Wildlife Damage Management, Internet Center for

USDA National Wildlife Research Center -

Staff Publications

University of Nebraska - Lincoln Year 

Wildlife Hazard Management at

Airports: A Manual for Airport

Personnel

Edward C. Cleary∗ Richard A. Dolbeer†

∗Staff Wildlife Biologist, U.S. Department of Transportation, Federal Aviation Administration

†National Coordinator, Airports Program, U.S. Department of Agriculture, Animal &

Plant Health Inspection Service

This paper is posted at DigitalCommons@University of Nebraska - Lincoln.

http://digitalcommons.unl.edu/icwdm usdanwrc/133
Wildlife Hazard Management at Airports 

A Manual for Airport Personnel 

Prepared by 

Edward C. Cleary 

Staff Wildlife Biologist 

U.S. Department of Transportation 

Federal Aviation Administration 

Office of Airport Safety and Standards 

800 Independence Avenue 

Washington, DC 20591, USA 

Richard A. Dolbeer 

National Coordinator, Airports Program 

U.S. Department of Agriculture 

Animal & Plant Health Inspection Service 

Wildlife Services 

6100 Columbus Avenue 

Sandusky, OH 44870, USA 

Second Edition, July 2005 
The Federal Aviation Administration, in cooperation with the U.S. Department of 

Agriculture, Animal and Plant Health Inspection Service, Wildlife Services, produced the 

second edition of this manual. The first edition was published December 1999. 

The U.S. Departments of Transportation and Agriculture prohibit discrimination in all 

their programs and activities on the basis of race, color, national origin, gender, religion, 

age, disability, political beliefs, sexual orientation, or marital or family status (not all 

prohibited bases apply to all programs). Persons with disabilities who require 

alternative means for communication of program information (Braille, large print, 

audiotape, etc.) should contact one of the authoring agencies. 

 
i 

TABLE OF CONTENTS 

LIST OF CHAPTERS .................................................................................................... ii

LIST OF TABLES ........................................................................................................viii

LIST OF FIGURES........................................................................................................ x

LIST OF APPENDICES................................................................................................ xi

ACKNOWLEDGEMENTS..........................................................................................137

SELECTED PUBLICATIONS AND WEB SITES .......................................................139

GLOSSARY...............................................................................................................143

ACRONYMS..............................................................................................................149

APPENDICES ...........................................................................................................151
ii Table of Contents 

LIST OF CHAPTERS 

CHAPTER 1: INTRODUCTION TO THE WILDLIFE STRIKE PROBLEM .....................1

CHAPTER 2: THE FAA NATIONAL WILDLIFE STRIKE DATABASE FOR CIVIL 

AVIATION....................................................................................................5

2.1 Introduction..................................................................................................5

2.2 Reporting wildlife strikes..............................................................................6

2.3 Management of the database......................................................................6

2.4 Use of and access to information in the database.......................................7

2.5 Summary of wildlife strike records, 1990-2003............................................8

2.5.a Strike frequency ..........................................................................9

2.5.b Types of wildlife involved...........................................................13

2.5.c Characteristics of strikes ...........................................................13

2.5.d Aircraft components struck and damaged .................................13

2.5.e Effects of wildlife strikes on aircraft and flights ..........................14

2.6 Selected examples of wildlife strikes .........................................................17

2.7 Conclusions...............................................................................................22

CHAPTER 3: AGENCIES AND ORGANIZATIONS IMPACTING WILDLIFE 

HAZARD MANAGEMENT ON AIRPORTS................................................23

3.1 Introduction................................................................................................23

3.2 Federal agencies.......................................................................................24

3.2.a U.S. Department of Transportation, Federal Aviation 

Administration............................................................................24

3.2.a.i Mission................................................................................24

3.2.a.ii Authority..............................................................................24

3.2.a.iii Role and responsibility........................................................24

3.2.a.iii.a Office of Airport Safety and Standards ......................................24

3.2.a.iii.b Wildlife hazard assessments .....................................................25

3.2.a.iii.c Wildlife hazard management plans ...........................................25

3.2.a.iii.d Advisory Circulars (150/5200 Series) ........................................25

3.2.b U.S. Department of Agriculture, Wildlife Services .....................26

3.2.b.i Mission................................................................................26

3.2.b.ii Authority..............................................................................26

3.2.b.iii Role and responsibility........................................................26

3.2.c U.S. Department Of Defense.....................................................27

3.2.c.i Mission................................................................................27

3.2.c.ii Authority..............................................................................27

3.2.c.iii Role and responsibility........................................................27

3.2.d U.S. Army Corps of Engineers ..................................................28
Table of Contents List of Chapters iii 

3.2.d.i Mission................................................................................28

3.2.d.ii Authority..............................................................................28

3.2.d.iii Role and responsibility........................................................28

3.2.e U.S. Environmental Protection Agency .....................................28

3.2.e.i Mission................................................................................28

3.2.e.ii Authority..............................................................................28

3.2.e.iii Role and responsibility........................................................28

3.2.e.iii.a Landfills .....................................................................................29

3.2.e.iii.b Pesticides ..................................................................................29

3.2.f U.S. Department of Interior, U.S. Fish And Wildlife Service ......29

3.2.f.i Mission................................................................................29

3.2.f.ii Authority..............................................................................29

3.2.f.iii Role and responsibility........................................................30

3.3 State agencies...........................................................................................30

3.3.a State wildlife management agencies .........................................30

3.3.b State environmental protection agencies ..................................31

3.3.b.i Landfill siting permits and inspections.................................31

3.3.b.ii Pesticide registration...........................................................31

3.3.b.iii Pesticide applicator licensing..............................................31

3.4 Airports......................................................................................................31

3.4.a Airport operator .........................................................................31

3.4.b Air Traffic Control ......................................................................32

3.4.c Pilots .........................................................................................32

3.5 Bird Strike Committee - USA.....................................................................33

CHAPTER 4: FEDERAL REGULATIONS AND DEPARTMENTAL POLICIES 

IMPACTING AIRPORT WILDLIFE MANAGEMENT..................................35

4.1 Introduction................................................................................................35

4.2 Summary of applicable federal regulations................................................36

4.2.a Title 14, Code of Federal Regulations, part 139........................36

4.2.b Title 40, Code of Federal Regulations, part 258.10...................36

4.2.c Title 50, Code of Federal Regulations, parts 1 to 199 ...............36

4.2.c.i Depredation permitting requirements and procedures ........37

4.2.c.ii Standing depredation orders...............................................37

4.2.d The Migratory Bird Treaty Act of 1918, as amended 

(U.S. Code 603-711; 40 Statute 755)........................................38

4.2.e The Animal Damage Control Act of 1931, as amended 

(7 U.S. Code 426-426c; 46 Statute 1468) .................................38

4.2.f Federal Insecticide, Fungicide, and Rodenticide Act, as 

amended (7 U.S. Code 136; Public Law 104.317) ....................39
List of Chapters Table of Contents iv 

4.3 Departmental policies................................................................................39

4.3.a FAA Advisory Circulars .............................................................39

4.3.a.i 150/5200-32A. Reporting wildlife aircraft strikes................39

4.3.a.i 150/5200-33A. Hazardous wildlife attractants on or near 

airports................................................................................39

4.3.a.ii 150/5200-34. Construction or establishment of landfills 

near public airports .............................................................40

4.3.b FAA, Airports Division: Airport Certification Program Policies 

and Guidance............................................................................40

4.3.b.i Policy No. 77. Initiation of wildlife hazard assessments 

at airports............................................................................40

4.3.b.ii Policy No. 78. Section 7 consultation on endangered or 

threatened species..............................................................40

