless fisherman, hiker or boater. I think this suggestion is the height of
absurdity.”

Now let’s connect all the dots:

Forest Service adds wood to improve non-native fish habitat.
Forest Service removes wood for any reasons they see fit.
Forest Service would rather see someone die then remove wood to accommodate boating.

Conclusion: The Forest Service wants live fish and dead people.

Now that’s an “Outstanding and Remarkable Value!”


Get your comments in, time is running out!

Thanx – Rob Maxwell

Date: August 14, 2008 (ONLY 4 more days left to respond!)
Subject: H2O: New MAJOR Development in Upper Chattooga Fight

Trout Unlimited is teaming up with the "Camo Coalition" for a last
minute push for comments on the Upper Chattooga. On the
CamoCoalition's web site is a page with a form letter. All the
anti-boater, wilderness destroying crowd has to do is type in their
name, e-mail, street address and click send. Lazy! Then the Forest
Service gets this e-mail:

**************************************************************
Subject Line: I support Alternative 1

Body: I appreciate the opportunity to voice my opinion on the Upper
Chattooga Environmental Assessment. The Upper Chattooga is a unique
biological and cultural resource that will be changed forever by the
human impacts associated with boating and would be best protected by
no change in the current management. I support Alternative 1.

Thank you!
*************************************************************

Now here's where the fun starts. Here's the link to the letter, scroll
down to the bottom:

[www.camocoalition.com]

Keep the "Michelle Burnette" box checked, that's the PR lady at the
Forest Service

Change the subject line to read:

I support Alternative 8

Cut-n-past this body copy into the form.

I appreciate the opportunity to voice my opinion on the Upper
Chattooga Environmental Assessment. The Upper Chattooga is a unique
geological and cultural resource that is being polluted and destroyed
with the stocking of non-native fish and the human impacts associated
with fishing. I would support the banning of all stocking of
non-native fish in the wilderness area and would welcome the
introduction of low impact sports such as boating. I support
Alternative 8.

Use your real name, address etc.... at the bottom. Remember it goes to
the Forest Service and WILL count as a comment. BUT that doesn't
releive you of your sworn duty to sent in your own real letter!!!!

MAKE SURE YOU CLICK THE BOX THAT SAYS: "Do not send me future Action Alerts"

Now click "Send Message"

E-mail this to all your friends and please post it to all your message
boards and blogs. The push is on. We are in the final hours. I think
I'm gonna need a body guard when this is all over -- TU is gonna kill
me!!!!!!!!!

Back of the bus everyone!!!!!!!!
Rob Maxwell
Atlanta, GA

Thanks Barry. Yes, that WAS fun!
Chris S

Chris Schardl

removing as a sticky note, noting to keep up top

Congrats to AW's President, Don Kinser for an awesomely written comment. The boating ban must not stand!
barryg

AW Big Wig Don Kinser's Upper Chattooga Comments New

Forum: BoaterTalk
Date: Aug 21 2008, 0:54 GMT
From: rangerrob


NICE JOB DON!!!!!!!
*****************************************

August 18, 2008
VIA EMAIL: comments-southern-francismarion-sumter@fs.fed.us

Mr. Tony White
4931 Broad River Road
Columbia, SC 29212-3530
Re: Official Comments on July 2 EA
Upper Chattooga River Management

Dear Mr. White,

You must be joking! Your recently published EA is a sham and provides absolutely
no basis what so ever to limit boating much less ban it entirely. Your preferred
alternative is nothing more than a de facto ban and the “predictable mean daily flow”
idea is absurd. Do you really think you have the ability to predict the flow in the river?
This flawed measure is nothing more than a way for you to ensure that boating never
occurs.

I had the honor and privilege to participate in your Expert Panel and paddle the river
in January 2007. On the two days we were allowed to paddle the upper river the flow
was approximately 340 CFS. This is well below your absurd threshold of a
“predictable mean daily flow of 450 CFS.” I remember vividly, and others there will
attest to this fact, that the anglers refused to fish in the Rock Gorge section of the
river that day because it was “too dangerous.” On the other hand 340 CFS was more
than adequate for paddling use.

You continue to maintain that the Chattooga is an outstanding fishing resource. The
truth is that the Chattooga is a marginal cold water fishery made possible entirely by
hatcheries and costly human intervention. In fact your own studies show that anglers
don’t even rank the Chattooga tops in the region, yet you failed to acknowledge these
studies in your EA. Worse yet your supposed “Environmental Assessment” failed to
address the significant environmental impacts from the hatchery and the use that
stocking attracts to the river.

On the other hand, the Chattooga River is a world class whitewater river. I know first
hand because of my river experiences around the world. For this reason I have
chosen to live there. It is also why whitewater paddlers from across the country and
around the world choose to visit the Chattooga River and why I have been working
diligently to restore whitewater paddling access to the upper 21 miles, nearly half, of
this National Wild & Scenic River since 1998.

The report entitled “Capacity and Conflict on the Upper Chattooga River” clearly
shows that paddling impacts would be negligible, expected paddling use will be low,
and most importantly that the normal flow regime naturally segregates use.
Furthermore the flow regime results in a very small number of days each year where
whitewater boating is even feasible. In many ways, paddling is the best and lowest
impact way to access this area. This was true in 1971 when the Chattooga Study
Report declared when speaking of the Chattooga above Highway 28:
“Rafting or some method of floating is the best way to see this rugged portion
of the river. Many of the pools and canyon-enclosed sections are 10-20 feet
deep and impossible to wade by hikers and fishermen.”

I fully support protecting the Chattooga River and I am hopeful that the FS will finally
do something to manage use on the upper river other than to simply ban floating
(which has little impact on the environment). A good start would be self issued
permits for all users of the upper river corridor, including boaters.

