Our friends at Stop the Chop NY/NJ, the premier advocacy group fighting non-essential helicopter traffic in our area have sent out a detailed e-mail alert with information on how to submit online testimony on the proposed FAA & NPS Helicopter Sightseeing Plan for the NY Harbor. Below is a copy of their email - we urge you to make your opposition to this plan heard! IMPORTANT ACTION IS NEEDED ON YOUR PART BY MONDAY NOV. 21! Submit your comments on the new FAA & NPS Helicopter Sightseeing Plan for the NY Harbor! See below for links and details on how to use the online NPS comment portal (in case you have trouble with the form, we now have detailed instructions below). STOP THE CHOP NY/NJ DOES NOT SUPPORT THIS PLAN WHICH WILL INCREASE HELICOPTER NOISE & TRAFFIC! On October 21, 2022, the Federal Aviation Administration (FAA) and the National Park Service (NPS) announced a short 30-day public comment period on the draft air tour voluntary agreement for commercial air tour operations (helicopter sightseeing) in the New York Harbor touring the Statue of Liberty, Ellis Island, and Governors Island National Monuments. Stop the Chop NY/NJ,Friends of Liberty State Park, and many of our Congressional representatives have sent letters requesting an extension, but that may not happen. Thus, your comments are due by Monday, November 21! We have drafted the below comments with various topics you can use in your opposition to the new plan which we believe will increase helicopter noise and traffic in the New York Harbor area, resulting in worse conditions for New Yorkers in the Battery Park, South Street Seaport, Brooklyn Heights, Red Hook, Governors Island areas and for Jersyites in the Liberty State Park and Jersey City areas. Please feel free to utilize the letter below, and/or write your own personal comments! Public comments MUST be submitted through the NPS Planning, Environment and Public Comment (PEPC) website through MONDAY, NOVEMBER 21 here: DIRECTIONS ON HOW TO COMMENT VIA THE NPS WEBSITE:
1. Click on the link to the NPS website via this newsletter (Note, the links work as I just submitted our comment using the link is this newsletter. If the link doesn't work for you, try a different internet browser.)
2. Click on “Open For Comment” on the left side of the NPS website
3. Click on the “Draft Voluntary Agreement…” in the center of the website page
4. Click on the “Comment Now” button in the middle of the NPS website page
5. Fill in the form and copy / paste our STCNYNJ letter into the comments box or write your own comments!
6. Hit submit
7. Given the hyper links in the STCNYNJ letter, one has to confirm they aren’t a robot-computer and so one needs to put the random letters / digits in the box and then hit submit
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****To read the actual NPS/FAA draft helicopter tour Agreement and the accompanying Frequently Asked Questions for the New York Harbor click here. HERE IS OUR SAMPLE LETTER: (Copy, cut & paste/ add your comments to personalize it!!) Dear National Park Service (NPS) and Federal Aviation Authority (FAA), As a NYC/NJ metropolitan area resident, I thank you for the opportunity to comment on the proposed “Commercial Air Tour Voluntary Agreement for Statue of Liberty National Monument and Governors Island National Monument.” Unfortunately, I find the proposal to be extremely inadequate and strongly urge the FAA and NPS to revise the plan. Industry Bias
I believe the current proposal is overwhelmingly biased in favor of the nonessential helicopter tourism industry, with no consideration to the industry’s impact on tax-paying New York and New Jersey residents who already suffer from constant helicopter noise and air pollution, has no detail on terrorism or safety risk mitigation, and basically maintains or even worsens the unacceptable status quo. Noise and Air Pollution Impact on NY & NJ Residents
In terms of noise and air pollution, the proposal does nothing to solve the problem. In Section 4.0 of the proposal, the agreement provides “All commercial air tours shall maintain a 1,000 ft. lateral setback from Liberty Island (high water mark), Ellis Island (high water mark), and the Governors Island National Monument boundary…” In addition, the non-essential tourism helicopters are required to fly at a minimum of 500 ft. except when taking off and landing. Yet nowhere in the proposal does it detail or explain how the 1,000 ft buffer and 500 ft. flight elevation minimum prevents the ongoing desecration of our most important National Monument by the 7 day a week noise, nor does it address the issue of excessive air and noise pollution to land-bound tourists or, importantly, residents who work or live in lower Manhattan, western Brooklyn, and Jersey City. In fact, by creating the 1,000 foot setback, this plan will actually increase the noise from these unnecessary joyriding helicopter tours for the Battery Park, South Street Seaport, Brooklyn Heights, Red Hook, and Jersey City communities by bringing them closer to non-NPS controlled land! This is especially problematic given that this plan allows the helicopters to fly at just “500 feet above ground level”, and sound is amplified over water such as the NY Harbor. Negative Impact on Parks
