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W24(HALE)

August 5, 2008

This letter is in response the Department of Transportation, Federal
Aviation Administration (FAA), Federal Register Notice (Docket Number
FAA-2008-0713), [Notice of Interim Operating Authority (IOA) Granted to
Commercial Air Tour Operators Over National Parks and Tribal Lands
Within or Abutting National Parks]{.underline}, Federal Register: July
8, 2008 (Volume 73, Number 131). Haleakala National Park submits the
following comments:

Currently, IOA has been granted to eight existing helicopter air tour
operators totaling 26,002 operations annually and two existing fixed
wing air tour operators totaling 323 operations annually for Haleakala
National Park. The request from Mauiscape Helicopters for new entrant
IOA for Haleakala National Park would add 4,140 operations to the
current level of IOA of 26,325.

The National Park Service is a cooperating agency with the FAA to
develop an Air Tour Management Plan (ATMP) and environmental impact
statement (EIS) for Haleakala National Parks. An EIS is being prepared
because there is a potential for significant environmental impacts from
the current level of IOA granted to existing air tour operators.
Granting new entrant IOA at this time seems to make presumptions about
the impacts of air tours on the resources of the National Park Service.
In fact, our review of available data indicates that Haleakala National
Park has a noise problem from the current level of IOA and that these
flights may already adversely affect park resources. Because it is the
job of the FAA and NPS to manage air tours to avoid these impacts it
does not seem appropriate to increase the number of flights at this
time, before completion of the ATMP/EIS analysis.

The National Parks Air Tour Management Act of 2000 (NPATMA) states that
the FAA and NPS must consider the following in deciding whether to grant
IOA to new entrant air tour operators: not create a noise problem at the
park or on the tribal lands; and that the granting of IOA shall promote
the protection of national park resources, visitor experiences, and
tribal lands. The NPS is greatly concerned that increasing flights will
add to existing noise problems, increase the audibility levels of
commercial air tour aircraft at various locations in the park, and
increase impacts to park resources and values, which could be
significant.

Haleakala National Park is famous for the natural quiet in the Haleakala
Crater, however, data reported in the 1995 Report to Congress on the
Effects of Aircraft Overflights on the National Park System show that
commercial air tour aircraft were audible 38-76% of the time. The NPS
and FAA began an acoustic monitoring program in 2003 to collect data for
preparation of the ATMP. Data from the measurement sites at Haleakala
National Park provides information on the amount of time commercial air
tour aircraft can be heard over various locations in the park. Observer
logging data from 2003 showed audibility levels of commercial air tour
aircraft still over 60% of the day in some areas of Haleakala Crater.

During public scoping and initial Section 106 consultations under the
National Historic Preservation Act with Native Hawaiian organizations
for the Haleakala National Park ATMP EIS, concerns were raised on the
impacts of the current level of IOA of 26,325 on noise, cultural
resources, visitor experience wilderness values, and threatened and
endangered bird species. There were repeated public comments regarding
the unacceptability of the high number if air tours experiences daily by
people on the ground both within and outside the park.

As directed under NPATMA, the FAA and NPS are charged with mitigating or
preventing the significant impacts of air tour operations over the
parks. The ATMP/EIS process is currently evaluating various factors in
developing a range of alternatives that will include different levels
(i.e., numbers) of air tours, to address the impacts of air tour
operations over Haleakala National Park. The ATMP/EIS environmental
analysis will guide the decision of what level of air tours should be
allowed over or within ½ mile of the boundary of the park. If the final
plan includes a limitation on the number of commercial air tour
operations for any time period, the plan shall provide for the initial
allocation of opportunities to conduct commercial air tour operations.
New entrants would be allowed to compete for allocations at that point
in the process.

The NPS contends that granting new entrant IOA at Haleakala National
Park at this time in the ATMP/EIS process is premature. This will not
promote the protection of park resources and visitor experiences and add
to existing noise problems. We look forward to continuing to work with
FAA on the ATMP/EIS for Haleakala National Park.

Sincerely,

/s/

Marilyn H. Parris

Superintendent