AircraftOwner Online

I am one of six directors of the Recreational Aviation Foundation (RAF), a national, public charity organization. The RAF has financial supporters in forty-nine states. The RAF's vision is "Preserving the legacy and promoting the enjoyment of aviation in the backcountry of America". The RAF is involved in both terrestial and water landing site issues. 

From a personal perspective, I live on a large lake (Flathead). I do not have a boat, but many others do and the noise can be irritating at times. However, as I get older (72 years as of today), I become more tolerant of other people's activities. All users of Ross Lake should have the same attitude.

I have a seaplane that I use for personal transportation to reach many destinations for recreational activities. Once I land and tie up to the dock, the plane does not move until I leave to go somewhere else. The noise signature is minimal compared to the long periods of engine noise from boats. Unless you have a detailed environmental analysis as to why seaplanes are more of an environmental concern that other methods of water access, I suggest you not limit seaplane access to Ross Lake. It appears that seaplanes are a perceived social issue, not environmental.

 The RAF supports the balanced use of our public lands by various means of access as long as those access means do not cause irreversible environmental degradation. We believe that seaplanes are a compatible use of the waters of Ross Lake. Other seaplane users will undoubtedly provide more reasons to support seaplanes and I will not repeat them here.

 In conclusion, it appears that there is no logical reason to ban seaplanes from the majority of Ross Lake. Dispersed recreational use is preferred to concentrated use. The RAF supports the continued, unrestricted use of seaplanes on the entirety of Ross Lake.

My comments as submitted: There should be no changes made to seaplane access in the Ross Lake National Recreation Area. Seaplane access in completely within the definition of what National Recreation Areas are intended to be.  

According to the FEDERAL EXECUTIVE BRANCH POLICY GOVERNING THE SELECTION, ESTABLISHMENT, AND ADMINISTRATION OF NATIONAL RECREATION AREAS BY THE RECREATION ADVISORY COUNCIL, the criteria for becoming a National Recreation Area include the following requirements:

1. National Recreation Areas should be spacious areas…  

2. National Recreation Areas should be located and designed to achieve a comparatively high recreation carrying capacity, in relation to type of recreation primarily to be served…  

3. National Recreation Areas should provide recreation opportunities significant enough to assure interstate patronage within the region of service, and to a limited extent should attract patronage from outside of the normal service region.  

4. The scale of investment, development, and operational responsibility should be sufficiently high to require either direct Federal involvement, or substantial Federal participation to assure optimum public benefit.  

5. Although nonurban in character, National Recreation Areas should nevertheless be strategically located within easy driving distance, i.e., not more than 250 miles from urban population centers which are to be served. Such areas should be readily accessible at all times, for all-purpose recreational use.  

6. Within National Recreation Areas, outdoor recreation shall be recognized as the dominant or primary resource management purpose. If additional natural resource utilization is carried on, such additional use shall be compatible with fulfilling the recreation mission, and none will be carried on that is significantly detrimental to it.  

To restrict seaplane access is clearly opposite of the stated intent of National Recreation Areas in general, and specifically as defined in NRA Criteria #5 above which states that any NRA "should be readily accessible at all times, for all-purpose recreational use."  

Seaplanes provide visitors a perspective which engenders a deep respect for the natural appearance of area. They require little infrastructure and are an integral and well accepted part of the region's transportation tradition and history.  

To suggest that seaplanes are some how less desirable than motor boats, jet-skis, ski boats and the like is preposterous. Seaplane operations are limited in duration, and only the hulls of the floats make contact with the lake. All other motorized vehicles on the lake are in constant contact with the water, and require physical intake and outflow of lake water to remain operational. They are frequently refueled lakeside, or on the lake. It is not at all unusual to see telltale evidence of fuel and oil spills found adjacent to them. This is not the case with seaplanes.  

As well, seaplane operations are, by their very nature, limited in duration. Motorized watercraft, on the other hand are operating their motors when ever they are in motion.  

Then there is the question of alcohol and alcohol related accidents and incidents. Pilots are required by law not to consume any alcohol within eight hours of operating their aircraft. Boaters are not so constrained. Unfortunately and by contrast, Washington State holds the unenviable state ranking of #12 in the category of "Number of Alcohol Related Injuries in Recreational Boating Accidents" and is #15 in the per capita rankings.
Seaplanes should be allowed full and unfettered access to any and all areas of the Ross Lake National Recreation Area, consistent with access provided to motorized watercraft. Ross Lake is not a Wilderness Area – it is a National Recreation Area. It should continue to be treated as such in accordance to the original intentions of its designation.