4.3.b.iii Policy No. 79. Review of airport wildlife hazard 

management plans. ............................................................40

4.3.b.iv Policy No. 82. Waste disposal facility coordination. ...........41

4.3.c FAA, Airports Division, Office of Airport Safety and 

Standards, Certalerts relating to airport wildlife management ...41

4.3.c.i Certalert No. 98-05. Grasses attractive to hazardous 

wildlife .................................................................................41

4.3.c.ii Certalert No. 04-09. The relationship between FAA and 

USDA/WS. ..........................................................................41

4.3.c.iii Certalert No 04-16. Deer hazards to aviation and deer 

fencing. ...............................................................................41

4.3.d USDA, Wildlife Services Directive 2.305, Wildlife Hazards To 

Aviation .....................................................................................41

4.3.e Memorandum of Understanding: FAA and USDA/WS ..............42

4.3.f Interagency Memorandum of Agreement ..................................42

CHAPTER 5: RECOGNIZING HAZARDOUS WILDLIFE ATTRACTANTS ON OR 

NEAR AIRPORTS .....................................................................................43

5.1 Introduction................................................................................................43

5.2 Separation criteria for hazardous wildlife attractants on or near airports...44

5.2.a Airports serving piston-powered aircraft ....................................44

5.2.b Airports serving turban-powered aircraft ...................................44

5.2.c Protection of approach or departure airspace ...........................45

5.3 Land-use practices that potentially attract hazardous wildlife....................45

5.3.a Waste disposal operations ........................................................45

5.3.a.i Siting new municipal solid waste landfills subject to AIR 

21........................................................................................45

5.3.a.ii Siting new municipal solid waste landfills not subject to 

AIR 21.................................................................................47
Table of Contents List of Chapters v 

5.3.a.iii Considerations for existing waste disposal facilities 

within the limits of separation criteria ..................................47

5.3.b Trash transfer stations...............................................................48

5.3.c Composting operations on or near airport property...................48

5.3.d Underwater waste discharges ...................................................49

5.3.e Recycling centers ......................................................................49

5.3.f Construction and demolition debris facilities .............................49

5.3.g Fly ash disposal.........................................................................49

5.4 Water management facilities .....................................................................50

5.4.a Existing storm water management facilities ..............................50

5.4.b New storm water management facilities....................................51

5.4.c Existing wastewater treatment facilities.....................................52

5.4.d New wastewater treatment facilities ..........................................52

5.4.e Artificial marshes .......................................................................52

5.4.f Wastewater discharge and sludge disposal ..............................53

5.5 Wetlands ...................................................................................................53

5.5.a Existing wetlands on or near airport property ............................53

5.5.b New airport development ..........................................................54

5.5.c Mitigation for wetland impacts from airport projects ..................54

5.5.c.i On-site mitigation of wetland functions ...............................54

5.5.c.ii Off-site mitigation of wetland functions ...............................55

5.5.c.iii Mitigation banking...............................................................55

5.6 Dredge spoil containment areas................................................................55

5.7 Agricultural activity ....................................................................................55

5.7.a Crop production.........................................................................55

5.7.b Livestock production..................................................................56

5.7.c Aquaculture ...............................................................................56

5.7.d Alternative uses of agricultural land...........................................56

5.8 Golf courses, landscaping and other land-use considerations ..................57

5.8.a Golf courses ..............................................................................57

5.8.b Landscaping and landscape maintenance ................................57

5.8.c Other hazardous wildlife attractants ..........................................58

5.9 Synergistic effects of surrounding land uses .............................................58

CHAPTER 6: DEVELOPING WILDLIFE HAZARD MANAGEMENT PROGRAMS 

AT AIRPORTS...........................................................................................59

6.1 Introduction................................................................................................59

6.2 Wildlife hazard assessment.......................................................................60

6.2.a Requirement for wildlife hazard assessment.............................60

6.2.b Necessary elements of a wildlife hazard assessment ...............61
vi List of Chapters Table of Contents 

6.2.c Duration of wildlife hazard assessment and basic survey 

techniques.................................................................................63

6.3 Wildlife hazard management plan .............................................................64

6.3.a Requirement for wildlife hazard management plan ...................64

6.3.b. National Environmental Policy Act review .................................65

6.3.c Necessary elements of a wildlife hazard management plan......66

CHAPTER 7: EVALUATING WILDLIFE HAZARD MANAGEMENT PROGRAMS AT 

AIRPORTS ................................................................................................81

7.1 Introduction................................................................................................81

7.2 Monitoring and record keeping..................................................................82

7.2.a Hazard assessments, plans, and studies ..................................82

7.2.b Daily log of wildlife control activities ..........................................82

7.2.c Daily log of wildlife strikes .........................................................83

7.2.d Records of significant management actions taken ....................85

7.2.e Summary reports by month and year ........................................85

7.2.f Training .....................................................................................86

7.3 Assessment of wildlife hazard management plan......................................86

7.4 Airport wildlife hazards working group.......................................................87

7.4.a Function ....................................................................................87

7.4.b Membership...............................................................................87

7.4.c Meetings....................................................................................88

7.4.d Meeting reports .........................................................................88

7.5 Summary and conclusions ........................................................................89

CHAPTER 8: WILDLIFE HAZARD MANAGEMENT TRAINING FOR AIRPORT 

PERSONNEL.............................................................................................99

8.1 Introduction................................................................................................99

8.2 Training ...................................................................................................100

8.2.a Bird identification.....................................................................100

8.2.b Mammal identification..............................................................102

8.2.c Basic life histories and behavior of common species ..............102

8.2.d Wildlife and environmental laws and regulations.....................103

8.2.e Wildlife control techniques.......................................................104

8.2.f Record keeping and strike reporting........................................105

8.3 Sources of training ..................................................................................106

8.4 Wildlife hazard management library ........................................................107

8.5 Field guides and reference books ...........................................................107

CHAPTER 9: WILDLIFE CONTROL STRATEGIES AND TECHNIQUES AT 

AIRPORTS ..............................................................................................111

9.1 Introduction..............................................................................................111

9.2 Wildlife control strategies.........................................................................113
Table of Contents List of Chapters vii 

9.2.a Aircraft flight schedule modification.........................................114

9.2.b Habitat modification and exclusion..........................................114

9.2.b.i Food..................................................................................114

9.2.b.ii Cover ................................................................................115

9.2.b.iii Water ................................................................................117

9.2.b.iv Exclusion techniques ........................................................118

9.2.b.iv.a Exclusion of birds ....................................................................118

9.2.b.iv.b Exclusion of mammals.............................................................119

9.2.c Repellent techniques...............................................................120

9.2.c.i Wildlife patrols and runway sweeps in vehicles ................121

9.2.c.ii Chemical repellents for birds ............................................121

9.2.c.iii Chemical repellents for mammals.....................................123

9.2.c.iv Audio repellents for birds ..................................................123

9.2.c.v Audio repellents for mammals ..........................................124

9.2.c.vi Visual repellents for birds..................................................125

9.2.c.vii Visual repellents for mammals..........................................126

9.2.c.viii Trained falcons and dogs to repel birds ............................126

9.2.c.ix Radio-controlled model aircraft to repel birds ...................126

9.2.c.x Nonlethal projectiles to repel birds....................................127

9.2.d Wildlife removal techniques.....................................................127

9.2.d.i Capturing birds and mammals ..........................................127

9.2.d.i.a Chemical capture of birds........................................................128

9.2.d.i.b Live-trapping birds...................................................................128

9.2.d.i.c Chemical capture of mammals ................................................129

9.2.d.i.d Live-trapping mammals ...........................................................129

9.2.d.ii Killing birds and mammals ................................................129

