| Tennessee Paddlesports Association
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To grow, protect and support Tennessee's paddlesports outfitting businesses by improving members' financial viability, ensuring a fair and reasonable regulatory environment and enhancing members' ease of doing business.
May 27, 2022 Comments Regarding the Center Hill Dam and Reservoir Water Control Manual The following comments are submitted by the Tennessee Paddlesports Association in response to the Corps of Engineers’ request for comments as part of the initial scoping regarding changes to their Water Control Manual at Center Hill Dam. The Tennessee Paddlesports Association is a statewide association of outfitters providing paddlecraft rental services to the general public, including outfitters operating on the Caney Fork River in the tailwaters below Center Hill Dam. We very much appreciate the recreation access on the Caney Fork River downstream of Center Hill Dam provided by the U.S. Army Corps of Engineers. • Importance of Caney Fork as a Recreation Resource. The Caney Fork River below Center Hill Dam is a very significant recreation resource for paddling and fishing. The recreation project purpose designation includes recreation in the tailwaters area of the Center Hill project where fishing and recreational kayaking and canoeing occur. We believe that project operations as defined by the Reservoir Water Control Manual should provide flows that optimize opportunities for those recreational activities during times when those recreation uses are most popular. Reliable recreation flows on the Caney Fork River are an important social and economic benefit to the surrounding area and population in middle Tennessee. • Evaluation of flows to enhance downstream recreation. We recommend that the National Environmental Policy Act analysis evaluate the potential to provide flows to enhance downstream recreation to include fishing and paddling as has been done at other Corps of Engineers’ projects in the nation. Those flows should be provided on weekend days and holidays from Memorial Day weekend to September 30th with exceptions for events that require flow adjustments due to rainfall or other natural events when flood control or power emergencies prevail. • Minimum flows. While we are not experts on the flow levels for minimum flows, it does appear that operating one unit within any 48-hour period is inappropriate for minimum flows as described in the Corps’ notice. We believe the minimum flow should never be less than around 400 cubic feet per second to protect the health of the river and that an appropriate constant minimum flow of 400 cfs, when not generating or providing releases for other purposes, should be evaluated. • Recreation flows. During this period (weekend days and holidays from Memorial Day weekend to September 30th), we ask that the Corps of Engineers evaluate a scenario where flows around 400 cubic feet per second are provided up until 10:00 AM and after 3:00 PM until later in the evening to enhance the reliability of wade fishing in the tail waters. Between the hours of 10:00 AM and 3:00 PM releases should be conducive to paddling and float fishing. Those flows should be tested prior to being finalized and should be up to, but not exceed, the capacity of one generator (or about 3,400 cfs). A level that leaves the islands at Happy Hollow exposed may be appropriate, for example. A range of flows should be tested with participation by downstream recreation users as part of the evaluation process. • Ramping rates. Ramp rates should be incremental, perhaps graduated, in 15-minute cycles. Ramping down is important to avoid stranding fish in pools. • Level of NEPA analysis. We believe that an Environmental Assessment should be conducted to determine if a higher level of NEPA analysis is required to accommodate these proposed changes. • While the flow manual does not involve access issues, at some point we are hopeful that the Corps will evaluate moving the put-in for paddling further downstream at the Buffalo Valley access site to help reduce the potential for user conflicts. Submitted by David Brown, Executive Director, Tennessee Paddlesports Association, P.O. Box 66, Strawberry Plains, TN 37871 __________________________ April 2022 Have You Applied for Your TWRA Paddlecraft Outfitter Rental Permit for 2022? Except for outfitters under Forest Service permits, outfitters renting non motorized vessels (canoe, kayaks, SUPs, tubes and inflatables) to the public must have a TWRA permit in 2022. TWRA offers these directions to ensure your permit applications are processed in a timely manner. Applications are available at https://www.tn.gov/twra/boating/paddle-craft-permit.html When outfitters submit an application for a permit, they must do so to the email address on the application. This protocol will ensure that your application is reviewed by the appropriate person in a timely manner. Applications can take up to 30 days to be processed this time of year through the correct channels. Be sure applications include all the required documentation. Piecemeal applications are more likely to be deferred or overlooked. Sending emails about applications or reporting to the wrong address may also result in delays or lost documents. Questions: For permit application and questions contact: Misdirected questions may lead to delays. Permit renewals are supposed to be submitted between October 1 and December 15th to avoid the backlog of applications in the Spring that can lead to delays.
