American Whitewater sincerelythanks the many hundreds of AW members and other whitewater enthusiasts that tookthe time to contact the Forest Service and let them know how important the
On July 3, after hundreds ofhours of volunteer and staff effort, AW submitted our official comments andweighed in on the proposed Sumter Forest plan and boating access on theChattooga Headwaters.
Stay tuned to AW’s website for further developments this summer and fall regardingthe
AW focused our commentsregarding the proposed Sumter Forest Plan and the accompanying DEIS in thesetwo areas:
1. The Appendix H analysis regarding boating use on the
2. Issues that impact user experiences on the
When we refer to the“Chattooga Headwaters” or simply “Headwaters”, we mean the entire river from
Summary of American Whitewater’s Position
We are generally supportiveof Alternative I – the preferred alternative – as a prescription for overallforest management. We strongly support improvements in riparian environments,reduction in allowable timber harvest and the other conservation objectivesthat are part of Alternative I. However, we have some very specific objectionsto certain aspects of the proposed plan that deal with management ofrecreational boating on the
Specifically, and mostimportantly, we want to see the final Forest Plan (Alternative I) modified toallow boating on the Chattooga River above the US Highway 28 Bridge year roundat all water levels as originally intended by the 1971 USFS Study to includethe river in the National Wild & Scenic Rivers system.
The Agency’s own surveys andstudies support the facts that year round boating above Hwy 28 on the Chattoogawill have minimal or non-detectable impacts. These studies detail that:
§ Boating use isconsistent with all applicable laws and regulations.
§ Boating use isself-regulating based on precipitation and water level.
§ There are lowamounts of actual available river use.
§ There are noidentified negative ecological or biological impacts.
§ Allowing accessrequires no significant capital expenditures for improvements.
§ Allowing boatinguse minimally impacts only one very small user group (back country anglers) andthis impact amounts only to social interactions with boaters that would bemeasured in seconds on a handful of days each year.
Thus the decision to liftthe prohibition on floating the Chattooga Headwaters should result in a Findingof No Significant Impact (FONSI) under the National Environmental Policy Act(NEPA);
If the Agency has anystudies or research contradicting this summary of float use above Highway 28,then the Agency has a legal responsibility to cite and include the results ofthose references in this DEIS. As no applicable studies were referenced, ourconclusion is that none exist. If this conclusion is inaccurate, then theAgency must reference those studies in the Record of Decision (ROD).
In addition, there areseveral areas that we wish to comment on regarding the Area 2 ManagementStandards in the proposed Plan. These areas include:
§ Whether apotential self-guided boater reservation system is being considered, and if sowhat should it look like it?
§ How the Agencywill manage the overlap of guided use between Thrift’s Ferry and WoodallShoals?
§ How the Agencywill manage vehicular access to the river at Sandy Ford and Earl’s Ford on the
§ What actions andstudies the Agency is planning to generate better data on all users of theriver corridor?
§ What actions theAgency is taking to comply with previous plans to remove the old US 76 Bridgeand the replacement of the current US 76 Bridge and the potential replacementof other bridges on the river?
§ What actions theAgency is taking to comply with the Wild and Scenic Rivers Act and Clean WaterAct to improve water quality throughout the watershed and particularly Stekoa Creek?
§ Whether anyfuture user fees are being considered and the nature of those fees?
We request that the Agencyrespond to each of these questions in the ROD, as each is relevant andapplicable to the scope of the DEIS.
Further, the decision toclose a floatable section of river to all boating at all levels was madewithout following an open NEPA process. Our research and analysis of records,which were collected through a 2002 Freedom of Information Act (FOIA) requestas well as through our independent research, reveal that the Agency did notsolicit any public comment, commission appropriate studies, or seek balancedexpert opinion regarding this action before the decision was reached.
The Forest Service is a multipleuse Agency. One motto the Agency uses is “
According to Forest Servicedocuments, the Agency manages at least 4,348 miles of Wild and Scenic Rivers.This is notable because float use is not denied on the basis of user conflicts(especially not on minimal, undocumented, decades old,anecdotal user conflicts) on any of those river miles except on the
In fact, float use has beenallowed on all Wild and Scenic segments, except in the Pacific Northwest whereboating is seasonally limited on a few miles of river solely on the basis ofexplicitly defined and documented ecological restrictions under the EndangeredSpecies Act.
The Agency has issuedDecision Notices (DN’s) for thousands of river miles,both with and without Wild and
The Agency needs to documentthe basis for this inconsistent decision and provide justification for why theban on river recreation is necessary and appropriate in this circumstance, whenthe contrary has been found on all other rivers managed by the Forest Service.
The decision to prohibitboating on the Chattooga is clearly inconsistent with national policy,recreation research, and social research. Further, the 1976 decision to closethe river to boating appears arbitrary under NEPA, and the decision did notmeet the process requirements under law when the decision was originally madein 1976 or affirmed in 1985.
As a result, the decision toprohibit boating use above Highway 28 needs to be rescinded immediately andboating should be allowed until the Agency has an opportunity to examine theissues that past federal planners with limited knowledge put together withoutconsidering the issue under an open NEPA process.
At a minimum, AW demandsthat the prohibition on float use be rescinded immediately and that boating beallowed on the headwaters while appropriate and relevant studies can becommissioned that either proves or disproves the unfounded claims from 1976 and1985 which were used to support the prescription banning float use.