9.2.d.ii.a Destroying eggs and nests ......................................................130

9.2.d.ii.b Shooting birds .........................................................................130

9.2.d.ii.c Shooting mammals..................................................................131

9.2.d.ii.d Oral toxicants for birds.............................................................132

9.2.d.ii.e Contact toxicants for birds.......................................................132

9.2.d.ii.f Toxicants for mammals ...........................................................133

9.2.d.ii.g Fumigants for mammals ..........................................................134

9.2.d.ii.h Lethal traps for mammals ........................................................134

9.3 Conclusions.............................................................................................134

9.4 Other sources of information ...................................................................135
viii Table of Contents 

LIST OF TABLES 

Table 2-1. Source of information for reported wildlife strikes to civil aircraft, USA, 

1990–2003...................................................................................................7

Table 2-2. Person filing report of wildlife strike to civil aircraft, USA, 1990–2003. ........9

Table 2-3. Number of reported wildlife strikes to civil aircraft by type of operator, 

USA, 1990–2003. ........................................................................................9

Table 2-4. Number of reported bird, mammal, and reptile strikes to civil aircraft by 

USA state, including the District of Columbia (DC), Puerto Rico (PR), 

USA-possessed Pacific Islands (PI), and the U.S. Virgin Islands (VI), 

1990–2003.................................................................................................10

Table 2-5. Number of reported strikes, strikes with damage, and strikes having a 

negative effect-on-flight (EOF) for the five most commonly struck bird 

species groups and two most commonly struck mammal groups, USA, 

1990–2003.................................................................................................11

Table 2-6. Number of reported bird and mammal strikes to civil aircraft by month, 

USA, 1990–20031. ...................................................................................12

Table 2-7. Reported time of occurrence of wildlife strikes to civil aircraft, USA, 

1990–2003.................................................................................................12

Table 2-8. Reported phase of flight at time of wildlife strikes to civil aircraft, USA, 

1990–2003.................................................................................................13

Table 2-9. Number of reported bird strikes to civil aircraft by height (feet) above 

ground level (AGL), USA, 1990–2003........................................................14

Table 2-10. Civil aircraft components reported as being struck and damaged by 

wildlife, USA, 1990–2003...........................................................................15

Table 2-11. Number of civil aircraft with reported damage resulting from wildlife 

strikes, USA, 1990–2003. ..........................................................................16

Table 2-12. Reported effect-on-flight (EOF) of wildlife strikes to civil aircraft, USA, 

1990–2003.................................................................................................16

Table 6-1. Airport Wildlife Hazard Review Worksheet. ...............................................75

Table 7-1. Example of a daily log of wildlife control activities. ....................................91

Table 7-2. Example of a Wildlife Strike Log for recording bird or other wildlife 

remains found within 200 feet of runway centerline that, in the judgment 

of wildlife control personnel, were killed as a result of interacting with an 

aircraft........................................................................................................93

Table 7-3. Example of a form to provide monthly summary of wildlife control 

activities.....................................................................................................95

Table 7-4. Example of a form to provide annual summary of wildlife control activities 

derived from monthly reports (Table 7-3). Modify each airport’s form to 

reflect the common control activities undertaken during the year. The 

data may also be presented graphically.....................................................97

Table 8-1. Ranking of 25 species groups as to relative hazard to aircraft (1=most 

hazardous) based on three criteria (damage, major damage, and effect-
Table of Contents List of Tables ix 

on-flight), a composite ranking based on all three rankings, and a relative 

hazard score. Data were derived from the FAA National Wildlife Strike 

Database, January 1990–April 20031......................................................101
x Table of Contents 

LIST OF FIGURES 

Figure 2-1. Number of reported bird (N = 51,154) and mammal (N = 1,272) strikes 

to civil aircraft, USA, 1990–2003. An additional 67 strikes involving 

reptiles were also reported for this 14-year period. ...................................8 

Figure 5-1. Separation distances within which hazardous wildlife attractants should 

be avoided, eliminated, or mitigated.........................................................46 
Table of Contents xi 

LIST OF APPENDICES 

APPENDIX A: Names, Addresses, and Phone Numbers: .........................................153

Federal Aviation Administration.......................................................................155

FAA National Headquarters ..................................................................155

FAA Alaska Region Headquarters ........................................................155

FAA Central Region Headquarters .......................................................156

FAA Eastern Region Headquarters ......................................................156

FAA Great Lakes Region Headquarters ...............................................157

FAA New England Regional Headquarters...........................................157

FAA Northwest Mountain Region Headquarters ...................................158

FAA Southern Region Headquarters ....................................................158

FAA Southwest Region Headquarters ..................................................159

FAA Western Pacific Region Headquarters ..........................................159

USDA APHIS Wildlife Services........................................................................161

Headquarters ........................................................................................161

Operational Support Staff .....................................................................161

Eastern Region .....................................................................................161

Western Region ....................................................................................163

National Wildlife Research Center........................................................165

NWRC Field Stations............................................................................165

APPENDIX B: Animal Damage Control Act, 2 March 1931, as amended..................167

APPENDIX C: FAA Advisory Circulars ......................................................................171

AC 150/5200-32A Reporting Wildlife Aircraft Strikes.......................................173

AC 150/5200-33A Hazardous Wildlife Attractants On Or Near Airports ..........179

AC 150/5200-34 Construction or Establishment of Landfills Near Public 

Airports ...............................................................................................203

AC 150/5300-13 Airport Design. Appendix 19. Minimum Distances Between 

Certain Airport Features And Any On-Airport Agriculture Crops.........211

APPENDIX D: FAA, Office Of Airport Safety And Standards, Program Policies And 

Guidance — Airport Certification Program – 14 CFR 139........................213

Policy No. 77: Initiation of Wildlife Hazard Assessments at Airports................215

Airport Certification Program – 14 CFR 139 Program Policy And 

Guidance.................................................................................217

Policy No. 78: Section 7 Consultation on Endangered or Threatened 

Species...............................................................................................217

Airport Certification Program - 14 CFR 139 Program Policy And 

Guidance.................................................................................221

Policy No. 79: Review of Airport Wildlife Hazard Management Plans .............221

Policy No. 82 Waste Disposal Facility Coordination ........................................225
xii List of Appendicies Table of Contents 

APPENDIX E: FAA, Office Of Airport Safety And Standards, Certalerts ...................229

No. 98-05: Grasses Attractive To Hazardous Wildlife......................................231

No. 04-09: Relationship Between FAA And WS ..............................................233

No. 04-16: Deer Hazard to Aircraft and Deer Fencing.....................................237

APPENDIX F: USDA, Wildlife Services Directive 2.305 Wildlife Hazards To Aviation 

.................................................................................................................239

APPENDIX G: Memorandum Of Understanding Between United States Department 

Of Transportation, Federal Aviation Administration And United States 

Department Of Agriculture, Animal And Plant Health Inspection Service, 

Wildlife Services. (No. 12-34-71-0003-MOU)...........................................243

APPENDIX H: Memorandum of Agreement Between the Federal Aviation 

Administration, the U.S. Air Force, the U.S. Army, the U.S. 

