June 15, 2011

Water Docket

Environmental Protection Agency

Mail Code 2822T

1200 Pennsylvania Avenue N.W.
Washington, D.C. 20460
Attn: Docket ID No. EPA-HQ-OW-2011-0409


Dear Sirs/Madams:

The Georgia Canoeing Association appreciates this opportunity to present its comments on the referenced. The Georgia Canoeing Association (“GCA”) is a not for profit corporation that currently serves 600 families.

The purpose of the GCA is to unite persons interested in canoeing and kayaking in the watersheds and coastal waters of Georgia and contiguous states, and thereby to provide information, educational and training services and to increase the safety, enjoyment and skills of those canoeing and kayaking in this region. GCA has served paddlers in Georgia and throughout the Southeast since 1966.


While paddling the rivers of Georgia and nearby states for the past 40 years, we have frequently observed the adverse effect on our paddling waters of improperly regulated activities that impact upon the seasonal streams, ephemeral streams and wetlands that nourish the rivers that we paddle. The filling, damming, paving and culverting of the streams and wetlands that are the sources of our rivers has had a markedly deleterious effect on both the quality and the quantity of the rivers we paddle.


After many a rainstorm, we have seen torrents of mud flow into our rivers from small, intermittent and ephemeral tributaries where improperly regulated land disturbing activity was occurring. We have seen fecal coliform counts and other indicia of biological contamination skyrocket. At the same time we have seen the fish, turtles and other critters with which we love to share the rivers become fewer and fewer and in some cases, disappear altogether.


The impact on river flows has been equally dramatic. After rainstorms, the rivers now rise much more quickly and much higher, and then fall much more quickly down to levels that are often too low to allow us to paddle our favorite rivers. This is clearly a function of replacing natural aquatic systems with impervious surfaces. These problems must be addressed by appropriate regulations as far upstream in the watershed as is legally possible. For the sake of paddle sport and all other users of our rivers, including those of us who drink from our rivers and dispose of our waste therein, we urge your guidance to extend your regulatory reach as far as legally permitted under proper interpretation of judicial precedent. We also urge your regulation to be based on sound science, not political considerations.

Thank you for your efforts to save our rivers.

Yours truly,

Daniel I. MacIntyre

Legal Committee Chair
Georiga Canoing Association