WESTERN WHITEWATER ASSOCIATION

P.O. BOX 8922

BOISE, IDAHO 83702

Comments on the FC-RONRW SDEIS concerning the Main Salmon River.

The Main Salmon is the premier Whitewater River in the United States for powerboats.  Congress set this Wild and Scenic River aside as a recreational asset for its users.  Powerboats are a legislated use on the Main Salmon and should be allowed to share this unique resource equally with other river users.

Having reviewed the DEIS/SDEIS, the alternative closest to an equitable allocation for powerboats would be Alternative 11.  Current management practices and all the other alternatives addressed in the DEIS/SDEIS are unfair and show a distinct bias against private powerboat users.  The current management plan and most of the alternatives ignore the Congressional mandate (enhanced public enjoyment and use for all users), the spirit of the Frank Church Wilderness Area, and the intent of its founders.

1978 Use Levels-
The Forest Service must revisit their data regarding 1978 use levels for powerboats.   By the Forest Service's own admission, the 1978 use data is inadequate at best.  You have also failed to take into account multiple day trips and to realistically account for boat launches from the Vinegar Creek and Spring Bar sites.  You have been presented with the Western Whitewater Association's 1978 User Survey completed by river users of that time.  That information must be validated and used to set a realistic 1978 use level for private powerboats.

Recreational Opportunity Spectrum-
The Main Salmon River has always been used as an access route into the surrounding wilderness, the same as any road might be utilized.  In addition, numerous private land holdings with homes, cabins, lodges, air strips, and other man-made structures are scattered along its entire length.  Due to these conditions, this corridor cannot be classified as Semi-primitive.  The ROS for the Main must be classified as R/N - Roaded Natural.

The People At One Time (PAOT) limitation proposed for the Main Salmon is significantly less than that proposed for the Middle Fork.  The Semi-primitive, Non-motorized classification as well as the substantially smaller size of the of the Middle Fork, should point towards the Main Salmon having a higher PAOT allocation.  While the Main Salmon River should be able to facilitate a much higher PAOT, the surrounding wilderness would still maintain more of a semi-primitive environment.

Controlled Season-
The use of Boat Use Days (BUD's) as a method of use restriction has eliminated any realistic access to the Frank Church Wilderness for private powerboat users.  Powerboats should be regulated by the same criteria - LAUNCHES PER DAY - as other river users.  Private powerboat families should be able to enjoy the same access that the private floating community enjoys and should be able to experience the Salmon River Canyon during the warm summer months for the same reasons as the floating community - camping, swimming, fishing, and hiking.  Private powerboats should be regulated using the same criteria as is used for the other river users and with the following use levels:

Boat Launches Per Day - 8
Maximum Length of Stay - 10 days
Maximum party size per launch - 10 people

These levels would provide a maximum potential PAOT of 800 for the private powerboaters - still much less than the potential PAOT of private or commercial float parties.  Safety concerns dictate that powerboats should travel in groups of at least two or three boats.  As with most private float boaters, most private power boating is done with small parties and multiple craft per party.

The current division of the Main Salmon at Ludwig Rapid for the purpose of significantly reducing access by private powerboats to the upper section of the river is illegal, unfair, and unnecessary.  There is no data from the 1978 time frame that suggests any different use patterns on the different sections of the Main Salmon River.  Also, during the early season when the river is running high and cold, float use is typically lower and the jet-back traffic is much less.  During that time period, private powerboat access to the upper river is at its highest.  Later in the summer (August), Ludwig Rapid acts as a natural barrier for most private powerboaters launching from the lower end, with few boaters using the upper stretches.  Powerboat access to the Main Salmon from Vinegar Creek, should have the same freedom of use as the float community enjoys.

Non-control Season-
We do not support an expansion of the controlled season.  There is no data to support such a change.  The natural restrictions of changing water levels and seasonal weather, control the spring and fall seasons adequately.  During the late fall and early spring, floatboat use is greatly reduced, with the primary river uses being tied to hunting and fishing out of powerboats.  During the shoulder seasons the high spring flows and low fall flows naturally minimizes the use for powerboats.

Other Comments-
The floatboat regulations during the controlled season must restrict the maximum number of craft to a lower level.  The current maximum of 30 craft creates a situation where the river can literally be full of float craft.  This can create a dangerous situation, because of the potential lack of river knowledge by some of the boat captains and the number of craft in a relatively short river section or spread out over a long stretch of river.  The maximum number of float craft should be 15 per launch.

The Main Salmon is the only river in the U.S. available to powerboating families with the qualities this river provides.  Exciting whitewater, beautiful mountain scenery, abundant wildlife, fascinating historical structures, and access into the premier wilderness in the U.S.  This river should be managed to provide equal access for all current users and managed for the benefit of those users.