Environmental Protection Agency, the U.S. Fish and Wildlife Service, 

and the U.S. Department of Agriculture to Address Aircraft-Wildlife 

Strikes......................................................................................................249

APPENDIX I: FAA Form 5200-7 Bird/Other Wildlife Strike Report ............................265

APPENDIX J: Gull Facts For Airport Wildlife Control Personnel................................271

APPENDIX K: Assessing Wildlife Hazard Management Plans At Civil Airports.........275

APPENDIX L: Aviary And Field Evaluations Of Various Wildlife Control Products 

And Strategies For Airports......................................................................293

APPENDIX M: A Wetland Banking Mitigation Strategy For FAA ...............................315

APPENDIX N: Liability Issues For Airport Managers Related To Wildlife Hazards...327

APPENDIX O: Summary of Studies on Vegetation Management for North American 

Airfields ....................................................................................................335

Appendix P: Title 14, Code of Federal Regulations, Part 139.337.............................343
 1 

CHAPTER 1: 

INTRODUCTION TO THE WILDLIFE STRIKE PROBLEM 

Birds and aircraft are increasingly competing for airspace in crowded skies, as demonstrated over the

threshold of runway 31R at Ferihegy Airport, Budapest, Hungary, 15 June 2004 (photo © Adam Samu,

used with permission). 

Throughout history, humans have been intrigued and inspired by the beauty of birds 

and their ability to fly. Birds first took to the air about 150 million years ago. Humans 

first began to share their airspace only 100 years ago. Unfortunately, when aircraft and 

birds attempt to use the same airspace at the same time, collisions occur. 

Birds are not the only wildlife problem for aircraft. Deer, coyotes, and even alligators 

wandering onto runways can create serious problems for departing and landing aircraft. 

Aircraft collisions with wildlife, also commonly referred to as wildlife strikes, annually 

cost the civil aviation industry in the USA at least $500 million in direct damage and 

associated costs and over 500,000 hours of aircraft down time. Although the economic 

costs of wildlife strikes are extreme, the cost in human lives lost when aircraft crash as a 

result of strikes best illustrates the need for management of the wildlife strike problem. 

This manual is designed to inform airport personnel about the scope of the wildlife strike 

problem and to serve as a ready reference on legal authority, regulations, and the 

development, implementation, and evaluation of Wildlife Hazard Management Plans for 

airports. 
 Introduction 2 Chapter 1 

The first powered flight by the 

Wright Brothers occurred in 

December 1903, and the wildlife 

strike problem began shortly 

thereafter. On 7 September 1905, 

the first reported bird strike, as 

recorded by Oliver Wright in his 

diary, occurred when his aircraft hit 

a bird (probably a red-winged 

blackbird) as he flew over a 

cornfield near Dayton Ohio. The 

first reported mammal strike 

occurred on 25 July 1909 at the 

start of Louis Bleriot's historic first 

flight across the English Channel 

from Les Baraques, France. 

During engine warm-up of his 

Bleriot XI aircraft, a farm dog ran 

into the propeller. On 3 April 1912 

Calbraith Rodgers, the first person to fly across the continental USA, was also the first 

to die as a result of a wildlife strike when his aircraft struck a gull along the coast of 

Southern California. Since those first wildlife strikes, aircraft designs and performance 

have changed radically, and wildlife populations and air traffic have increased. As a 

result, at least 122 civil aircraft have been destroyed and over 255 civilian lives have 

been lost worldwide due to wildlife strikes from 1960 to 2004. During this same period, 

wildlife strikes have resulted in at least 333 military aircraft destroyed and over 150 

military personnel killed. 

Oliver Wright recorded the first bird strike in 1905 in Ohio,

less than 2 years after the Wright Brothers’ first powered

flight. 

The onset of the jet age revolutionized air travel, but magnified the wildlife strike 

problem. Early piston-powered aircraft were noisy and relatively slow. Wildlife could 

usually avoid these aircraft, and strikes that did occur typically resulted in little or no 

damage. However, modern jet aircraft are fast and relatively quiet, and their engine fan 

blades are often more vulnerable than propellers to wildlife-strike damage. When 

turbine-powered aircraft collide with birds or other wildlife, serious structural damage 

and engine failure can occur. Multiple-engine damage from the ingestion of flocks of 

birds is of particular concern as the fleet of two-engine passenger aircraft increases in 

the USA. In 1969, 75% of the 2,100 passenger aircraft had 3 or 4 engines. In 1998, the 

fleet had grown to 5,400 primarily turbine-powered aircraft, of which only 30% had three 

or four engines. By 2008, the fleet will consist of about 7,000 aircraft, and less than 

10% will have three or four engines. 

Air travel has become commonplace in the USA. Aircraft have also assumed a vital role 

in tactical and logistical military operations. These factors have resulted in increased air 

traffic. For example, commercial air movements in the USA increased about 3% per 

year between 1985 and 2004. Coincidentally, human use of the skies has increased 

during an extremely successful period of wildlife management in North America. 

Aggressive natural resource and environmental protection programs by public and 

private wildlife management groups have contributed to impressive increases in 
Chapter 1 Introduction 3 

populations of many large-bodied species such as alligators, cormorants, cranes, deer, 

geese, gulls, herons, pelicans, raptors (falcons, hawks, eagles, and owls), vultures, and 

wild turkeys. At the same time, many of these species (e.g., Canada geese, coyotes, 

deer, and turkeys), have expanded into suburban and urban areas, including airports, 

and are thriving in response to protection and changes to habitats in these areas. 

Almost all of these species have body masses over 4 pounds (1.8 kg), which exceed 

the airframe and engine certification standards for wildlife strikes. These concurrent 

increases in air traffic and wildlife populations contribute to an increased probability of 

damaging wildlife strikes. These two factors, combined with the increased speed, 

quietness, and vulnerability of modern aircraft, interact to form the basis of the wildlife 

strike problem that airport managers 

face. As a final factor, airport 

managers also face increased 

concerns about airport liability in the 

aftermath of damaging wildlife strikes 

(see Appendix N). 

Wildlife strike problems at individual 

airports result from these abovedescribed factors interacting at the 

local level. The nature and magnitude 

of the problem an individual airport 

faces will depend on many factors, 

including air traffic type and volume, 

local and migratory wildlife populations, 

and local wildlife habitat conditions. 

Wildlife is attracted to an airport 

environment because desirable food, 

water, or habitat is present. The 

majority of wildlife strikes occur within 

the immediate airport environment: 

74% of all strikes occur at or below 500 feet above ground level (AGL). Eighteen of the 

19 civil and military large-transport aircraft destroyed because of bird strikes between 

1960 and 2004 resulted from strikes that occurred on the airport. Therefore, most 

wildlife involved in strikes is using the airport or its immediate vicinity, and the most 

logical place to begin correcting the problem is on and near the airport. 

The resident Canada goose population in the USA

increased at an annual rate of 8% per year between

1980 and 2004. Notice that the tall grass does not

deter Canada geese from grazing and loafing at the

airport (photo by M. Begier, USDA). 

Airport sponsors and managers have a legal responsibility under federal regulations 

(Title 14 Code of Federal Regulations, part 139 [14 CFR, part 139]) to ensure the airport 

maintains a safe operating environment. As part of this responsibility, they must assess 

the risk and magnitude of the wildlife strike problem for their airport (14 CFR, part 

139.337). This assessment must include accurate and complete reporting of all strike 

incidents, assessment of wildlife using the airport environment, and assessment of 

wildlife habitat available to wildlife on the airport. Based on airport conditions and 

assessed strike risk, airport personnel might need to devise a Wildlife Hazard 

Management Plan for reducing strike risk and occurrence. Airport personnel must then 

act to implement and periodically evaluate the plan. 
 Introduction 4 Chapter 1 

This manual contains a compilation of information to assist airport personnel in 

conducting Wildlife Hazard 

Assessments and in the development, 

implementation, and evaluation of 

Wildlife Hazard Management Plans. 

This manual includes specific 

information on the nature of wildlife 

strikes, legal authority, government 

agency roles and responsibilities, 

regulations, wildlife management 

techniques, Wildlife Hazard 

Assessments, Wildlife Hazard 

Management Plans, and sources of 

help and information. It is emphasized 

that this manual provides only a 

starting point for addressing wildlife 

hazard issues on airports. Wildlife 

management is a complex, evolving, 

and public-sensitive discipline, and ecological conditions vary widely across the USA. 

