Attachment_3.2.pdf

Prospectus for Commercially Guided Helicopter Skiing Services on the Seward Ranger District Chugach National Forest

R10-MB-861f

Attachment 3.2 Appendix E – Special Use Permit

Chugach National Forest GPS Permit Protocol and

Performance Standards for Compliance with No-fly Zones

GPS Permit Protocol This document describes the protocol for the use of Global Positioning Systems (GPS) in association with permitted operations on the Chugach National Forest.

Purpose:

This guidance outlines the procedures for using a GPS to assist permit holders and permit administrators as a tool for monitoring permitted use of aircraft &/or other modes of transportation in association with permitted operations on the Chugach National Forest. Data collected will be used to inform both the Forest Service and the permittee regarding daily access routes in relation to areas open to operations, including: access corridors, species considerations, and user conflict occurrences. This technology will inform a continuing dialogue between the Forest Service and permittee during operational periods and support providing high quality experiences while protecting other resource values. This protocol is intended to establish a reasonable process that balances the needs of the public, wildlife, safety, outfitters and guides, and the Forest Service.

Principle:

In carrying out this protocol, permit administrators and permittees will strive to emphasize cooperation and frequent dialogue before, during, and after the operating season, more than, but not as a substitute for compliance with permit terms and conditions.

Considerations:

Practical – There are bound to be occasional incursions into no-fly zones despite our best efforts due to the complexity of addressing geo-spatial shapes across vast terrain, in balance with essential safety-first practices.

Safety – The primary focus of ski guides and the pilots must be on safety. Factors such as snow condition, avalanche terrain, weather events, and operational activities require their immediate and constant attention. Processing GPS data associated with no-fly zones, while important, is secondary to such safety and operational functions.

No Fly Zones and Thresholds Requiring Possible Action:

Before the operating season, the permittee, permit administrators, and, as appropriate, state agency representatives will meet to establish biological, social and economic guidelines as warranted for thresholds of incursions into no-fly zones, monitored with GPS. If these thresholds are exceeded, consultation should occur as soon as possible, and action may be required. Guidelines are to be established collaboratively where possible and will be based on the probability of the incursions having an adverse impact to the resource, such as causing stress to wildlife species. The guidelines will be applied consistently.

Prospectus for Commercially Guided Helicopter Skiing Services on the Seward Ranger District Chugach National Forest

Continuous communication and collaboration are essential and events during the operating season may require adjustments. Clear guidelines for monitoring are to be collaboratively established in advance of the operating season, providing clarity and agreement with permit stipulations. The guidelines may establish what percentage and/or type of encroachment into a no-fly zone will compel consultation and/or result in a specified action. The parties will clearly and jointly agree to definitions and expectations between an acceptable level of performance, a needs improvement, and an unacceptable level of performance.

Operating Season Process:

The permittee will conduct internal daily reviews of collected helicopter flight path data. Incursions into no-fly zones will be categorized, discussed and resolved with pilots and guides. Incursions due to navigational error will be noted and mapped. Raw data and maps, including track logs, will be saved and stored for the duration of the operating season.

As described under “performance standards for compliance with no-fly zones” following three instances of navigational error, a meeting with the Forest Service will occur to identify corrective actions. In the absence of performance discussions brought to the attention of the Forest Service, it will be assumed that performance is adequate.

When requested, the permittee will provide the Forest Service with a performance report for a specific operational day. The performance report will include the following information:

Track log data in a format agreed upon with the Forest Service, such as by computer hard drive or flash memory. All raw data will remain the property of the permittee and be considered proprietary information

A map of the flight lines for the operational day. Maps will not contain temporal information other than date of activity. These maps will remain the property of the permittee and will be returned after review.

Written documentation for any incursions into no-fly zones, including the reason for the incursion, such as weather events and operational safety. This documentation will be part of the public record.

The Forest Service will analyze the data and prepare a report monitoring performance for adherence to the no-fly zones. Performance will be discussed with the permittee and issues will be discussed and documented as needed.

Resolution of Differences:

If differences in interpretation of the flight data and subsequent performance of the permittee are not reconcilable at the Ranger District level during any review period, the issue will be resolved by the Forest Supervisor within 10 days following receipt of the report.

