Please accept my comments on the Upper Missouri Breaks RMP.
I am with the Okanogan and Ferry County Chapter of the Washington Pilots Association. Our 30 plus members own and fly personal aircraft for business purposes, for personal transportation, and as employee pilots. Many of our members fly single engine aircraft, several members own and operate aircraft in and out of remote and back country strips, including strips such as those located in the Missouri Breaks National Monument.
Washington Pilots Associatin Chapter members frequently fly from the Pacific Northwest to destinations located in the mid-west, the east coast, and in central Canada. We are therefore very interested that there be a well established and well dispersed network of emergency airstrips should an in-flight emergency occur. The ten airstrips located within the Missouri Breaks provide an essential margin of safety for our members when they overfly the area enroute to other destinations. Recreational use of personal aircraft is on the increase. There are no other public use airports within gliding distance of aircraft overflying the area. The new Sport Pilot Rule (Federal Aviation Regulations, Airmans Information Manual 2005) is expected to significantly increase the number of aircraft making cross country trips under visual flight conditions. The new rule applies to small, single engine, two passenger, propeller driven, piston aircraft. Increased traffic over the Missouri Breaks National Mounument can be expected, with associated increased potential need for emergency airstrips.
Several of our members are no longer able to hike, ride horses or ATVs, or engage in strenuous activities necessary to access many existing Federal Wildernesses. It is essential that these existing back country airstrips within the Missouri Breaks National Monument be retained to provide a portal for our members to enjoy a wilderness experience. Closing these airstrips will exclude them, as well as persons who suffer disabilities under the Americans with Disability Act (ADA) from enjoying these national treasures.
The Missouri Breaks National Monument airpstrips have existed for decades. Some may be eligible for the National Register because of their long and distinguished history of use. The airstrips should be maintained as public use facilities in keeping with their long history of use.
Most or all of the airstrips within the MBNM are located away from rivers used by the general public. The location of the airstrips is therefore not likely to be a visual discontinuity, nor will the sound of aircraft operations interfere with the enjoyment of the natural environment by non-motorized users.
In many instances our members invite friends and family to fly with them when they visit remote, back country airstrips. The ten airstrips within the MBNM will provide enjoyment of the natural world to many people, not just the pilots of aircraft.
We encourage the Bureau to not establish limits on party size, landings/take offs, or numbers of aircraft at one time at any of the airstrips. Typcially our members fly to remote airstrips in flights of two or more aircraft. Flying with companion aircraft increases safety because search and rescue authorities can be notified immediately should one of the aircraft experience a mishap or a mechanical problem. Party limitations may impede this essential 'buddy system'. In addition, since our aircraft are small, with generally fewer than four seats, several aircraft, or several trips may be necessary to fly in a family unit of normal size.
Because of existing roads and other facilities, we suggest that any maintenance of the airstrips be done by mechanical methods to the extent possible. Mechanical methods, including equipment, would be the safest and most cost effective means of maintaining these facilities. Members of the Montana Pilots Association and others in the community of aviation have stated publicly their intention to maintain the facilites to their existing condition or better.
Please add us to the mailing list for the final EIS for the RMP.
November 12, 2005
Attn.: Gary Slagel, Monument Manager
Upper Missouri River Breaks National Monument
PO Box 1160
Lewistown, MT 59457
Subj.: Draft Resource Management Plan, comments on
Ref.: UPPER MISSOURI RIVER BREAKS NATIONAL MONUMENT DRAFT RESOURCE MANAGEMENT PLAN and ENVIRONMENTAL IMPACT STATEMENT SEPTEMBER 2005
Encl.: Photo Sheet
Dear Gary,
As a pilot, aircraft owner, and backcountry aviation enthusiast, I have reviewed the referenced plan with respect to aviation and first would like to thank you and your team for putting six of the existing airstrips in your preferred Alternative F which I fully support. It is encouraging to see that airstrips are finally being recognized as legitimate trailheads on public lands for a significant user group and that they do fit into the overall management goals of the Bureau of Land Management (BLM) to provide for multiple use and diverse recreational opportunities. In the referenced plan, “multiple use” is defined as “harmonious and coordinated management of the various resources without permanent impairment of the land and the quality of the environment (43 USC 1702).” I believe that aviation access to the Monument as identified in Alternative F falls securely within that definition as discussed below.
The ten existing airstrips within the Monument have been in existence and under continual use for decades, and yet there is no evidence of soil erosion. This is in marked contrast to scars left on the landscape by other forms of motorized and non-motorized transportation. I recently landed at Cow Creek airstrip and noted that the overall runway surface supports a very healthy growth of native grass except for the two eroded automobile tracks down the center of the runway. I could see light impressions upon the grass where aircraft had been landing on either side of the automobile tire tracks. Aircraft have no powered wheels, and therefore do not tear up the soil. Also, once an airplane lands, it remains parked until the occupants are ready to end their visit.