Therefore, the assessment of wildlife hazards, the development of Wildlife Hazard 

Management Plans, and the implementation of management actions by airport 

personnel must be under consultation by qualified wildlife biologists trained in wildlife 

damage control. 

While on approach to a southern USA airport in 

March 2003, this PA-34 aircraft struck a pair of redbreasted mergansers at 800 feet AGL. The birds 

penetrated both windshields. The pilot was not hurt.
 5 

CHAPTER 2: 

THE FAA NATIONAL WILDLIFE STRIKE DATABASE 

FOR CIVIL AVIATION 

Each autumn, clouds of greater snow geese arrive at Chincoteague National Wildlife Refuge,

Virginia, and elsewhere along the Atlantic coast of USA from their Arctic breeding grounds in Canada

and Greenland. The greater snow goose population increased from about 50,000 birds in 1966 to

over 700,000 birds in 2004 (photo © Brian Kennedy/briankennedy.net, used with permission). 

2.1 INTRODUCTION

Before a problem can be solved, the problem must first be understood. A necessary 

first step toward understanding the complex problem of aircraft collisions with wildlife is 

the collection and analysis of data from actual wildlife strike events. This chapter 

provides an overview of the structure and management of the Federal Aviation 

Administration (FAA) National Wildlife Strike Database for Civil Aviation. The chapter 

emphasizes the need for accurate reporting of wildlife strikes and the methods for 

reporting strike events. A statistical summary of reported wildlife strikes for civil aircraft 

(1990—2003) is also presented to demonstrate the types of information obtained from 

the database. Finally, a list of selected individual strike cases provides an overview of 

the nature and magnitude of the wildlife strike problem in the USA. 

.
6 Wildlife Strike Database Chapter 2 

2.2 REPORTING WILDLIFE STRIKES

The FAA has a standard form (Form 5200-7, Bird/Other Wildlife Strike Report [see 

Appendix I]) for the voluntary reporting of bird and other wildlife strikes with aircraft. To 

improve the ease of reporting, strikes can also be reported via the Internet 

(http://wildlife-mitigation.tc.faa.gov). 

Pilots, airport operations, aircraft maintenance personnel, or anyone else who has 

knowledge of a strike should report strikes. It is important to include as much 

information as possible on Form 5200-7. The identification of the species of wildlife 

struck is particularly important. Bird strike remains that cannot be identified by airport 

personnel can often be identified by a local biologist or, by sending feather remains 

(with Form 5200-7) to— 

For Material Sent via Express Mail Service: For Material Sent via U.S. Postal Service: 

Feather Laboratory Feather Laboratory 

Smithsonian Institution Smithsonian Institution, Div. of Birds 

NHB, E610, MRC 116 PO Box 37012 

10th & Constitution Ave. NW NHB, E610, MRC 116 

Washington DC 20560-0116 Washington DC 20013-7012 

(Identify as “safety investigation material”) (Not recommended for priority cases) 

The Smithsonian does not charge for feather identification services when the feathers are 

accompanied by an FAA Bird/Other Wildlife Strike Report (FAA Form 5200-7). Please send 

whole feathers if available, as diagnostic characteristics are often found in downy barbules at 

feather base. If available, include wings, breast, and tail feathers. Beaks, feet, bones, and 

talons are also useful diagnostic materials. Do not send entire bird carcasses through the 

mail. 

Chapter 7 and Appendix I provide more details on strike reporting. 

Analyses of wildlife strike data have proven invaluable in determining the magnitude, 

nature, and severity of the wildlife strike problem. The database provides a scientific 

basis for identifying risk factors; justifying, implementing, and defending corrective 

actions at airports; and judging the effectiveness of those corrective actions. The 

database is also of critical value to engine manufacturers and aeronautical engineers. 

2.3 MANAGEMENT OF THE DATABASE

The FAA National Wildlife Strike Database is managed by the Wildlife Services 

program of the U.S. Department of Agriculture (USDA) under terms of an Interagency 

Agreement with the FAA. All strike reports are sent to Wildlife Services for entry into 

the database after review by the staff Wildlife Biologist at the FAA, Office of Airport 

Safety and Standards. At the Wildlife Services office, a database manager edits each 

strike report and consolidates multiple reports for the same strike before entering the 

data. 
Chapter 2 Wildlife Strike Database 7 

Contacts with persons making reports are sometimes made for clarification of details. 

In addition to FAA Form 5200-7, strike reports are also obtained from other sources 

(Table 2-1). After entry into 

the database, the original 

reports are filed 

chronologically for future 

reference if necessary. 

There are approximately 

52,500 strike records for civil 

aircraft in the database for 

1990 through 2003. 

In addition to the civil aviation 

strike reports, strike reports 

for military aircraft in the U.S. 

Air Force (USAF) database 

(where the strike occurred at 

joint use civil/military airports) 

have been merged into the 

FAA database (approximately 

6,000 from 1990 to 2003). 

Civil and military strikes are 

labeled so analyses can be 

done with data combined or 

separated. 

2.4 USE OF AND 

ACCESS TO INFORMATION 

IN THE DATABASE 

Maintaining a consistent 

record of wildlife strikes at an 

airport is essential for defining the wildlife hazard level and for evaluating the airport’s 

Wildlife Hazard Management Plan, as discussed in Chapter 7. In addition to their 

internal use at the airport, the strike reports, when incorporated into the National Wildlife 

Strike Database, provide a means for engineers, biologists, and safety analysts to better 

understand national and regional trends in strikes and thereby develop, justify, and 

defend more effective management programs and wildlife-resistant aircraft and engines. 

For example, the database has been extremely useful in identifying which wildlife 

species are most commonly involved in strikes, the seasonal pattern of strikes for 

various species, the extent and types of damage resulting from strikes, and which 

aircraft types and components are most vulnerable. It is emphasized that for annual 

reports and other publicly released analyses, the strike records in the national database 

are summarized statistically at the regional or national level for trends. Comparisons 

among individual airports, commercial air carriers, or engine manufacturers are not 

made. 

Table 2-1. Source of information for reported wildlife strikes to 

civil aircraft, USA, 1990–2003. 

Source 

14-year 

total 

% of total

 known 

FAA Form 5200-71 (Paper) 31,497 60 

FAA Form 5200-7E (Electronic)2 2,948 6

Airline report 7,003 13 

Multiple3 4,704 9

Airport report 2,861 5 

Other4 1,059 2

Engine manufacturer 793 2 

Aircraft Incident Report 720 1 

Preliminary Aircraft Incident Report 628 1 

Aviation Safety Reporting System 152 <1 

Aircraft Incident Preliminary Notice 60 <1 

National Transportation Safety Board 57 <1 

U.S. Air Force BASH program 11 <1

Total 52,493 100

1 Bird/Other Wildlife Strike Report. 

2 Electronic filing of reports (http://wildlife-mitigation.tc.faa.gov) 

began in April 2001. In 2001, <1% of reports were filed 

electronically compared to 21% in 2002 and 29% in 2003. 

3 More than one report was filed for the same strike. 

4 Various sources, such as news media and Commercial Incident 

Reports. 
8 Wildlife Strike Database Chapter 2 

Selected strike records and data fields are available to the public and aviation industry 

online at http://wildlife-mitigation.tc.faa.gov. The general public can access information 

on the number of strikes by year, state, and species of wildlife. Engine manufacturers, 

commercial airlines, and airports, with a password supplied by the FAA, can access 

strike reports involving their company or airport. USDA Wildlife Services biologists and 

FAA Airport Certification Safety Inspectors can access strike reports for airports in the 

state or region, respectively, where they work. 

