Cosby
09-12-2007, 11:33 AM
If you don't mind, please copy the following letter into an email and send it to comments-southern-francismarionsumter@fs.fed.us; webmaster@fs.fed.us; gewhite@fs.fed.us; whansen/r8_fms@fs.fed.us; lyaukey@louisberger.com
The scum bags are trying to keep us out of the headwaters of the chattooga river so the rednecks can have quiet fishing spots.
Mr. John Cleeves
U.S. Forest Service
4931 Broad River Road
Columbia, SC 29212
comments-southern-francismarion-sumter@fs.fed.us
RE: Chattooga Scoping Document
Dear Mr. Cleeves,
The alternatives currently proposed by the USFS require substantial amendment because they are not supported by or tied to actual capacity data, are not consistent with the USFS’s appeal decision governing this process, are not consistent with applicable law, and will not protect the Chattooga River. The USFS’s own capacity study demonstrated that boating is an appropriate use of the Upper Chattooga River, yet 5 of your 6 proposed alternatives ban boating on some or all of the upper river. The Upper Chattooga’s capacity to support whitewater boating is not zero, and all action alternatives must allow at least some boating on the entire river. Any alternatives that limit recreation must do so based on the capacity of the river corridor as determined by real data – and must do so equitably.
In addition, the proposed alternatives should be amended as follows:
• Proposed use limits must be tied to a specific standard regarding user capacity. Only one USFS alternative even mentions a standard (Alternative #2).
• Limits must be applied equitably and fairly– not targeted to any specific user groups without significant evidence. All USFS alternatives single out boating for harsh limits and bans – for which there is no evidence.
• Limits should only be imposed when standards are met or exceeded – and not before. Five of the six USFS alternatives limit and/or ban boating immediately without basis.
• Alternatives must include a range of standards for all users. USFS alternatives address a range of arbitrary limits on boaters – but only one alternative would limits other users. For example, a standard of 10, 6, and 2 group encounters per day should be analyzed, as well as provisions that exclude the outlier days when high use can be expected or occurs randomly.
• Alternatives must be based on a capacity for all users and/or individual uses. The proposed USFS alternatives are not based on the social or physical capacity of the river corridor.
• Alternatives must prescribe indirect limits prior to direct limits as is required by USFS policy. Five of the six alternatives implement direct limits (i.e., bans) prior to trying indirect limits first in direct violation of USFS policy.
• Alternatives, including any capacity triggers, should distinguish between high use frontcountry areas and low use backcountry areas. USFS alternatives make no distinction between how many encounters with other users are acceptable in a campground or at a trailhead as opposed to on a trail or river deep in the woods.
• Alternatives should look at varying levels of user created trail closures, user created trail hardening, creation of new trails, campsite closures or relocations, fish stocking, parking, total recreational use, angling use, hiking use, camping use, boating use, and swimming use.
Thank you for considering these ideas.
Sincerely,
Chris Osborne
chris@illstreet.com
The scum bags are trying to keep us out of the headwaters of the chattooga river so the rednecks can have quiet fishing spots.
Mr. John Cleeves
U.S. Forest Service
4931 Broad River Road
Columbia, SC 29212
comments-southern-francismarion-sumter@fs.fed.us
RE: Chattooga Scoping Document
Dear Mr. Cleeves,
The alternatives currently proposed by the USFS require substantial amendment because they are not supported by or tied to actual capacity data, are not consistent with the USFS’s appeal decision governing this process, are not consistent with applicable law, and will not protect the Chattooga River. The USFS’s own capacity study demonstrated that boating is an appropriate use of the Upper Chattooga River, yet 5 of your 6 proposed alternatives ban boating on some or all of the upper river. The Upper Chattooga’s capacity to support whitewater boating is not zero, and all action alternatives must allow at least some boating on the entire river. Any alternatives that limit recreation must do so based on the capacity of the river corridor as determined by real data – and must do so equitably.
In addition, the proposed alternatives should be amended as follows:
• Proposed use limits must be tied to a specific standard regarding user capacity. Only one USFS alternative even mentions a standard (Alternative #2).
• Limits must be applied equitably and fairly– not targeted to any specific user groups without significant evidence. All USFS alternatives single out boating for harsh limits and bans – for which there is no evidence.
• Limits should only be imposed when standards are met or exceeded – and not before. Five of the six USFS alternatives limit and/or ban boating immediately without basis.
• Alternatives must include a range of standards for all users. USFS alternatives address a range of arbitrary limits on boaters – but only one alternative would limits other users. For example, a standard of 10, 6, and 2 group encounters per day should be analyzed, as well as provisions that exclude the outlier days when high use can be expected or occurs randomly.
• Alternatives must be based on a capacity for all users and/or individual uses. The proposed USFS alternatives are not based on the social or physical capacity of the river corridor.
• Alternatives must prescribe indirect limits prior to direct limits as is required by USFS policy. Five of the six alternatives implement direct limits (i.e., bans) prior to trying indirect limits first in direct violation of USFS policy.
• Alternatives, including any capacity triggers, should distinguish between high use frontcountry areas and low use backcountry areas. USFS alternatives make no distinction between how many encounters with other users are acceptable in a campground or at a trailhead as opposed to on a trail or river deep in the woods.
• Alternatives should look at varying levels of user created trail closures, user created trail hardening, creation of new trails, campsite closures or relocations, fish stocking, parking, total recreational use, angling use, hiking use, camping use, boating use, and swimming use.
Thank you for considering these ideas.
Sincerely,
Chris Osborne
chris@illstreet.com