You should eliminate stocking of non native exotic fish. This not only damages the
natural ecosystem but actively attracts use. Here seems to be the Agency’s perverse
logic: The resource is over used and we need to limit visitation to protect the resource
so let’s stock exotic fish, build a camp ground and parking lot and ban boating.
You should enforce your existing regulations regarding campsites, user created trails,
litter, etc.

I want to emphasize here again, the indisputable fact, that the upper Chattooga’s
normal flow regime will naturally segregate anglers and paddlers in time and space.
We told you this for free in 2001. All the data and research that you have now paid
millions in tax payer dollars for fully affirms this. I challenge the FS to find a more
eloquent, fair and implementable decision that to simply allow boating on the upper
Chattooga and let nature take care of the rest. It works on every other headwater
stream in the Southeast, and indeed across the country, and it will work on the upper
Chattooga too!

Since 1999 I have invested well over a man-year of my time working toward fair,
equitable, and nationally consistent management of the Chattooga River. Your failure
to listen to those of us who support floating use on the upper Chattooga and your
smug coziness with the local anglers, land owners, state DNR staff, and others who
claim to “protect” the Chattooga by excluding boaters is appalling. Worse yet, your
flawed process that arrived at the pathetic EA document is inexcusable. So is the
magnificent amount of money you have wasted. I only wish you had spent as much
protecting the river has you have spent trying to protect a flawed and indefensible
status quo

You have missed every deadline during this entire process. You have spent 39
months doing a “capacity” study yet you didn’t arrive at a capacity for any use and
certainly not for boating use. You only allowed boats on the river for 2 days in
January 2007 under highly contrived and constrained conditions. You have no idea
what the actual boating capacity for the upper Chattooga river might be.
For these reasons I support Alternative 8 of your scoping document. However I must
qualify this and say that Alternative 8 is flawed in many ways as is the entire list of
Alternatives presented in your scoping document. First all of the alternatives must
treat boaters equally with other users unless you can present factual data to suggest
impacts that would be greater from boaters. You can not show this with the data you
have published.

Your Chief said this in his appeal decision:

“While there are multiple references in the record to resource impacts and
decreasing solitude, these concerns apply to all users and do not provide the
basis for excluding boaters without any limits on other users.”

So which is it? Is the resource beyond its carrying capacity and, if so, what limits will
you place on all users of the corridor? None of your alternatives limit any user except
boaters so one must assume that you believe the resource is not beyond it carrying
capacity. Since you don’t know the total carrying capacity how can you say that
adding boating use would exceed the river’s capacity? You can not.

I don’t claim to know the “capacity” of the Chattooga River for boating use but I do
know it is not zero! It is far greater than zero. Any decision that bans or limits boating
is simply not defensible based on the data in the record.

Your Decision Must Not be a (Local) Popularity Contest!
You can not make a decision to continue the illegal boating ban based purely on local
public sentiment (or outcry) over this issue. Yet that is what you seem intent to do
guided primarily by the vitriolic and unfounded rhetoric from a few passionate locals
despite all USFS national policy to the contrary.

This is not a local issue and this is not a private resource. This is a National Wild &
Scenic River!

You have received literally thousands of pro-boating comments from across this
great country over the past several years. Many of these pro boating comments are
thoughtful, specific and well written (and this is more than be said for most of the
“status quo” crowd).

This is despite the fact that 99.99999999% of the boating world has never had the
opportunity to experience the upper Chattooga because of the 32+ year illegal ban.
All the hard science and real data supports hand powered, private floating use as a
legitimate use on the upper river.

Where’s My Chance for Solitude?
You must explicitly acknowledge that all private, non commercial users, except
paddlers have unlimited and unfettered access to the entire length of the Chattooga
Wild and Scenic River. Not one single angler, hiker, birder, hunter, nature lover, or
solitude seeker has been displaced from the Chattooga River below highway 28 by
any USFS policy or restriction, any assertion to the contrary is simply untrue and
disingenuous. Choosing not to visit a certain place is not displacement – it is simply a
personal choice.

Yet I, as a private, self guided whitewater paddler, have been displaced exclusively to
the lower river since 1976 where I must contend with some 40,000 commercial users
a year! Where’s my opportunity as a paddler for the cherished back country
experience and solitude provided by the upper Chattooga River? Certainly it is
not on the lower river where commercial use is emphasized over private, self guided
use. No where on the river do you manage the resource with any regard what
so ever to the solitude and wilderness experience of the private, self guided,
paddler.
This is unacceptable. My solitude as a wilderness compliant user is just as important
as anyone else’s and all the alternatives should fully reflect this important fact.

Boating is a Legitimate Historical Use!
Boaters were enjoying the upper river prior to W&S designation. It is illegal under the
National Wild & Scenic Rivers Act to exclude an historic use in the absence of any
science or data suggesting impacts to the resource.

The USFS must revise the alternatives and needs to get back to basics:

􀂄 You must acknowledge the results of the boating study which clearly
demonstrates that boating remains an important and outstanding form of
recreation on the Headwaters that must be protected and enhanced under the
law.


􀂄 You must propose a range of alternatives for protecting and enhancing
whitewater boating on the Headwaters; and

􀂄 To the extent the USFS wants to consider other management issues you must
separate out these important management issues for consideration based on
alternatives relevant to those issues and not confound and obfuscate the
question relative to boating.

I fully support American Whitewater’s comments regarding the EA and make them a
part of my comments by reference.

The boating ban on the upper Chattooga River, now in place for over 32 years, is
unfair. I also believe it is illegal and just plain wrong. It is well past time that the FS
does the right thing and reaches a new decision that reverses the illegal and
inequitable ban on floating the upper Chattooga River.

Sincerely,
Donald E. Kinser