Bob Kay's comments:
Here's a copy of the text Bob Kay sent to that website:  
I applaud National Park Service efforts to collaborate with interested individuals to formulate plans concerning the future of seaplane access at Ross Lake.  

I personally support leaving the existing access for seaplanes at Ross Lake as is.  The existing access has worked since inception and no data exists to suggest this might change.  Here are some reasons I am against placing additional restrictions on seaplane access:  

• Few, if any, noise complaints have been raised by visitors or anyone else. It is unlikely this will change as seaplane rated pilots are decreasing in number and Ross Lake remains a relatively remote location.
• Seaplane use of the area has never been excessive and no information appears to suggest this will change.  Excessive use was a concern when the existing plan was originally adopted in the 1980’s and has not since materialized.
• The new proposals do not provide adequate and secure/safe campsites to seaplane visitors.  There are only a limited number of campsites (north facing with a dock) which are well suited for float planes.  It would be unfair to eliminate access for seaplanes to preferred campsites and facilities.
• When viewed in aggregate, seaplanes make less noise than outboard engines.  It has been estimated that less than a dozen seaplanes use the lake in a season.  Seaplanes only make a sizable noise print during the takeoff phase of flight; for about 30 to 60 seconds.  The total time of noise (in excess of that of an outboard motor) is no greater than 10 to 12 minutes per year. 
• Any concerns about noise or excessive use could be readily addressed through the implementation of a standard noise abatement policies and published guidelines for seaplane access.
• A permit system limiting seaplane access is unnecessary and may be costly and difficult to administer.
• Seaplanes are often mentioned in the same “motorized usage” sentence as jet-skis and motorboats; however, they differ vastly in use, pollution levels, and overall noise output.  Seaplanes are a mode of transportation used to access recreational opportunities on the lake.  Conversely, motorboats are used as primary recreational vehicles after accessing the lake. 
• If access is accorded motorboats and water taxis throughout the lake, then it is unfair and unjust to limit or eliminate seaplane access.
• Seaplane pilots are responsible, conscientious, and formally trained wilderness visitors.  They are federally licensed, legally bound to not consume alcohol while flying, and required to complete airplane recurrent training every two years.  Few other Ross Lake guests are held to such rigorous conduct and training standards.    Seaplanes provide a means of access for the elderly and the handicapped unable to readily access the lake by other methods.
• Seaplanes have historical significance in the northwest and should continue to remain part of the overall Ross Lake experience.

  Thoughts for your submission:

The National Park Service is creating a management plan for Ross Lake National Recreation Area in Washington state which would affect a wide variety of activities and, as proposed, would severely restrict seaplane operations on the lake.  Washington Seaplane Pilot’s Association www.wa-spa.org (WSPA) is leading the effort along with the RAF, WPA, AOPA and the Seaplane Pilots Association to ensure that seaplanes will still have full access to the lake and are calling on individual pilots to register their feedback.

Please read the following introduction and then send in your feedback so the National Park Service will have evidence that we are a large constituency and it is important for us to maintain access.  Please let us know if you will be able to submit input so we have our own record.  (email: Stephen@ratzlaff.co).  The official deadline for submissions is September 30^th.  We believe early submissions have greater impact so we are asking that pilots submit their comments by August 31^st.

Ross Lake provides a unique experience for seaplane pilots as an extraordinary beautiful lake in a remote environment including campsites (with docks) all maintained by the National Park Service.  It is ideal for seaplane camping and we need to do everything we can to preserve our current access.

Ross Lake was created by the damming of the Skagit River and is in the recreation area of the North Cascades National Park.  Besides seaplanes, the lake may be accessed through the Ross Lake Resort which is situated in a line of twelve individual cabins and three bunkhouses built on log floats.  The Resort maintains boats with outboard motors for traversing the lake.   There are two ways to get to Ross Lake via land; either from the south by foot or ferry, or from the north via Canada and a 30 mile gravel road.  For those pilots on wheels, the nearest airports are Concrete(3W5) and Darrington (1S2).  Given the sensitivity to airplanes at this time, we highly suggest limiting flyovers at this time.