Report:

A report will be prepared by the Forest Service, will address the performance of the permittee, and will include the results of monitoring for noise and for goat habitat and recommendations for potential future use.

Prospectus for Commercially Guided Helicopter Skiing Services on the Seward Ranger District Chugach National Forest

GPS Technology:

Forest Service and permittee will jointly work with GPS equipment vendors to determine the best technology to employ for monitoring heli-ski flights and operations.

Performance Standards for Compliance with No-fly Zones This section defines the “thresholds” related to successful permit compliance. Flights and all entries into no-fly zones will be documented and reported following the procedures listed above.

Entries into no-fly zones will be grouped in the following categories:

GPS Error: Entries of 100’ or less into a no-fly zone will not be considered a navigational error or impact the performance rating. There are several sources of technological error that can impact the accuracy of any GPS system receiving a satellite signal. These sources include errors in locational accuracy from satellite reception as well as datum transformation (NAD27) used so that GPS flight data can be analyzed with Forest Service GIS. This category would mostly apply to landing zones. To account for the GPS margin of error, helicopter landings within no-fly zones of a distance less than 100 feet into the zone will not impact permit compliance.

Safety: Entry into no-fly zones may occur because of safety considerations. Safety considerations would include low-fuel, emergency landings, evacuations, search and rescue response, and potentially other scenarios. Entry into no-fly zones for safety reasons will not impact permit compliance. This does not include landing in no-fly zones to assess snow conditions of authorized use areas.

Weather: Entry into no-fly zones may occur because of poor visibility or weather. These types of entries would be incidental, or safety related. Entry into no-fly zones for these reasons will not impact permit compliance.

Resource conditions: Entries into no-fly zones may occur to avoid observed wildlife. Entry into a no-fly zone for this reason will not impact permit compliance.

Mapping Errors: Occasionally mapping errors occur in downloading and displaying GPS flight data. For example, the GPS track log may show a line into a no-fly zone, even though the flight occurred outside the no-fly zone. Examples of this occur during periods of poor or inadequate satellite coverage, or multipath errors in projecting the data. These situations will not impact permit compliance.

Training and Pre-Season Operations: If pre-season training occurs, entry into a no-fly zone during pre-season operations and training will not impact permit compliance. This includes the first operational day (either with or without clients) within an area for the first time in the season.

Navigational Error: Navigational errors will be defined as entries into no-fly zones greater than 30 seconds, other than entries required due to safety, weather or resource considerations described above.

Examples of navigational error include situations where the guide or pilot had a lack of familiarity with the no fly-zone, could not identify the no-fly zone geographically or simple pilot error. Flights and landings greater than 30 seconds will be noted as navigational errors and may impact permit compliance.

Entries into no-fly zones for less than 30 seconds will be discussed with the pilot and guide but will not impact permit compliance.

Prospectus for Commercially Guided Helicopter Skiing Services on the Seward Ranger District Chugach National Forest

For an acceptable level of compliance related to the no-fly zones, the permittee will:

Following three occasions of navigational errors within a specific no-fly zone, the permittee will provide to the Forest Service maps from flight data showing the incursions and will meet with the Forest Service to identify corrective actions. An occasion refers to an operating day. For example, if there were two or more entries into a no-fly zone in one day, that would be one occasion. Corrective actions will be identified to eliminate subsequent navigational errors into that specific no-fly zone. Corrective actions may include such measures as removal of the use area from the permit, changes in flight paths, or other identified actions. Failure to comply with the corrective actions or subsequent incursions into the specific no-fly zone may result in suspension or revocation of the permit.

Successfully record, download and store GPS flight data on a minimum of 75% of operating days. The flight data (track log) will be available for review by the Forest Service upon request. Should the permittee’s GPS unit become inoperable during the season, the Forest Service should be notified immediately. The permittee will determine the estimated time for repair or replacement. Days spent operating while waiting for repair or replacement will not impact permit compliance. It is expected that the permittee has an operable, tested, unit(s) at the beginning of the season.

Follow the flight recording and reporting procedures protocol described above.

Upon request from the Forest Service, within 24 hours the permittee shall provide to the permit administrator all GPS data from a specific operating date which will be spot checked for accuracy.