“Great idea, Chuck! I put your very good questions to my friend Don Barger who
knows this law well having served on the federal advisory committee for this
law advising the FAA and NPS,. Here are his responses:”
Kirk makes a good point about doing your research and getting your supporting
facts right. Some important points to consider are:
is 2,000 flights/year the same, an increase, or a decrease from the currently
authorized numbers?
While the temporary Interim Operating Authority (IOA) would permit up to 1920
overflights/year, that is an operator-submitted number from almost 20 years ago
that has never been verified. The actual number of annual flights, based on a
three-year average, is 946 flights/year. But, again, those overflights are
being made under a temporary (“interim”) authority that terminates once an ATMP
is put in place. The ATMP is in no way bound by what flights were allowed
temporarily under IOA; the ATMP is a “clean slate” determination that is
supposed to be based on an analysis of the impacts caused by any proposed air
tours on the park, park resources, and the visitors’ experience. This proposed
plan perpetuates rather than terminates IOA. The ATMP is supposed to produce a
data-driven determination based on the protection of the natural ambient
soundscape of the park absent the intrusion of 946 air tours annually. It’s
not. It’s based on accepting the recognized problem of 946 helicopter
overflights per year over the park and offering some restrictions to make a bad
problem less bad.
what are the current and proposed restrictions on those flights, such as what
areas of the park can they fly over, minimum altitude requirements, time of day
requirements?
IOA imposes no restrictions on air tours other than the number of flights. It
is just a temporary, permissive allowance to continue a certain number of
flights over a park until an ATMP is completed that determines whether flights
are permitted at all and, if so, under what conditions. The National Parks Air
Tour Management Act (NPATMA) states that an ATMP “may prohibit commercial air
tour operations over a national park in whole or in part”. Once an ATMP is in
place, IOA is terminated and the findings of the ATMP replace it. The proposed
ATMP uses altitude, timing and routing restrictions to the existing flights
under IOA. While their plan would reduce the impacts of these temporary
overflights on many areas of the park, there is no evidence at all that such
restrictions would prevent adverse affects on park resources or your experience
as a park visitor.
3) do NPS and FAA, in the draft air tour management plan, provide sufficient
evidence to show that the proposed plan will maintain the wilderness character
of the majority of the park, as required by the park GMP, as well as the
special management considerations for historic properties, endangered species,
and other important resources? If not, how is the plan deficient?
FAA is the lead agency for the preparation of this ATMP. They present no
evidence or research whatsoever to support the proposed plan. Likewise, they
present no alternatives for evaluation and comparison. None. Also, not
presented in the plan: any consultation with USFW on endangered species; any
consultation with government and tribal historic preservation offices; any
explanation as to how “wilderness character” can be maintained by permitting
avoidable non-conforming impacts on areas managed as wilderness in the park;
any explanation, data, models, measurements, or even allegations of evidence
about why anything in their plan might work to protect natural sounds in the
park and our ability to experience them.
Please note that I am raising these issues with the hope that those of you who
send comments to NPS provide more useful comments than just a quick
off-the-cuff opinion.
Sent from Mail <https://go.microsoft.com/fwlink/?LinkId=550986> for Windows
On Oct 8, 2021, at 12:24 PM, Charles Nicholson <cpnicholson53@xxxxxxxxx>
wrote:
Kirk makes a good point about doing your research and getting your supporting
facts right. Some important points to consider are:
1) is 2,000 flights/year the same, an increase, or a decrease from the
currently authorized numbers?
2) what are the current and proposed restrictions on those flights, such as
what areas of the park can they fly over, minimum altitude requirements, time
of day requirements?
3) do NPS and FAA, in the draft air tour management plan, provide sufficient
evidence to show that the proposed plan will maintain the wilderness
character of the majority of the park, as required by the park GMP, as well
as the special management considerations for historic properties, endangered
species, and other important resources? If not, how is the plan deficient?
Please note that I am raising these issues with the hope that those of you
who send comments to NPS provide more useful comments than just a quick
off-the-cuff opinion.
Chuck Nicholson
Norris, TN
On Fri, Oct 8, 2021 at 12:54 PM KirkH <kihu63@xxxxxxxxx
<mailto:kihu63@xxxxxxxxx>> wrote:
IMHO......
After doing a bit of research on this, the information I can find about the
proposed changes are not as described in this eMail message to TN-Bird. What
I have read indicates that the NPS & FAA are working to make the helicopter
tours & routes more restricted than they currently are. Please tell me if
I'm misreading something here, since I'm not looking to start trouble or an
argument over this. 😉🤓
It would be a shame to flood the hard-working NPS & GSMNP people with a bunch
of misguided, irate messages or eMails for a problem that doesn't exist.
Regards,
-----
Kirk Huffstater
Morristown, TN, USA
<http://www.avg.com/email-signature?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>
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On Fri, Oct 8, 2021 at 12:17 PM Melinda Welton <dmarc-noreply@xxxxxxxxxxxxx
<mailto:dmarc-noreply@xxxxxxxxxxxxx>> wrote:
It appears the NPS may be trying to pull a fast one and they need a flood of
letters. Please consider writing and sharing a letter like this. The deadline
is this Wednesday the 13th!
National Park Service is about to approve a plan that would allow nearly
2,000 helicopter flights over the Great Smoky Mountains National Park
annually. They need to know that you value the park and how helicopters
overflights would diminish your experience. Even if you rarely or never visit
the park, but appreciate the value of the park and its preservation, you are
a “user” and your words are valuable.
Even if you write one profound sentence, they need to hear from you – it's be
important. Make it personal.
I go to the Smoky Mountains to (hike/bike/birdwatch/photograph/be in
nature/enjoy the sounds of nature/bird song/find solitude/escape from etc.)
Helicopter overflights would (intrude/disturb/ruin/compromise/impact etc.) my
experience of the park. They should not be (allowed/drastically reduced etc.)
Helicopters are disruptive and unfair to those on the ground and should be
disallowed.
Comments must be sent by Wednesday the 13th! to the link is below.
Thank you in advance,
Melinda Welton
Submit comments by this Wednesday the 13th:
https://parkplanning.nps.gov/document.cfm?parkID=382&projectID=100689&documentID=114585
<https://parkplanning.nps.gov/document.cfm?parkID=382&projectID=100689&documentID=114585>
If you’d like to write more in depth information contact me.
615-210-8095
Summary of the plane:
https://parkplanning.nps.gov/projectHome.cfm?projectId=100689 ;
<https://parkplanning.nps.gov/projectHome.cfm?projectId=100689>