0

1000

2000

3000

4000

5000

6000

7000

19901991199219931994199519961997199819992000200120022003

N

o. of r

eporte

d strik

e

s

Mammals

Birds

Figure 2-1. Number of reported bird (N = 51,154) and mammal (N = 1,272) strikes to civil aircraft, 

USA, 1990–2003. An additional 67 strikes involving reptiles were also reported for 

this 14-year period. 

2.5 SUMMARY OF WILDLIFE STRIKE RECORDS, 1990–2003 

The FAA's Office of Airport Safety and Standards, in cooperation with USDA Wildlife 

Services, publishes an annual report, Wildlife Strikes to Civil Aircraft in the United 

States. This report contains a detailed analysis of strike data from 1990 to the most 

recent year. Copies of the annual report can be downloaded from the FAA's Wildlife 

Hazard Mitigation Website at http://wildlife-mitigation.tc.faa.gov. 
Chapter 2 Wildlife Strike Database 9 

The following section presents a summary 

analysis of reported wildlife strikes to civil 

aircraft in the USA for 1990 through 2003 to 

provide an overview of the types of information 

obtained from the database. Reports were 

received from 1,212 airports encompassing all 

50 states and some U.S. territories and from 

170 foreign airports when U.S. registered 

aircraft were involved in a strike. Because less 

than 20% of all strikes have been reported to 

the FAA and many reports received by the 

FAA did not include cost or damage data or 

were filed before aircraft damage was fully 

assessed, the number of strikes and 

associated cost data compiled from the 

voluntary reporting program greatly 

underestimate the magnitude of the problem. 

2.5.A STRIKE FREQUENCY 

For the 14-year period (1990–2003), 52,493 

strikes were reported to the FAA. Birds were 

involved in 97.4% of the reported strikes, mammals in 2.4%, and reptiles in less than 

0.2% (Figure 2-1). 

Table 2-2. Person filing report of wildlife 

strike to civil aircraft, USA, 

1990–2003. 

Person filing 

report 

14-year 

 total 

% of total 

known 

Airline operations 11,313 28 

Pilot 10,762 27

Tower 6,672 17

Carcass found1 5,809 15

Airport operations 3,971 10 

Other 1,520 4

Total known 40,047 100 

Unknown 12,446 

Total 52,493

1 Airport operations personnel found wildlife 

remains within 200 feet of a runway 

centerline that appeared to have been struck 

by aircraft and no strike was reported by 

pilot, tower, or airline. 

The number of strikes annually reported tripled from 1990 (1,739) to 2000 (5,979). 

From 2000 to 2003, reported strikes 

plateaued at about 6,000 per year with 

5,940 strikes reported in 2003 (Figure 2-1). 

We suggest that the steady increase in 

reports for 1990 to 2000 was the result of 

several factors: an increased awareness of 

the wildlife strike issue, an increase in 

aircraft operations, an increase in 

populations of hazardous wildlife species, 

and an increase in the number of strikes. 

The plateau in reported strikes from 2000 to 

2003 might be related to a slight (<6%) 

decline in air traffic after the events of 

September 2001 and to more aggressive 

wildlife hazard management programs at 

airports. 

Table 2-3. Number of reported wildlife strikes to 

civil aircraft by type of operator, 

USA, 1990–2003. 

Type of operator 

14-year 

total 

% of total 

known 

Commercial 38,005 84

Business 5,596 12

Private 1,567 4

Government/Police 266 <1

Total known 45,434 100 

Unknown 7,059

Total 52,493

Most (66%) of the 52,493 strike reports filed during the 14-year period were submitted 

using the paper (60%) or electronic (6%) version of FAA Form 5200-7, Bird/Other 

Wildlife Strike Report. Since the online version of this form became available in April 

2001, use of the electronic reporting system has climbed dramatically. Almost 28% of 

the strike reports filed in 2003 were done using this system (Table 2-1). 
10 Wildlife Strike Database Chapter 2 

Table 2-4. Number of reported bird, mammal, and reptile strikes to civil aircraft by USA state, including 

the District of Columbia (DC), Puerto Rico (PR), USA-possessed Pacific Islands (PI), and the 

U.S. Virgin Islands (VI), 1990–2003. 

Reported strikes Reported strikes

State Birds Mammals Reptiles Total State Birds Mammals Reptiles Total

AK 393 14 0 407 NC 997 20 0 1,017

AL 489 12 0 501 ND 121 3 0 124

AR 222 13 0 235 NE 461 13 0 474

AZ 712 51 0 763 NH 297 10 0 307

CA 4,325 54 0 4,379 NJ 1,427 67 7 1,501

CO 1,290 59 0 1,349 NM 94 2 0 96

CT 561 16 0 577 NV 248 3 0 251

DC 1,307 30 0 1,337 NY 2,903 96 10 3,009

DE 36 1 0 37 OH 1,626 53 0 1,679

FL 3,622 49 40 3,711 OK 470 19 2 491

GA 866 15 0 881 OR 810 8 0 818

HI 1,047 4 0 1,051 PA 1,962 63 0 2,025

IA 335 12 0 347 PI 80 0 0 80

ID 102 5 0 107 PR 85 0 5 90

IL 2,521 71 1 2,593 RI 209 7 0 216

IN 527 11 0 538 SC 248 12 0 260

KS 148 5 0 153 SD 82 6 0 88

KY 1,203 12 0 1,215 TN 1,328 15 0 1,343

LA 949 18 1 968 TX 3,416 60 0 3,476

MA 684 12 0 696 UT 535 10 0 545

MD 556 40 0 596 VA 735 42 0 777

ME 157 8 0 165 VI 67 0 0 67

MI 1,248 70 0 1,318 VT 41 1 0 42

MN 435 13 0 448 WA 785 11 0 796

MO 1,040 26 0 1,066 WI 437 43 0 480

MS 171 4 0 175 WV 123 45 0 168

MT 61 5 0 66 WY 39 4 0 43

Total known1 44,633 1,243 66 45,942

Foreign2 983 8 0 991

Unknown 5,538 21 1 5,560

Total 51,154 1,272 67 52,493

1 Strikes were reported at 1,212 airports in the USA. 

2 Strikes to USA air carriers were reported at 170 foreign airports. 
Chapter 2 Wildlife Strike Database 11 

Table 2-5. Number of reported strikes, strikes with damage, and strikes having a negative effect-onflight (EOF) for the five most commonly struck bird species groups and two most commonly 

struck mammal groups, USA, 1990–2003. 

Reported strikes Strikes with damage Strikes with EOF 

Species group 

14-year 

total 

% of 

 total 

known 

14-year 

 total 

% of 

 total 

known 

14-year 

 total 

% of 

 total 

known 

Birds 

Gulls 5,323 25 891 28 710 30 

Doves/pigeons 2,966 14 245 8 264 11 

Raptors 2,666 12 537 17 351 15 

Waterfowl 2,217 10 1,023 32 477 20 

Blackbirds/starlings 2,210 10 131 4 156 7 

All other known 6,302 29 390 12 406 17 

Total known 21,684 100 3,217 100 2,364 100 

Unknown 29,470 3,483 1,952 

Total birds 51,154 6,700 4,316 

Mammals

Artiodactyls1 643 51 524 94 339 85 

Carnivores2 312 25 23 4 48 12 

All other known 305 24 11 2 10 3 

Total known 1,260 100 558 100 397 100 

Unknown 12 6 6 

Total mammals 1,272 564 403 

1

 Deer and elk, respectively, comprised 614 and 8 of the 643 strikes with artiodactyls. 