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State Parks Issues CUA Applications for Outfitters Tennessee State Parks recently issued an online application for a commercial use authorization (CUA) to enable outfitters to provide a variety of recreation services in State Parks to include guided hikes, paddlecraft rentals and other services. The application fee is $300. State Parks requires general liability insurance with limits up to $1 million and commercial auto coverage with limits of $1.5 million for 9 to 15 passenger vans. To view a list of the various services allowed by Park unit and other requirements for the CUA, go to TDEC Vendor Opportunities - Website contains all relevant info and attachments related to CUAs. CUA Permit Application - Direct link to the application. JOIN TN PADDLESPORTS ASSOCIATION _______________ TACIR Hearing December 2nd TPA's Executive Director will be among the panelist at a hearing conducted by the TN Advisory Committee on Intergovernmental Relations on paddlecraft uses in the state on December 2nd. TACIR is studying the challenges with providing river and lake access Join us. Among the topics TACIR is considering are 1. the procedural and financial measures necessary to accommodate the increased demand for non-fish-and-game recreational activities and the resources required to manage such activities by TDEC and TWRA; 2. how TWRA-managed resources are being utilized by non-motorized vessels for non-fish-and-game recreational activities, such as paddle boarding, canoeing, tubing, and kayaking; 3. the accessibility to and funding for all non-fish-and-game recreational activities; 4. the annual fees and taxes charged to paddle craft and commercial outfitters in the previous four fiscal years; 5. any duplicative fees charged by TDEC and TWRA, and what action may be taken to eliminate such duplicity in fee structures and their regulatory authority generally; 6. the extent to which customers of non-motorized vessels contribute to revenue derived from the purchase of fishing licenses and registration of watercraft; 7. the amount of funding needed to manage, sustain, and improve access to and the management of non-motor vehicle activities in this state and what fundraising options are available to support non-fish-and-game and other similar activities; 8. what fee structure is most appropriate for recreational users generally, given that the benefits of non-fish-and-game programs are broader than just outfitters, who are already paying sales tax; 9. the feasibility of outfitters who pay additional fees to TDEC and TWRA receiving a credit on the sales tax paid on such fees and whether the local option sales tax should be included in the credit; and 10. what measures TDEC and TWRA can implement to improve their strategic plans, their organizational structures, and the oversight and sustainability of non-fish-and-game-related recreational activities. ______________ Legislation Authorizes Review of Funding Resources and Strategies to Improve Non-Fish and Game Recreation Senator Kerry Roberts introduced SB 1080 to amend the Tennessee Code Annotated, Title 4; Title 69 and Title 70, relative to recreational activities including the regulation of commercial paddlecraft rental businesses. The proposed legislation authorizes the Department of Economic and Community Development to review possible funding resources and develop strategies for improvements for non-fish and game recreational activities, in conjunction with the Tennessee Wildlife Resources Agency and the Department of Environment and Conservation, and report its findings to the governor and the general assembly by January 1, 2022. The bill amends TCA Title 4; Title 69 and Title 70. Title ยง 69-9-227 deals with the law authorizing regulation of commercial operations that lease or rent nonmotorized vessels. Title 70 covers the authorities and funding sources of the Tennessee Fish and Wildlife Commission and the Tennessee Wildlife Resources Agency. Title 4 also covers broad state agency authorities. _________________ Good News About Paddlesports Contributions to Emotional, Physical and Economic Well-Being During the Pandemic Check out these op-eds by TPA Members. Ed McAlister in the Knoxville News Sentinel. Jason Carver in the Smithville Review. _____________________________ Know Before You Go Paddling for Safety Sake Since the Coronavirus pandemic led to shutdowns and restrictions on some leisure travel, the public has been flocking to the outdoors. Paddlecraft use of waterways has increased dramatically in 2020 with many self-guided paddlers using their own craft to visit the state’s rivers. Some paddlers do not have sufficient experience or are attempting to paddle rivers in high water conditions increasing the risks of a serious incident or water rescue. Safety data shows that paddlers are much less likely to be involved in a serious incident when they go with a professional outfitter, in part because outfitters do not operate when water conditions are too treacherous for inexperienced paddlers. When a customer rents a canoe, kayak or inflatable they also receive a briefing on potential hazards and are issued a Coast Guard approved life-jacket. The Tennessee Paddlesports Association (TPA) is offering a free set of briefing posters to the public in an effort to reduce the risks to inexperienced paddlers who venture out in their own canoe, kayak, paddleboard or inflatable. BeSafePoster General 2020.pdfLifeJacket Poster General 2020.pdf Kayaking Basics.pdf Canoeing Basics.pdfTPA also urges paddlers to be considerate of other users and to avoid leaving their boats on ramps where they block access by other boaters. TPA has a set of Best Practices designed to diminish user conflicts. The Tennessee Paddlesports Association is a state-wide association of outfitters providing paddlecraft rental equipment, instruction, and other services on Tennessee waterways under permits issued by the Tennessee Wildlife Resources Agency.
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