Dear John Borton and Siskiyou National Forest::
I am aware that the Siskiyou National Forest is developing an analysis of special use permits for outfitters on the Lower Rogue and Illinois Rivers and is determining whether or not the special use permits should be reissued or amended. I support the development of an alternative that would drastically reduce or eliminate entirely the activity of motorized jetboats on these magnificent Wild Rivers. Particularly in the Wild section of the Rogue, I support the “no action” alternative, or not renewing the permits.
I am very concerned about the impacts that intensive jetboat use have on the Wild and Scenic Rogue River Corridor. Large motorized jetboats disturb the riverine environment, negatively impacting fish and other aquatic species—such as the Northwester Pond Turtle. Furthermore, their noise and large wakes disturb the wildlife values for which the Rogue was originally designated as a Wild and Scenic River. Ultimately, the DEIS fails to adequately analyze the effects of re-issuing the permits under the Preferred Alternative. How can this document ensure the protection of all the rivers Outstanding Remarkable Values (ORVs) when the Fisheries ORV will clearly be diminished by levels of motorboat use that are “likely to adversely effect” federally threatened coho salmon?
Jetboats, in disrupting the fisheries and wildlife resources of the Rogue and Illinois Rivers, also negatively impact the recreational experience of users who hope to enjoy the spectacular qualities of the Rogue’s wildlife, fisheries, and scenery. The public interest is in preserving the qualities of the river that caused it to be included as a charter piece of the Wild and Scenic Rivers Program, and in not giving undo preference to the highly disruptive activity of one type of user—namely, motorized jetboats/tourboats.
The Wild and Scenic Rivers Act requires that the outstandingly remarkable values for which a river was designated must be “protected and enhanced.” The preferred alternative in the DEIS must reflect this legal mandate instead of catering to private, commercial interests.
Thank you, Your name
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Fisheries were determined to be an outstandingly remarkable value (ORV) for the Rogue and Illinois Rivers at the time of their designation. Because motorboats are present when juvenile and adult coho are using the lower Rogue, the possibility exists that channel disruption, harassment, and disturbance may diminish the health of the threatened coho. The fish are forced to move in the stream channel, some areas of the stream channel are modified, and fish are often prompted to vacate their thermal refugia. Also, similar factors may negatively impact other sensitive species in the project area.
Outside of the No Action Alternative, the SNF has failed to present the public with an alternative that adequately protects the fisheries ORV for the Wild sections of the Rogue and Illinois. The Preferred Alternative will undermine one ORV, ostensibly for the benefit of one subset of recreational users (jetboats). The DEIS fails to resolve its internal contradictions by, on the one hand, claiming to protect the ORVs of the project area, and on the other hand permitting use levels that will undermine coho salmon.
Recreation
User conflicts that exist between motorized and non-motorized users should be investigated in light of the direction given by the Wild and Scenic Rivers Act, which calls for Wild rivers to be managed as if they were in a “primitive” state. It is difficult to imagine that motorized tourboating matches the original intent of Congress when it designated the Rogue as a charter piece of its Wild and Scenic Rivers system
Moreover, significant user conflicts do occur. Although the SNF asserts that the user conflicts are minimal, there are a significant number of users whose experience is diminished by excessive tourboat use to warrant a reconsideration of motorized tourboat levels, particularly in the Wild section of the Rogue River. The SNF has chosen, in its Preferred Alternative, to favor one type of recreational user at the expense of other users, and at the expense of the natural, scenic, and biological values that make the Rogue and Illinois so remarkable. In diminishing the wildlife and fisheries values, excessive powerboat use also indirectly diminishes the experience of other users who visit the project area to fish, view wildlife, and enjoy relative peace in a natural setting.
Wildlife
The DEIS states that there are many species for which the Preferred Alternative may adversely individuals, such as the Del Norte salamander, the common kingsnake, and the Northwestern pond turtle. Other species, such as bald eagles, marbled murrelet, and the northern spotted owl, may also be affected by the Preferred Alternative’s designated level of motorboat use. For some wildlife, the DEIS states that “the potential for impacts is proportional to the amount of boat activity,” and yet the DEIS recommends maintaining a high level of motorized tourboating without thoroughly analyzing any intermediate level of use. The public would benefit from a broader, more thorough analysis of a range of alternatives.
Furthermore, the effects on bald eagles and northern spotted owls may be more serious than suggested by the DEIS. We would look for more population-level data to corroborate the SNF’s assertion that boat activity does not effect some sensitive of these and other sensitive vertebrates. The noise and disturbance of the powerful motorboats may harass sensitive species, disrupting their foraging and breeding patterns. The determination that there will be “no effect” on critical habitat is inaccurate in the case of motorized tourboat operation, where the noise and disturbance of permittee operations routinely reduces the undisturbed quality of the habitat.
Aquatic Conservation Strategy
The Preferred Alternative in the DEIS violates the ACS by undermining the health of sensitive fish species and habitat. The ACS requires protections for the habitat of sensitive and federally listed species. Yet, the SNF has determined that the Preferred Alternative is “likely to adversely effect” coho salmon. The habitat quality of sensitive and threatened fish species will be reduced under the Preferred Alternative, and the effect determination in the DEIS reflects this possibility. Yet, the DEIS has failed to adequately analyze the Preferred Alternative’s compliance with the ACS under the Northwest Forest Plan.
Management Indicator Species (MIS)
The SNF is required to present the public with population data for MIS in a given project area. There is no suitable habitat proxy offered in the DEIS to replace this specific type of data, so the DEIS is incomplete and fails to offer the public the necessary scientific evidence to corroborate its assertions about the status of MIS. We expect SNF to present the public with data consistent with NEPA’s requirement to take a “hard look” at the environmental effects of the action.
MIS are intended to give the SNF a solid grounding in actual population trend data to inform its determinations about the possible environmental effects of its actions.
Cumulative Effects
The cumulative effects analysis presented in the DEIS is cursory, particularly regarding fisheries effects. Because the immediate activity is likely to adversely effect the coho, and may effect other fisheries species, it follows that it will contribute to other activities that have diminished the health of sensitive and threatened fish. The SNF needs to thoroughly explore how the motorboat activity contribute to a larger suite of factors that have caused the coho to be listed as threatened and that might ultimately cause the listing of other sensitive species.
In general, cumulative effects should be analyzed in detail for each possible environmental effect. Impacts that would independently be considered to have insignificant effects may, taken as a whole, have negative effects on the system. The disturbance of jetboats may contribute more substantially to a cumulative diminishment of ORVs in the Rogue and Illinois Rivers than indicated in the DEIS.