Additionally of concern is the negative impact on New Jersey’s Liberty State Park, the downtown Manhattan and Brooklyn waterfront parks, and the area of Governors Island over which these low-flying helicopters are already and will be flying. Many of these communities in both states are Environmental Justice communities who already bear a disproportionate share of polluting industries. Terrorism Risks
Furthermore, as indicated in Section 3.1 of the proposal, “The Department of Homeland Security (DHS) and the Department of the Interior (DOI) have identified Statue of Liberty National Monument as being at increased risk for terrorist activity, and therefore the park unit is subject to much higher safety and security standards consistent with DOI and DHS critical infrastructure policies.” Again, nowhere in the proposal is there any mention of a solution to these risks! In 2003 Walt Disney World and Disneyland were protected by a 3 mile no-fly zones. The Statue of Liberty, a symbol of our nation, deserves no less. Lack of Transparency
Another real concern is the fact that this Agreement was created as a result of “[d]iscussions between tour operators and NPS staff” (See the Statue of Liberty National Monument and Governors Island National Monument Air Tour Voluntary Agreement: Frequently Asked Questions Document.) Thus, the industry had a seat at the table in drafting this Agreement but the local communities that will suffer the consequences of increased noise pollution and reduced air quality did not. The lack of transparency as to which tour companies helped create this Agreement, and from which heliports they operate, is troublesome. More, Not Fewer, Helicopters
Additionally, this Agreement appears to be increasing the number of sightseeing helicopter companies as the “FAA and NPS intend to enter into the Agreement with [two current operators] as well as two new operators” and “other part 135 operators will also be considered”! Instead, I urge the NPS/FAA to substantially reduce the number of helicopter flights and companies touring the New York Harbor, if not a total ban of them. Other Air Tour Management Plans throughout the country have included caps on the number of sightseeing flights, and yet this New York Harbor plan contains none at all. Will 1,000 helicopters circling the Harbor each day not impact the visitor experience the NPS is charged with protecting? The National Parks Air Tour Management Act of 2000 requires that this Agreement meet the following objectives: “The objective of any air tour management plan shall be to develop acceptable and effective measures to mitigate or prevent the significant adverse impacts, if any, of commercial air tour operations upon the natural and cultural resources, visitor experiences, and tribal lands.”
I believe this proposed Agreement unequivocally fails this mandate. Negative Impact on Environment
Finally, this Agreement makes no mention of the climate impact of these fossil-fuel based nonessential joyriding flights. Helicopters use large amounts of jet fuel; to allow them to be used simply for tourist photo ops as we face a global climate emergency goes against everything the federal and local governments are urging us to do to reduce our climate impact. Conclusion
New York electeds, in seeking to ban or curtail these type of nonessential helicopter flights (and others), due to ever increasing public complaints and numerous recent fatal helicopter crashes, have introduced legislation at all levels of government: Congressional bills H.R. 1643 and H.R. 7769; the New York State “Stop the Chop” bill currently awaiting the Governor’s signature; and at least four separate bills currently pending in the New York City Council.
See https://stopthechopnynj.org/ legislation/ The reality is that the only solution to the above problems is elimination of such nonessential helicopter flights. Fortunately, tourists who seek to view Governors Island, the Statue of Liberty and/or Ellis Island have options by using the existing ferry systems and boat-based tour operators. I strongly urge the FAA and NPS to make the bold but proper step to revise this plan and ban these non-essential sightseeing helicopters in the New York metro area, as no other fair solution is feasible. Sincerely,
Your name Thank you. Best,
Melissa Elstein, STCNYNJ Board Chair, Secretary & Coalition Organizer
http://www.stopthechopnynj.org |
