On behalf of the Tennessee Ornithological Society (TOS) I am submitting the following comments on the Draft Air Tour Management Plan (ATMP) for Great Smoky Mountains National Park. TOS is the leading voice supporting the hobby of birdwatching, conducting bird research, and advocating for the protection of birds and their habitats.
We find that there is insufficient data to evaluate several aspects of the ATMP including the allowable number of air tour flights. The current number of flights authorized in the draft ATMP is 1,942 annually. This number is derived from the “temporary” Interim Operating Authority and is somehow based on the fact there was an average of 946 flights conducted annually, from 2017 – 2019. There is no further explanation. Hence, we are unable to evaluate whether 1,942 flights per year is acceptable or unacceptable, as it relates to affects on the soundscape.
However, we do support the other restrictions in the draft ATMP and would like to see them added to the temporary IOA while awaiting implementation of an ATMP.
It is our opinion that without more data or alternatives to choose from we cannot support the Draft Air Tour Management Plan for the Great Smoky National Park as written.