Photo Credit: Katie Cahn @katiecahn
UPDATE: The comment period closed on July 27th. You can read our submitted comments here.
Andrew Pickens Ranger District recently issued a scoping notice and request for public comment on a request by Daniels Discovery Tours and Southern Outlaw Adventures for “temporary commercial special use permits” for guided fly fishing trips on Sumter National Forest lands, specifically on the Chauga River, and on the Chattooga River below the Ellicott Rock Wilderness. The Daniels Discovery Tours business is also requesting a permit to do guided camping and hiking trips.
Read the USFS Scoping Notice for Outfitter Commercial Special Use Permits here; your comments must be submitted by July 27th. Send to SM.FS.email@example.com and include the project name FY22 Andrew Pickens Fly Fishing Outfitter Guides in the subject line and in the body of your comment, plus your name, address and telephone number.
The scoping notice for these commercial special permits says that they could be “categorically excluded” from further analysis in an Environmental Assessment (EA) or an Environmental Impact Statement (EIS). This brings to the fore some important issues about commercial special use permits inside the Chattooga Wild & Scenic River Corridor—which has been set aside to protect a unique experience–and raises some basic questions:
- How much commercial special use could be permitted, before it negatively impacts the Chattooga’s wild and scenic unique experience? In other words, what is the “carrying capacity”?
- Currently, how many commercial use special use permits are there for business operations inside the Chattooga Wild & Scenic River Corridor?
- Currently, how many commercial use special use permittees are licensed on public lands overall, in the three national forests in the Chattooga watershed?
We have asked the Forest Service repeatedly for this basic information—and have yet to receive it.
In 1972, during testimony in the US Congress about adding the Chattooga River to the National Wild and Scenic River System, the House Committee on Interior Affairs concluded that the greatest threat to the Chattooga River would be over-commercialization.
The Chattooga River Development Plan was published in the Federal Register on May 10, 1974, and states, (under Recreation): “The main attraction of the Chattooga River is its recreation opportunity and-the chance to visit a whitewater river and experience solitude, adventure and challenge. Protecting and maintaining the aesthetic values of the river must remain of paramount importance. Development within the boundary of the Chattooga River must not detract from or destroy the natural beauty that makes this river different from other rivers.” Further, concerning limitations on compatible uses, it states: “Although current levels of all types of use create some problems, uncontrolled future use would probably result in safety hazards and a lowering of the quality of the recreation experience. When the need warrants, this will be prevented by the establishment of regulations limiting size, number, type, etc. to provide optimum use.”
The FY22 Andrew Pickens Fly Fishing Outfitter Guides scoping notice offers little information about the proposed new commercial special use permits. There is no mention of group sizes, length of stay, specific operating locations, etc. The cumulative effects of increased commercial use, by itself and in combination with other commercial and private uses, cannot be assumed to be negligible. In order to protect the outstandingly remarkable values of the Chattooga River, and uphold its status as a unique, protected resource, the issuance of commercial special use permits must be carefully considered. It is our opinion that no new commercial special use commercial permits should be granted until a full carrying capacity analysis for the Chattooga Wild & Scenic River Corridor is conducted within an EA or an EIS.
Current controversies, such as the recent commercial special use permit request for the ultra running “Shadows of the South” race, is a clear indication that it’s time for limitations on compatible uses. In this case, the Forest Service was in error by almost issuing a permit for a commercial event that needed to either be closely regulated or simply not permitted by statute.
We strongly oppose categorically excluding the proposed, new commercial special use permit applications from documentation and analysis in an EA or an EIS, based on the Forest Service’s erroneous assumption that issuing two more temporary commercial special use permits would have no “significant” effects on the recreation experience, as prescribed in the National Wild and Scenic Rivers Act, and directives in the Development Plan for the Chattooga National Wild & Scenic River. No new commercial special use commercial permits should be granted until a full carrying capacity analysis for the Chattooga Wild & Scenic River Corridor is conducted within an EA or an EIS.
You can express your stance on this issue via email to: SM.FS.firstname.lastname@example.org
Make sure you include the project name in the subject line of your email, as well as in the body of your comment [i.e. FY22 Andrew Pickens Fly Fishing Outfitter Guides], and also include your name, address, and telephone number. The pressure for allowing more commercialization of the Chattooga River and its protected river corridor is high; the time is now to speak up to preserve the experience of solitude and wildness for the individuals who recreate here.