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AW ANALYSIS
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ALT. 1
No Action
AW Choice
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Alt. 2
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Alt. 3
AW Choice
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Alt. 4
USFS Choice
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Alt. 5
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Self-Guided Boating:
Section III
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Not Regulated
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175 weekend
125 weekday
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200 weekend/holiday
125 weekday
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175 weekend
125 weekday
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200 weekend/holiday
125 weekday
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Self-Guided Boating:
Section IV
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Not Regulated
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160 weekend
75 weekday
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200 weekend/holiday
125 weekday
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160 weekend
75 weekday
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200 weekend/holiday
125 weekday
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American Whitewater requested the use allocation under Alternative 3 & 5. This was
based on:
- Historic use levels;
- The fact that use rarely exceeds these amounts except on busy holiday weekends
such as Memorial Day and the Fourth of July; and
- The fact that private or self-guided boater use at current levels has not been
found to have negative environmental or social impacts.
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Private Boater Reservation System Section III
Apr. 1 - Aug. 31
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None
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If use is exceeded for 20 weekends in a given year, then reservations would be required
on weekends the following year. If use is exceeded for 50 weekdays in a given year,
then reservations would be required on weekends (pg 27) [sic - should probably
state weekday based on info on pg 18] the following year.
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Since 1996, self-guided use on these dates has reached 200/weekend an average of 3
days/year, and has not reached 125 people/weekday.
Since 1996, self-guided use on these dates has reached 175/weekend an average of 4
days/year, and has not reached 125 people/weekday.
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Private Boater Reservation System Section IV
Apr. 1 - Aug. 31
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None
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If use is exceeded for 20 weekends in a given year, then reservations would be required
on weekends the following year. If use is exceeded for 50 weekdays in a given year,
then reservations would be required on weekends (pg 28) [sic - should probably
state weekday based on info on pg 19] the following year.
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Since 1996, self-guided use on these dates has reached 200/weekend an average of 2
days/year, and has reached 125 people/weekday an average of 1 day/year.
Since 1996, self-guided use on these dates has reached 160/weekend an average of 2
days/year, and has reached 75 people/weekday an average of 4 days/year.
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AW credits the USFS for looking at a reservation system under a proactive management
plan. However, we question the need for the restrictive permit reservations suggested
under Alternatives 2 & 4 if use at the higher levels under Alternatives 3 & 5 are
atypical and not generally viewed as unacceptably crowded. Hence AW's general support
for Alternative 3 & 5.
AW generally supports advance planning to address anticipated future use patterns.
Yet we are prompted to question the need to change the existing plan, given that use
has plateaued at a self-regulated level for the past 6 years and permits do not
appear to be necessary in the next several years.
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AW will encourage the USFS to consider modifying the proposal to trigger permits only
after two consecutive years at the trigger levels. This will allow the agency time to
plan for the reservation permit system, time to educate visitors about use levels and
the need for a permit system, and time to determine whether use patterns were a fluke
or the result of unusual weather patterns that might attract visitors. For instance,
whitewater use dramatically increased across the board in 1994 and 1995 following the
release of the movie "River Wild" featuring Meryl Streep. However, since 1995, use has
steadily declined as the fad component of whitewater recreation has declined.
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Allow Headwaters Boater Access Above Highway 28
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AW Request to Consider Denied: Despite receiving more than 200 letters during the
scoping period in support of access to the headwaters, the USFS writes "We have
received many comments requesting the Forest Service consider either opening these of
the river to boaters or to make sure these sections remain closed to boaters. The issue
is outside the scope of the Purpose & need and Proposed Action for this project. At
this time, we are only analyzing recreational boating use on Sections I-IV of the
Chattooga River" (pg 7).
The EA does not specify when our request to consider will be evaluated.
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Improve Stekoa Creek Water Quality: Reduce fecal coliform
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AW Request to Make Improved Water Quality a Priority Denied & Recognized: USFS responds
that the "issue is outside the scope of the Purpose & Need and Proposed Action for
this project" (pg 7). The agency later notes that "To assess the current and
future impacts of boating use on the river, focused monitoring is needed on the water
quality areas of sedimentation and fecal coliform..." (pg 24). However, the EA
later clarifies that "Known water quality problem areas should be targeted first
until we get better information. Stekoa Creek has been and continues to be the most
contaminated tributary within the Chattooga Watershed. Estimates are that Stekoa Creek
may also have about 2/3 of the total fecal (and sediment) loading for the Chattooga
Watershed. Warwoman Creek, West Fork Chattooga River, and Whetstone Creek have periodic
fecal contamination (pg 25)."
