October 23, 2003
Mr. Ken Wotring FC-RONR Wilderness Coordinator 50 Hwy 93 South Salmon, ID 83467
Dear Mr. Wotring:
This serves as the comments of the Aircraft Owners and Pilots Association (AOPA) to the Final Environmental Impact Statement for the Frank Church River of No Return Wilderness Management Plan. AOPA is the world's largest aviation association, representing the general aviation concerns of more than 400,000 members nationwide.
AOPA is strongly opposed to any attempt to close or limit the public's unconditional use of any airport or landing facility. Therefore, AOPA is opposed to any alternative that would close or limit the use of Dewy Moore, Mile-Hi, Simonds and Vines airstrips.
While Alternative D would allow the emergency use of the Dewy Moore, Mile-Hi, Simonds and Vines airstrips, we believe the public's unconditional use of these airstrips is appropriate. Therefore, AOPA is opposed to Alternative D. It is our belief that the intent of public law 96-312 is to keep these airstrips open unconditionally to the public. In fact, the congressional intent of public law 96-312 was clarified in Senate Committee on Energy and Natural Resources report no. 96-414 that accompanied the enacted legislation (S.2009).
The Committee heard extensive testimony about the importance of maintaining the existing airstrips in order to provide necessary access to the proposed wilderness. Based on that testimony, the Committee provided in this section of the bill that the Secretary shall not close or render unserviceable, i.e. effectively close any airstrip in regular use on national forest lands on the date of enactment for reasons other than extreme danger to aircraft landing and taking off from such airstrips. Even closing for reason of "extreme danger to aircraft" could not occur without the express written consent of the agency of the State of Idaho charged with evaluating the safety of backcountry airstrips. This will assure the continued access by air of the remote and otherwise unaccessable stretches of these wilderness land.
The Dewy Moore, Mile-Hi, Simonds, and Vines airstrips were in regular use at the time of the enactment of this legislation. It is our understanding that the Forest Service has approached the Idaho Division of Aviation with the intent to close these airstrips in compliance with this law, but that the Division of Aviation did not grant permission to close these airstrips. Limiting the use of these airstrips to "emergency use only" would not adequately assure the "continued access by air of the remote and otherwise unaccessable stretches of these wilderness land" as is the intent of public law 96-312.
Generally speaking, these backcountry airstrips are utilized by pilots with exceptional skill and aircraft capable of operating on unimproved airstrips. These aircraft operators have the utmost respect for the environment and operate in such area to enjoy the beauty of their surroundings. These airstrips have not required any maintenance by the Forest Service since 1984 and remain in a usable condition despite this lack of maintenance. Therefore, based upon the lack of Forest Service resources required in the last 20 years to keep these airstrips open and by the lack of any benefit cost analysis, it does not seem reasonable to discontinue their use and limit aircraft operator's access to these areas.
AOPA strongly encourages the Forest Service to continue the public's unrestricted use of the Dewy Moore, Mile-Hi, Simonds and Vines airstrips.
Bill Dunn Vice President Airports
October 23, 2003
Recreational Aviation Foundation,
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