2 Coyotes and foxes, respectively, comprised 150 and 59 of the 312 strikes with carnivores. 

Pilots and airline personnel filed 28% and 27% of these 52,493 reports, respectively 

(Table 2-2). About 84% of the reported strikes involved commercial aircraft; the 

remainder involved business, private, and miscellaneous aircraft (Table 2-3). California, 

Florida, and Texas had the most (3,416–4,325) bird strike reports (Table 2-4). Twelve 

other states each had over 1,000 bird strikes reported. New York, Illinois, Michigan, 

New Jersey, Pennsylvania, and Texas each had 60 or more mammal strikes. 
12 Wildlife Strike Database Chapter 2 

Table 2-6. Number of reported bird and mammal strikes to civil aircraft by month, USA,

 1990–20031

. 

All birds All mammals Deer only2

Month 

14-year 

total 

% of total 

known

14-year 

total 

% of total 

known

14-year 

total 

% of total

known 

Jan 1,969 4 60 5 27 4

Feb 1,806 4 50 4 21 3

Mar 2,712 5 73 6 31 5

Apr 3,537 7 83 7 40 7

May 4,729 9 65 5 27 4

Jun 3,806 7 102 8 45 7

Jul 5,678 11 127 10 50 8

Aug 6,845 13 154 12 50 8

Sep 6,919 14 150 12 64 10

Oct 6,685 13 171 13 85 14

Nov 4,100 8 168 13 126 21

Dec 2,368 5 69 5 48 8

Total 51,154 100 1,272 100 614 100

1 In addition, 67 strikes with reptiles were reported, of which 16 (24%) occurred in September. 

2 Deer strikes were comprised of 574 white-tailed deer, 24 mule deer, and 16 deer not 

identified to species. Other wild ungulates reported struck (but not included in this column of 

table) were 8 elk, 7 pronghorns, 7 moose, and 1 caribou. 

Table 2-7. Reported time of occurrence of wildlife strikes to civil aircraft, USA, 

 1990–2003. 

Birds Mammals

Time of day 

14-year 

total 

% of total 

known

14-year 

total 

% of total 

known 

Dawn 1,567 4 23 3

Day 22,632 63 200 24

Dusk 1,922 5 81 10

Night 9,562 27 536 64

Total known 35,683 100 840 100 

Unknown 15,471 432

Total1 51,154 1,272

1 In addition, 67 strikes with reptiles were reported: 56 for which the time was not 

reported, 6 during the day, 3 at night, 1 at dawn, and 1 at dusk. 
Chapter 2 Wildlife Strike Database 13 

2.5.B TYPES OF WILDLIFE INVOLVED

Gulls (25%), doves (14%), raptors (12%), and waterfowl (10%) were the most frequently 

struck bird groups (Table 2-5). Gulls were involved in more than twice as many strikes 

as waterfowl (5,323 and 2,217, respectively). Waterfowl, however, were involved in 

more damaging strikes (1,023 or 32% of all damaging strikes in which the bird type was 

identified) than were gulls (891 or 28% of all damaging strikes in which the bird type 

was identified). Gulls were responsible for the greatest number of bird strikes (710 or 

30%) that had a negative effect-on-flight. 

The most frequently struck mammals were Artiodactyls—primarily deer (51%)—and 

Carnivores—primarily coyotes (25%, Table 2-5). Artiodactyls were responsible for 94% 

of the mammal strikes that resulted in damage and 85% of the mammal strikes that had 

a negative effect-on-flight. In all, 38 identified species of mammals were reported 

struck; 17 identified species caused damage. 

2.5.C CHARACTERISTICS OF STRIKES

Most bird strikes (51%)

occurred between July and 

October (Table 2-6); 63% 

occurred during the day (Table 

2-7); 58% occurred during the 

landing (descent, approach, or 

landing roll) phase of flight; and 

39% occurred during takeoff 

and climb (Table 2-8). About 

61% of the bird strikes occurred 

when the aircraft was at a 

height of 100 feet or less above 

ground level (AGL), 74% 

occurred at 500 feet or less 

AGL, and 92% occurred at or 

below 3,000 feet AGL (Table 2-

9). 

Most mammal strikes (50%) 

occurred between August and 

November with 35% of deer 

strikes concentrated in October and November (Table 2-6). Most mammal strikes 

(64%) occurred at night (Table 2-7), 52% occurred during the landing roll, and 33% 

occurred during the takeoff run. About 10% of the reported mammal strikes occurred 

while the aircraft was in the air, e.g., when the aircraft struck deer with the landing gear 

or encountered bats (Table 2-8). 

Table 2-8. Reported phase of flight at time of wildlife strikes to 

civil aircraft, USA, 1990–2003. 

Birds Mammals 

Phase of flight 

14-year

total 

% of total 

known 

14-year 

total 

% of total 

known 

Parked 24 <1 0 0

Taxi 161 <1 24 3

Takeoff run 7,810 20 318 33

Climb 7,327 19 26 2

En route 1,148 3 1 <1 

Descent 1,463 4 4 <1

Approach 15,065 38 82 8

Landing roll 6,461 16 498 52

Total known 39,459 100 953 100 

Unknown 11,695 319 

Total1 51,154 1,272 

1 In addition, 67 strikes with reptiles were reported.

2.5.D AIRCRAFT COMPONENTS STRUCK AND DAMAGED

The aircraft components most commonly reported as struck by birds were the 

nose/radome, windshield, engine, wing/rotor, and fuselage (Table 2-10). Aircraft 
14 Wildlife Strike Database Chapter 2 

engines were the component most frequently reported as being damaged by bird strikes 

(33% of all damaged components). Of the 7,511 aircraft engines reported as being 

struck by birds, 34% (2,591) were damaged (Table 2-10). 

There were 6,761, 350, 10, and 5 incidents in which one, two, three, and four engines, 

respectively, were struck by birds on a single aircraft. There were 2,424, 80, 1, and 1 

incidents in which one, two, three, and four engines, respectively, were damaged by 

birds on a single aircraft. 

Aircraft components most 

commonly reported as struck by 

mammals were the landing gear, 

propeller, and wing/rotor. These 

same components ranked highest 

for the parts most often reported 

as damaged by mammals (Table 

2-10). 

2.5.E EFFECTS OF WILDLIFE 

STRIKES ON AIRCRAFT AND 

FLIGHTS

For the 14-year period, 7,265 

reports (17% of known total) 

indicated the strike damaged one 

or more aircraft components 

(Table 2-9), and 4,726 reports 

(15% of known total) indicated the 

strike had a negative effect on the 

flight (Table 2-11). Only 2,630 

strike reports provided an 

estimate of the aircraft down time 

(total = 455,931 hours, average = 

173 hours/incident), and 1,759 

reports provided an estimate of 

the direct or other costs (total 

= $195,034,000, average = 

$147,000/incident). Of the 1,759 

reports providing a damage cost 

estimate, 1,637 provided an 

estimate of direct aircraft damage 

(total = $169,045,000, average = $103,000/incident), and 595 provided an estimate of 

other monetary losses (total = $25,989,000, average = $44,000/incident). 

Table 2-9. Number of reported bird strikes to civil aircraft by 

height (feet) above ground level (AGL), USA, 

1990–2003. 

