See below from Director of the OPA Back Country Division, Alan Cossitt…
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Forest Service Planning NOI
c/o Bear West Company
172 East 500 South
Bountiful, UT 84010
fspr@contentanalysisgroup.com
Subject: Comments — USFS Planning Rule Revision NOI dated December 18, 2009
This letter is being submitted to provide the Oregon Pilots Association’s (OPA) comments on proposed USFS planning rules.
The Oregon Pilots Association represents pilots in Oregon and throughout the country. Our charter is to protect and enhance aviation in Oregon. Oregon contains many public land and airstrips managed by the USFS and Oregon aviation will be affected by the proposed changes to the planning rules.
We would like to place on the record that we concur with the comments as provided by the Recreation Aviation Foundation (RAF) in their letter to you.
(Ed note RAF letter listed below)
Sincerely,
Alan Cossitt
Direction of Backcountry Aviation Division,
Oregon Pilots Association
http://www.oregonpilot.org/
RAF Letter:
February 15, 2010
Forest Service Planning NOI
C/O Bear West Company
172 East 500 South
Bountiful, UT 84010
Subject: Comments – USFS Planning Rule Revision NOI dated December 18, 2009
This letter is being submitted to provide the Recreational Aviation Foundation’s comments on proposed USFS planning rules.
The Recreational Aviation Foundation (RAF) is a national public charity organization.
The RAF’s vision is “Preserving the legacy and promoting the enjoyment of aviation in the back country of America”.
The RAF’s mission is “To provide leadership, private financial support, and expertise for preserving and enhancing recreational aviation resources on both public and private lands throughout the United States for present and future generations.
The RAF believes that the USFS needs to place more emphasis on recreation and access to Forest Service lands, employing methods that are ecologically sustainable. To achieve this, the USFS needs to develop a planning process which is efficient, allows adequate public participation (including proper, timely notification of all user groups) and is administered by planners that do not have a personal bias against any particular user group. Consensus is desirable but seldom occurs when one particular interest group fails to participate.
Regarding the Section: Process Principles for a New Rule
1. The current drawn out planning process results in public frustration in the inability of Forest Service personnel to make decisions. This needs to be more efficient and designed so that land management decisions are not driven by threats of lawsuits. Decisions need to be based upon the facts and best science. Final authority must be with the agency, not in the court of law. The final plan authority needs to reside at the Washington Office level to ensure that national management goals are met, and a consistency of application, based on best science, prevents dissimilar application of management practices for otherwise similar plan models.
2. USFS planning should only apply to NFS lands. The USFS has no business influencing other managed lands, whether public or private, unless those land owners volunteer without coercion to participate in some degree in the planning process.
3. There should be one planning process for all NFS lands. This is absolutely necessary for efficiency and accurate public participation.
In the case of the RAF’s participation, the RAF has supporters in 37 states. The guidance given to supporters in how to participate in the NFS planning process should be uniform throughout the country.
4. The RAF has experienced, during participation in several plan revisions, a lack of expertise in our area of interest (recreational aviation). The USFS needs to conduct a review of the entirety of management aspects of the planning process and ensure all relevant activities happening of national forest lands are being addressed. As pertains to airstrips on USFS lands, the FS Manual/Handbook gives responsibility for design and construction to Engineering, but no authority to manage; Fire and Aviation gain control of a specific airstrip in the event of an emergency requiring use of the airstrip, but again, no authority to manage; and Recreation, Lands, Heritage and Wilderness Resources chapters in the Manual/Handbook are silent on airstrips, and again give no authority to manage what is probably the heaviest use of USFS airstrips – Recreational aircraft use. In addition to addressing the above aspects, the USFS needs to ensure a subject matter expert for each planning activity is present on the planning team.
To this end ,the RAF believes there is a need for education beginning with USFS front line planners about aviation. We have attached a copy of our Land Managers Guide regarding aviation and considerations relating to the use of aircraft on public lands.
Airstrips are an appropriate use of National Forest System (NFS) lands as they provide enhanced access for a variety of legitimate recreational activities. These include but are not limited to hiking, camping, fishing and hunting. The RAF has cooperated with user groups related to the above. We recognize their expertise and they ours.
We look forward to a continued positive relationship with the USFS on these issues.
Thank you,
John J. McKenna Jr.
President
Recreational Aviation Foundation
1711 West College Street
Bozeman, MT. 59715
CC: Brendan Fitzpatrick, President OPA
Chuck Jarecki, RAF