"I've spent the past few nights reading the Upper Chattooga management plan comments sent to the Forest Service. Most of them say the same things. However, Claude E. Terry has a very unique point of view. Its one of the finest comments sent to the Forest Service. Please take a few minutes to read every word. Then e-mail it to all your boating buddies, post it to any message board, list serve, and blog you can. This is a letter that should be read by everyone."
From: Claude E. Terry
Reply To: Claude E. Terry
To: comments-southern-francismarion-sumter@fs.fed.us
Subject: Chattooga Planning Team - Comments
Date: 07/22/2008 11:44 AM
July 22, 2008
Jerome Thomas
Forest Supervisor
Francis Marion and Sumter National Forests
US Forest Service
4931 Broad River Rd.
Columbia, South Carolina 29212
Attn: Chattooga Planning Team
Jerome, Thanks for the opportunity to comment on the draft EA for the Upper
Chattooga River. It appears that reasonable comments and input are sorely
needed. As a history, I boated the upper river in the early 70's, before the
arbitrary, capricious, and probably unlawful closure by the Forest Service in
1976. I obeyed the rule of law, and now, regardless of the eventual access
decision, at 70+ years I will never be able to boat those magnificent gorges
again.
Similarly, thousands of boaters have seen their prime years pass without ever
being able to legally use the river.
The closure issue, this decision and its casual flaunting of equity and rights has
been divisive and has produced major questions as to the Forest Service’s
objectives and ability to handle complex and adversarial issues. As an aside,
having a Trout Unlimited executive as the Forest Supervisor for an extended
period did not aid in the issue either.
At the start of this process, several years ago, I had conversations with several
whitewater clubs people. I assured them that today’s Forest Service would be
even-handed and give the boaters a fair hearing. It appears I was wrong. To put
my response in perspective, please note that I have consulted to Federal
agencies since 1969, served as a expert witness on water related issues, and
was the Mission Contractor for Region IV, USEPA for Environmental Studies of
the impact of Federal actions. The projects often involved public presentations. I
have done hands-on and design work for geohydrological restorations on the
Chattooga and other Federal projects. In all of these activities, fair and objective
consideration of alternatives before acting was essential, and even the
appearance of bias was to be avoided.
It is counterproductive to address one "use" of the corridor in flowery terms, while
starkly pairing the other use alternative with "conflict" or "loss" wherever it occurs.
Yet, the existing rainbow trout fishery is described in your letter and the three
pages of alternatives as:
● -"high-quality trout fishing experience"-
● -"one of the unique premiere trout fisheries for backcountry anglers
seeking remoteness and solitude in the southeast"-
● Boating? Boating is mentioned with the need to:
● "Minimize conflict between boaters and anglers by establishing flow and
season(al) restrictions for boating"
● Maintain a "boatfree recreational experience"
● Boating is considered a threat to "uniqueness" and to "unique
opportunities for enhanced solitude"
There’s more, but the simple fact is the fishery is a trout-farm based, put and
take fishery based on a species alien to the area, providing recreation to a very
few people. There are many questions raised in my mind by the verbal "color"
attached to each use. For instance;
● Where on the entire Chattooga River are fishermen excluded to provide
"solitude" and "uniqueness" of experience for boaters?
● Where do you note the differing impact of shoes of fishermen, hikers,
campers, bird watching groups, compared to the passage of a boat?
● There are trail problems noted in the alternatives. Are those trails the
result of boaters’ visits or of fishermen and hikers?
● There is frequent use of "uniqueness" to describe a put and take fishery,
and almost no notice for the incredible white water, and the truly unique
boating experience.
The level of skill and perception required to enter and use this wilderness area
for white water boating are high. There is a reason that boaters have fought to be
allowed to use this segment of the Chattooga, and it is the truly unique white
water, not the artificial fishery.
The blatant attempt to make boating more dangerous or impossible by
prohibiting removal of " large woody debris" apparently came from a Forest
Service sycophant’s input. The removal ban would be laughably absurd if it were
not so dangerous and unscrupulous. It would be appropriate to list the name of
the individual suggesting the protection of woody debris against the loss of life of
a hapless fisherman, hiker or boater. I think this suggestion is the height of
absurdity.
There is a curious inconsistency about a purportedly fair review that touts fishing
as though it were unique and had no impact, vilifies boating as destroying
uniqueness and solitude, ignores hiking, birding and other uses with their
impacts, and wishes to leave trees across the stream to the risk of injury and
death for boaters, hikers, swimmers, and other users. So much for an objective
study.
The two different descriptions of the regulatory trigger flow for alternative 4 are
curiously unknowable and perhaps not even capable of attempts to calculate,
except retroactively. I can visualize boaters detained by Forest Service
personnel, standing at some gauge until midnight in the dead of winter, at which
point the Ranger say "Aha. Got you. See, the average flow was 451 cfs, but the
mean daily average flow level was only 448.5 cfs." It is interesting that a
basically incalculable number would have to be calculated before going to the
river in mid winter, where you park miles away, walk in with your gear, calculate
the river’s cfs accurately, enter the river, avoid touching the trees blocking the
channel at some point, cannot legally use the most attractive areas of the river,
and get out, only to find your calculations were for the "average mean daily flow
level", not the "mean daily average flow level" and that you are boating
unlawfully. If this sounds ridiculous, it is.
To this point, the Forest Service has been a friendly agency to users of the upper
Chattooga, except boaters. The proposed alternative 4 regulations for boating
display the same blind bias that has prevailed for 36 years. Surely, after years of
delay, we could expect a document without the inherent bias shown in the
current proposal.
Please accept these comments as a suggestion that I don’t think Alternative 4 is
objective, reasonable, fair, logical, or capable of actually achieving balanced
management of the Magnificent Upper Gorges of the Chattooga.
Very truly yours,
Claude E. Terry
Atlanta, GA
Atlanta, GA
2 comments:
The USFS does not need to determine if boats should be restricted that was decided back in 1976 and the answer then was is yes.
Action is required in order to change the current policy. That means the USFS have to prove IF boats will diminish the quality of recreation for the existing users; one user being the angler.
The bottom line is the EA does not prove boats will not harm anglers THERFORE boats can not be allowed.
Your bitching blog kinda misses the point.
I respectfully disagree.
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