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Like many paddlers, American Whitewater yesterday submitted comments on the Forest Service's environmental assessment (EA) of recreation on the Chattooga River. Our comments were a team effort, and can be downloaded and read in the box to the right. Our comments point out many of the flaws in the EA, which was clearly a strategic document attempting to justify a ban on paddling the upper Wild and Scenic Chattooga. The EA was the weakest such document that many of our reviewers have ever read. Our comments are aimed at bringing nationally consistent and environmentally protective management to the Upper Chattooga River for the first time.
The Forest Service's proposal in the EA was to totally ban boating on most of the upper river and all tributaries while allowing hikers, anglers, and campers to visit in unlimited numbers. In addition, EA contains a unworkable proposal to allow a few boating trips, for a few paddlers, in some years, on a small section of the river, at high water, in the winter, based on a permit, and subject to advance agency approval. While the EA offers no rationale behind their proposal, they suggest that its goal is to provide high quality angling. The EA contains no evidence of social or environmental impacts associated with allowing paddling to occur with the same limits that exist for other users on the upper Chattooga and for private boaters on every other river in the region.
Many issues remain distinctly unresolved. The Forest Service has failed to respond to the many orders handed down from their Washington Office in response to our appeal of the 2004 plan. Most notably they have not conducted a user capacity analysis and have not proposed equitable management of the river. If implemented, their proposal would violate laws, policies, regulations, and river managment protocols.
Perhaps the silver lining of the EA though is that the Forest Service is proposing to address some of the 19.3 miles of user created trails, 91 erosion problems, 141.5 gallons of trash, 26 campsites within 20 feet of the river, and over 500 damaged trees found in the Upper Chattooga River corridor in a 2007 inventory. Prior to AW challenging the 2004 management plan for the river, the Forest Service was unaware of these issues and certainly not planning on fixing them. Our appeal of the 2004 plan revealed these management problems and we are pleased that the Forest Service proposes to address them.
We would like to thank all the paddlers that filed comments in support of responsible management on the Chattooga. As a community we have daylighted a national treasure being mismanaged by a small group of people for a small group of people. While other groups have employed greenwashing to create misdirected opposition to boating, paddlers have stayed honest, thoughtful, and active. Together we will assure that paddling is recognized as an acceptable way to experience our Nation's rivers. Our efforts will reduce user conflicts and increase environmental protection on the Chattooga and rivers across the country.
The Forest Service will reach a decision by year end.
AW remains committed to bringing responsible river management to the Chattooga on behalf of all backcountry recreationists.
American Whitewater's comments on the Forest Service's 2008 environmental assessments addressing recreational use on the Chattooga.