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Old 12-11-2014   #1
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GCPBA Signs On To Letter Regarding Overflights In Grand Canyon

GCPBA Signs On To Letter Regarding Overflights In Grand Canyon

December 10, 2014

Docket Operations, M-30
U.S. Department of Transportation (DOT)
1200 New Jersey Avenue SE
Room W12-140, West Building Ground Floor
Washington, DC 20590-0001

RE: Docket number FAA-2014-0782

Grand Canyon River Guides (GCRG), Grand Canyon Trust (GCT), National Parks Conservation Association (NPCA), and Grand Canyon Private Boaters Association (GCPBA) respectfully submit the following comments on the Grand Canyon National Park Quiet Aircraft Technology Incentive: Seasonal Relief from Allocations in the Dragon and Zuni Point Corridors.

Grand Canyon River Guides, Inc., founded in 1988, is unique in that it provides a unified voice for river guides and river runners in defense of the Colorado River corridor through Grand Canyon. Our non-profit educational and environmental 501(c)(3) organization is comprised of over 1,700 individuals who are passionately dedicated to protecting Grand Canyon and the Colorado River experience.

Grand Canyon Trust is a nonprofit corporation headquartered in Flagstaff, Arizona with over 3,500 members. The mission of the Grand Canyon Trust is to protect and restore the Colorado Plateau – its spectacular landscapes, flowing rivers, clean air, diversity of plants and animals, and areas of beauty and solitude.

National Parks Conservation Association was founded in 1919. It represents a million members and supporters through its headquarters in Washington, DC and 23 regional and field offices, all working to "protect and enhance America's National Park System for present and future generations."

Grand Canyon Private Boater’s Association (GCPBA) is a non-profit organization dedicated to advocacy on issues surrounding private boater access to the Colorado River through Grand Canyon National Park. Founded in 1996, GCPBA represents a paid membership as well as a long-established internet constituency. GCPBA was an active participant in the formulation of the 2006 Colorado River Management Plan, and participated extensively in the NPS Grand Canyon Working Group dealing with overflight issues.

When Congress passed the 1987 National Parks Overflights Act, it challenged the National Park Service (NPS) to “substantially restore natural quiet” to Grand Canyon National Park. Twenty-seven years after it was enacted, barely 50 percent of the park is free from aircraft noise 75 percent of the time. Nearly half of the park’s silence, one of the qualities that distinguish Grand Canyon from ordinary places, has been sacrificed to air tour noise. That is why Congress enacted restrictions to dial down the noise in 1987 and why in Section 4.9 of NPS Management Policies, the agency said that it “…will restore to the natural condition wherever possible those park soundscapes that have become degraded by unnatural sounds (noise), and will protect natural soundscapes from unacceptable impacts.”

Despite these commitments, noise from air tours continues to impair a substantial area of Grand Canyon National Park.

With respect to the current proposal, please consider the following points:

1. Quiet technology isn't really quiet -- just less noisy.

2. Simply adding more seats to an aircraft should not qualify it for the quiet technology incentives. Operators should be maximizing their passengers per flight anyway.

3. Switching to quiet technology should be the cost of doing business in Grand Canyon, and a strict requirement integral to operating responsibly in one of the natural wonders of the world.

4. Adding more flights when we already fail to meet the standard of the "substantial restoration of natural quiet" in Grand Canyon National Park is counter-productive and unacceptable. It doesn't matter if aircraft are "quieter" -- if you add more flights, it's noisier, plain and simple.

5. The suggested incentives raise a lot of questions: How can the public be assured that noise won't increase? In this time of diminishing budgets, does Grand Canyon National Park have funds and personnel sufficient to monitor this? Will there be transparency and accountability? Once you give "seasonal relief from allocations," will it ever be possible to take it away? How will these changes be enforced and monitored?

6. In 2012, the very definition of the Substantial Restoration of Natural Quiet was re-written by a congressional special interest rider inserted into a must-pass spending bill. Substantial Restoration had previously been defined as: 50 percent “or more” of the park would be naturally quiet “at least” 75 percent of the time. The wording “or more” and “at least” were removed from this definition in a political move just as the National Park Service was preparing to issue final recommendations on reducing airtour noise over Grand Canyon. Under the new degraded definition, half the park can be loud all of the day, and the other half noisy up to 25 percent of the day. We do not support allowing unlimited “quiet” technology flights in the winter season, and up to 3,700 new airtours in the Dragon and Zuni corridors in the summer. These increases would adversely affect the visitor experience in the backcountry and along the river corridor.

Our organizations oppose any additional incentives beyond those that are already in place (i.e., decreasing the fees paid to the National Park by the air tour industry to operate over the park and allowing the use of previously unused allocations). The natural soundscapes in Grand Canyon are a threatened park value which we will continue to defend.

Thank you very much for your consideration of our views.


Lynn Hamilton, Executive Director, Grand Canyon River Guides, Inc.

Roger Clark, Grand Canyon Program Director, Grand Canyon Trust

Kevin Dahl, Arizona Senior Program Manager, National Parks Conservation Association

Walter Rist, President, Grand Canyon Private Boaters Association
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