Many concerned pilots recently attended a series of meetings in Washington hosted by the National Park Service for seaplane pilots and others to discuss the draft general management plan and environmental impact statement.  The park service has created four alternative plans for managing the area, and each would have a different impact on the level of seaplane access.  Their preferred option would limit the seaplanes to the north and south ends of the lake, and prevent access to nearly all acceptable seaplane campsites – their proposal would essentially eliminate seaplane access.

The pilots attending the meetings presented our case in a professional and polite manner.  They reminded the National Park Service that it had already determined that seaplane operations only numbered one or two dozen a year at the lake and there was no history of complaints about seaplanes.  Pilots in attendance explained that limiting operations to certain areas of the lake wouldn’t be feasible because the aircraft often need to land near the center of the lake for wind conditions, water depth, obstructions, and docking facilities.

The NPS officials appeared to understand that the current proposal was not feasible nor was it fair to seaplane pilots.  Furthermore they saw the level of support for maintaining access for floatplanes.  

The next stage in the process is for those concerned to submit formal comments regarding the proposed plan to the NPS.  The deadline for submission is September 30^th, 2010.  If you are a seaplane pilot now or hope to be in the future, and wish to maintain access to this wonderful location, please submit your comments to the National Park Service.

These should be provided electronically at the following location: http://parkplanning.nps.gov/commentForm.cfm?parkID=337&projectID=16940&documentId=35271

Suggested comments:

·         I support leaving current access for seaplanes as it is today.  It has worked since inception and there is no data to suggest this might change.

·         Few, if any, noise complaints have been raised by visitors or anyone else.  It is unlikely this will increase as seaplane rated pilots are decreasing in number and Ross remains a relatively remote location.

·         The proposal does not provide adequate and secure/safe campsites to seaplane visitors.  Only north facing campsites provide sufficient protection from the southerly swell.

·         Any concerns about noise or excessive use could be readily addressed through the implementation of a standard noise abatement policy and guidelines for seaplane access.

·         A permit system limiting seaplane access is unnecessary and is not supported.

Additional comments may include:

·         Seaplane use of the park has never been excessive and there is no data to suggest that will changes.  This was also a concern when the prior plan was developed in the 1980’s and excessive use has not since materialized.

·         Seaplanes make less noise then outboard engines in aggregate.  It has been estimated that there are probably less than a dozen seaplanes in a season.  Seaplanes only make sizable noise when taking off which only lasts 30 to 60 seconds.  The total time of noise (in excess of an outboard motor) is no greater than 10 to 12 minutes a year.

·         Seaplanes have historical significance to the northwest and should remain a part of Ross Lake.

·         If access is still provided to motorboats throughout the lake, then it is unfair and unjustified to limit seaplanes access.

·         There are only a limited number of campsites (north facing with a dock) which are well suited for float planes.

·         Seaplanes provide access to the elderly and handicapped, who cannot readily access Ross Lake.

·         It is unfair to eliminate access for seaplanes to the preferred campsites.

·         Seaplanes are a classic part of the history of the northwest.

·         Seaplanes are a mode of transportation, unlike jet-skis and ski boats.  They are generally used to access the lake and then leave.  Seaplanes are often used in the same sentence with jet-skis yet they are vastly different in use and noise output.

·         Seaplanes pollute less than any motor boats.  Engine exhaust does not enter the water.

·         Seaplane pilots must be licensed by the federal government and are required to complete recurrent training.  (They are legally bound to not consume alcohol and fly.)  The pilot community is also very effective at policing themselves.  This is one reason few problems occur with those in the seaplane community.

·         Limiting seaplane access to the proposed areas reduces safety by artificially

If you would like to get detailed information about the process and the proposals, you may download the latest Newsletter from: http://parkplanning.nps.gov/showFile.cfm?projectId=16940&docType=public&MIMEType=application%252Fpdf&filename=ROLA%5FAlts%5FNewsletter%5F060210b%5Flores%2Epdf&clientFilename=ROLA%5FAlts%5FNewsletter%5F060210b%5Flores%2Epdf

For more information, please contact Stephen Ratzlaff, WSPA board member at stephen@ratzlaff.co