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Scope of Purpose & Need Statement
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The report states that "Because of the perceived inadequacies of the current Forest
Plan as it relates to boating and the need for a more timely response; because these
other issues involve other National Forests; and because Forest Plan Revision is
underway but on a more extended timeline, the agency determined that the scope of
proposed activities should be limited to only recreational boating on Sections I - IV
for guided and self-guided use" (pg 8).
Note that these same arguments apply to AW's reasons for requesting a review of
Headwaters access too.
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Outfitter Use: Definition of "raft"
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Raft does not equal inflatable kayak
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Raft does equal inflatable kayak
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Shuttle Permits
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1
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More than 1
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No more than 2 (by permit <30% of all boaters could be shuttled)
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More than 1
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No more than 2 (by permit <30% of all boaters could be shuttled)
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Note that under Alternative 4 inflatable kayak rentals (aka IK's duckies, funyaks,
etc.) will be managed as private boater uses and are no longer considered "rafts". Note
that the shuttle permits are issued to the companies that rent duckies. Note that
Alternative 4 provides for multiple shuttle permits. Note that there is no restriction
on the number of IK's a company can rent. Note that the agency professes a need to
restrict private boater access with reserved permits based on historic use levels.
Finally, note that the act of creating a new commercial IK industry under the private
boater allocation will only make the river more congested and access more difficult for
the traditional visitors.
American Whitewater does not oppose inflatable kayak use on the river; however we
believe strongly that all inflatable kayak rentals and shuttle users should be
counted under the commercial outfitted allocation, which is the sector from which
anticipated increased visitation will actually arise from.
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Outfitter Use: Number of clients per trip
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30
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Allow trips to exceed 30 clients as long as each trip does not exceed 40 total people
(including guides). The overall daily commercial allocation does not change.
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The change will have the affect of allowing outfitters flexibility to take a 25 and 35
person trip instead of a 30 and 30 person trip. This proposal simply gives the
outfitters greater flexibility in booking trips and AW's analysis is that it will have
little effect on private boater use.
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Guided Boating: Number of boats/trip when water levels are above 1 foot at Hwy. 76
bridge
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7 rafts on 3 trips/day
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12 boats on 3 trips/day
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7 rafts on 3 trips/day
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max 12 boats/trip
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max 12 boats/trip
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AW Questions & Comments
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How is the current system not working? AW has asked the USFS to fully explain their
compulsion to change the system. "If it ain't broke, why fix it?"
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Alt.2 is not acceptable because it restricts private boater use without purpose.
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Alt. 3 is preferable over 2, 4, & 5 because it recognizes historic and traditional use
patterns.
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Alt. 4 is not acceptable because it restricts private boater use without purpose.
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Alt. 5 differs from alternative 3 principally in the number of craft that commerical
trips can use.
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Thanks for agreeing to consider an extension of the comment period.
The requested extension seems like a good idea, particularly so since you [Ranger
Crane] authorized on behalf of the Forest Service a 63 day comment period during the
original scoping period when you gave the public 30 days to comment from July 16th to
August 16, 2001 and later (on August 10th) extended the comment period to September 17th.
If you felt that the public deserved 63 days to comment on a much shorter 6-page
document, it seems logical to approve Mr. Kinser's extension request since this latest
amendment proposal is considerably larger with nearly 140 pages.
I would personally appreciate a longer period to digest this information, as would
many other members of the public. Based on prior personal experience with soliciting and
reviewing public comments under NEPA, I'm sure that the more time the public has to
digest the document, the more considered will be their (our) responses. Further, since
the agency was in no hurry to release this document, which you have led us to believe was
largely completed in January, giving the public a few more weeks to comment on the plan
should not significantly affect agency actions or implementation of the final
decision.
I look forward to your decision regarding the requested extension.
Thus on May 20th, the Forest Service agreed to extend the deadline for comments to June 12,
2002.