The locations of the six airstrips identified in the preferred alternative are in the uplands of the Monument and dispersed such that there will be minimal impact by aircraft arrivals and departures upon boaters on the river or other users within the Monument. Even then, these arrivals and departures are of very short duration having no lasting impact and have been shown by numerous studies to have negligent or no impact upon wildlife. Even so, the preferred alternative includes seasonal restrictions on some of the airstrips to protect wildlife at vulnerable times of year, and that is appropriate where deemed necessary. Despite the fact that the six airstrips appear on a map to be in close proximity to each other, the rugged, deeply incised landscape of the river breaks means that the airstrips are hours of foot travel apart from each other. The areas in which the six identified airstrips are located are not of wilderness character and include numerous roads, gas leases and wells, and livestock grazing improvements like fences and water impoundments, all of which need mechanized means of maintenance.
While fully supporting preferred Alternative F, I note that in Alternative C the Woodhawk airstrip is also identified for remaining open. I’m not sure why Woodhawk was not included in the preferred alternative other than possibly its location within the boundary of the wild and scenic river corridor, and I have been told that it was illegally constructed more recently that the other airstrips. While within the wild and scenic river corridor, it is again in the uplands and would not impose any impact upon the river environment. And while it may have been illegally constructed, Woodhawk is one of only two existing airstrips south of the river and is separated sufficiently from the other six identified airstrips to make it a useful addition to those six. It also appears to be in reasonably good condition. While there may be other factors in your decision that I am unaware of, I would ask that you reconsider including Woodhawk in the final decision. I also note that Alternative C and the preferred Alternative F both propose the application of adaptive management decisions responsive to changing conditions including increasing visitation and risks to resources that could occur over time. I fully support this management approach as it allows for adjustments in either direction as dictated by changing circumstances and needs. Regardless of your final decision with regard to Woodhawk, I want you to know that I fully support preferred Alternative F and ask that you include the six identified airstrips in your final decision.
Internal airstrip trailheads utilize significantly less real estate than other trail heads when overland access to other trailheads is considered. Aircraft use of these airstrip trailheads has the least impact upon the land and the surrounding environment compared to all other means of access except possibly watercraft and seaplanes. Allowing access via these airstrip trailheads also reduces motorized travel across the land to access the interior portions of the Monument. The use of aircraft to access the Monument is the personal choice of the pilot, family, and friends just as is the case in all other means of access. Additionally, these airstrip trailheads provide a method for disabled persons to reach remote sites within the Monument in accordance with the Americans with Disabilities Act when they cannot suffer the long overland journey. I have in the past enjoyed flying elderly relatives and friends into Schafer airstrip within the Great Bear Wilderness, an experience they could not have enjoyed without such an airstrip trailhead. I have enclosed a photo sheet from some of my backcountry airstrip experiences in Montana, Idaho, and Utah. I hope that you will see that they show aviation and backcountry airstrips as a beneficial and viable multiple use of our public lands. Airstrip trailheads in the Upper Missouri River Breaks National Monument will provide another unique outdoor environment for airplane camping, photography, and hiking in the surrounding areas.
These airstrip trailheads are useful for other activities in addition to recreation such as search and rescue, firefighting, law enforcement, and land management activities. They also provide emergency landing sites under the heavily used Missouri River east-west flight corridor in case of poor flying weather or mechanical problems. These airstrips would be charted and entered into the FAA database so that the aviation public will know of their existence and can be notified by Federal Aviation Administration NOTAM of any seasonal closures needed to mitigate reasonable wildlife concerns or other factors. I once made an emergency landing at an Idaho backcountry airstrip when I had an indication of loss of engine oil pressure. Fortunately, the cause was interference between my radio and the electronic oil pressure indicator. In any case, having that remote airstrip available for a precautionary landing was very much appreciated by this pilot!
The Montana Pilots Association has established over the years a very solid working relationship with the Spotted Bear Ranger District of the Flathead Forest for maintenance of the Meadow Creek, Spotted Bear and Schafer airstrips through voluntary labor, material, and funding, thus relieving the burden upon the government. I’m sure Montana Pilots Association as well as myself will welcome the opportunity to provide the same support for those airstrips identified in the final decision. Through volunteer agreements similar to those used by the United States Forest Service and because of the Montana Recreational Use Statute, there would be no legal liability incurred by the BLM other than that identified as gross negligence.
Again, thank you for including the six airstrips in the preferred alternative. It is rewarding to see aviation as part of a resource planning document for public lands, something I have been striving for over the last few years.
Sincerely,