Kayak and Canoe Club of New York

September 12, 2007

Mr. John Cleeves
U.S. Forest Service
4931 Broad River Road
Columbia, SC 29212
comments-southern-francismarionsumter@fs.fed.us

RE: Chattooga Scoping Document

Dear Mr. Cleeves,

The Kayak and Canoe Club of New York (KCCNY) is a New York State-based recreational organization with approximately 300 members in New York State, New Jersey, Pennsylvania and Connecticut. KCCNY is a 501 (c)3 non-profit corporation, with a mailing address c/o Mr. Kenneth Voytac, 299 Route 46 East, Denville, New Jersey 07834-2834. Our activities are funded entirely from individual memberships and donations from individuals. Our officers and staff consist entirely of unpaid volunteers.

Many of our members practice recreation in watersheds up and down the East Coast, and a number of our members have boated on the Chatooga River. Accordingly, we have an interest in the public benefits attendant on continued, even expanded, access to the Chatooga River, a public resource administered by your office.

It is KCCNY's considered belief that whitewater boating is a legitimate, conforming use of public waterways, and one which seldom conflicts with other uses. Whitewater boating is an Olympic Sport, in which America's finest young athletes represent our nation every four years, as well as both a challenging and contemplative form of recreation. Whitewater boating is environmentally sensitive; canoes and kayaks are muscle-powered. Boaters do not get thrills from killing, capturing, or otherwise stressing wildlife. KCCNY advocates balanced recreational use of public waters consistent with environmental sustainability, and has a documented record of supporting multiple recreational uses.

In these proceedings, KCCNY supports the position of the American Whitewater Afiiliation (AW) and offers the following comments:

The alternatives currently proposed by the USFS require substantial amendment because they are not supported by or tied to actual capacity data, they are not consistent with the USFS’s appeal decision governing this process, they are not consistent with applicable law, and they will not protect the Chattooga River.

A capacity study conducted by the USFS itself demonstrated that boating is an appropriate use of the Upper Chattooga River, yet 5 of the 6 proposed alternatives ban boating on some or all of the upper river. The Upper Chattooga’s has the capacity to support whitewater boating. Accordingly, 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 #3). All alternatives should do so.

· 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, while selected other user groups are not so limited.

· 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. Either bans and limits on boating should be removed from those alternatives, or a reasonable and considered basis for their inclusion must be provided

· 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 limit 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. Arbitrary limits selectively imposed are not consistent with the public interest.

· 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. They appear to be based on the desire of a small group of river users to have sole use of the river.

· Alternatives must impose indirect limits to activities prior to and in preference to imposing direct limits, as required by USFS policy. Five of the six alternatives implement direct limits (i.e., bans) prior to imposing indirect limits, 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.

The USFS is entrusted with considerable authority to manage lands within its jurisdiction, but with that authority comes the responsibility serve the public interest. Arbitrarily banning legitimate, environmentally sensitive, recreational activities will in no way serve the interests of the public. Thank you for considering these comments.

Sincerely,

Mr. Lauren J. Cook
Conservation Chair
Kayak and Canoe Club of New York

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