NICE JOB DON!!!!!!!
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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. You 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
AW Big Wig Don Kinser's Upper Chattooga Comments New 
BoaterTalk 