Height of strike 

(feet AGL) 

14-year 

total 

% of total 

 known 

% cumulative

total 

0 14,471 41 41

1-100 6,716 19 61

101-200 1,704 5 65

201-300 1,126 3 69

301-400 682 2 71

401-500 1,204 3 74

501-600 333 1 75

601-700 262 1 76

701-800 561 2 77

801-900 186 1 78

901-1,000 1,002 3 81

1,001-2,000 2,570 7 88

2,001-3,000 1,517 4 92

3,001-4,000 776 2 95

4,001-5,000 575 2 96

5,001-10,000 1,062 3 99

10,001-20,000 237 <1 99

20,001-30,000 11 <1 99

>30,000 1 <1 100

Total known 34,996 100 

Unknown 16,158

Total 51,154

Assuming all reported wildlife-aircraft strikes that had an adverse effect on the aircraft 

and/or flight engendered similar amounts of down time and/or monetary losses and that 

these reports are all of the damaging strikes that occurred, wildlife strikes cost the U.S. 

civil aviation industry a minimum of 118,663 hours per year of aircraft down time and 
Chapter 2 Wildlife Strike Database 15 

$100.58 million in monetary losses ($70.68 million per year in direct costs and $29.90 

million per year in associated costs). Further, assuming a 20% reporting rate, the 

annual cost of wildlife-aircraft strikes to the U.S. civil aviation industry is estimated to be 

in excess of 593,317 hours of aircraft downtime and $502.91 million in monetary losses 

($353.42 million per year in direct costs and $149.49 million per year in associated 

costs). 

Table 2-10. Civil aircraft components reported as being struck and damaged by wildlife, USA, 

1990–2003. 

Birds (14-year total) Mammals (14-year total) 

Aircraft 

component 

Number 

struck 

% of 

total

Number 

damaged

% of 

total

Number 

struck 

% of

total

Number 

damaged 

% of

total 

Radome/nose 12,044 26 1,201 15 69 6 65 6

Windshield 8,145 18 482 6 16 1 11 1

Engine(s) 7,5111 16 2,5911 33 98 8 95 9

Wing/rotor 6,243 14 1,751 22 144 12 141 14

Fuselage 5,726 12 275 3 82 7 91 9

Landing gear 2,252 5 249 3 452 37 239 24

Propeller 1,415 3 153 2 169 14 157 15

Tail 693 2 305 4 37 3 45 4

Light 386 1 305 4 15 1 22 2

Other 1,675 4 631 8 146 12 148 14

Total2 46,090 100 7,943 100 1,228 100 1,014 100

1 There were 7,126 bird-strike incidents in which a total of 7,511 engines were reported as struck 

(6,761 incidents with one engine struck, 350 with two engines struck, 10 with three engines struck, 

and five with four engines struck). In 2,506 (35%) of these 7,126 strike incidents, a total of 2,591 

engines were damaged (2,424 incidents with one engine damaged, 80 with two engines damaged, 

one with three engines damaged, and one with four engines damaged). 

2 In addition, 67 strikes with reptiles were reported; 15 indicated the part struck and 5 indicated the 

strike damaged an aircraft component: Windshield (1 struck, 1 damaged), Wing/rotor (1 struck, 1 

damaged), Fuselage (1 struck, 1 damaged), Landing gear (10 struck, 0 damaged), Tail (1 struck, 1 

damaged), Other (1 struck, 1 damaged). 
16 Wildlife Strike Database Chapter 2 

Table 2-11. Number of civil aircraft with reported damage resulting from wildlife strikes, USA, 1990–2003. 

Reported strikes

Birds Mammals Total1

Damage category 2 14-year total 

% of total 

known 14-year total

% of total 

known 14-year total

% of total 

known 

None 36,122 84 348 38 36,481 83

Damage 6,700 16 564 62 7,265 17

Minor 3,659 9 262 29 3,921 9

Uncertain 1,184 3 39 4 1,223 3

Substantial 1,845 4 247 27 2,093 5

Destroyed 12 <1 16 2 28 <1

Total known 42,822 100 912 100 43,746 100

Unknown 8,332 360 8,747

Total 51,154 1,272 52,493

1 Included in totals are 67 strikes involving reptiles in which 11 reports indicated no damage, 55 failed to report damage 

(if any), and 1 reported substantial damage. 2 The damage codes and descriptions follow the International Civil Aviation Organization Bird Strike Information 

System (1989): Minor = the aircraft can be rendered airworthy by simple repairs or replacements and an extensive 

inspection is not necessary; Uncertain = the aircraft was damaged, but details as to the extent of the damage are 

lacking; Substantial = the aircraft incurs damage or structural failure that adversely affects the structure strength, 

performance, or flight characteristics of the aircraft and that would normally require major repair or replacement of the 

affected component (specifically excluded are bent fairings or cowlings; small dents or puncture holes in the skin; 

damage to wing tips, antenna, tires, or brakes; and engine blade damage not requiring blade replacement); Destroyed 

= the damage sustained makes it inadvisable to restore the aircraft to an airworthy condition. 

Table 2-12. Reported effect-on-flight (EOF) of wildlife strikes to civil aircraft, USA, 1990–2003. 

Reported strikes

Birds Mammals Total1

Effect-on-flight2 14-year total 

% of 

total known 14-year total

% of 

total known 14-year total

% of 

total known

None 26,493 86 315 44 26,821 85

Negative effect 4,316 14 403 56 4,726 15

Precautionary landing 2,235 7 63 9 2,299 7

Aborted takeoff 1,072 4 130 18 1,202 4

Engine shutdown 251 1 22 3 273 1

Other 758 3 188 26 952 3

Total known 30,809 100 718 100 31,547 100

Unknown 20,345 554 20,946

Total 51,154 1,272 52,493

1 Included in totals are 67 strikes involving reptiles in which 13 reports indicated no effect-on-flight, 47 failed to report 

on effect-on-flight (if any), 1 reported a precautionary landing, and 6 reported “other”. 2 Effect-on-flight: None = flight continued as scheduled, although delays and other cost caused by inspections or 

repairs may have been incurred after landing; Aborted takeoff = pilot aborted the takeoff; Precautionary landing = pilot 

landed at other-than-destination airport after strike; Engine shut down = pilot shut down the engine or the engine 

stopped running because of strike; Other = miscellaneous effects, such as reduced speed because of shattered 

windshield, emergency landing at destination airport, or crash landing; Unknown = report did not give sufficient 

information to determine an effect-on-flight (Dolbeer et al. 2000). 
Chapter 2 Wildlife Strike Database 17 

2.6 SELECTED EXAMPLES OF WILDLIFE STRIKES

Below are descriptions of some wildlife strikes that are either of historic interest, have 

influenced flight safety, or are typical of damaging strikes in recent years in the USA. 

7 September 1905. From the Wright Brothers diaries, “Orville ... flew 4,751 meters in 4 

minutes 45 seconds, four complete circles. Twice passed over fence into Beard's 

cornfield. Chased flock of birds for two rounds and killed one which fell on top of the 

upper surface and after a time fell off when swinging a sharp curve.” This was the first 

reported bird-aircraft strike. Because 

of the location near Dayton, Ohio, and 

time of year, the bird struck was 

probably a red-winged blackbird. 

25 July 1909. During engine warm-up 

for Louis Bleriot's historic first flight 

across the English Channel from Les 

Baraques, France, a farm dog ran into 

the propeller of the Bleriot XI aircraft. 

This was the first reported terrestrial 

wildlife (mammal) strike. 

3 April 1912. Calbraith Rogers, the 

first person to fly across the 

continental USA, was also the first to 

die as a result of a wildlife strike. On 3 

April 1912, Rodgers’ Wright Pusher 

struck a gull, causing the aircraft to crash into the surf at Long Beach, California. 

Rodgers was pinned under the wreckage and drowned. 

Calbraith Rogers and his aircraft the Vin Fizz

following his fatal encounter with a gull (photo

courtesy National Air and Space Museum,

Smithsonian Institution, SI Neg. No. A-43520-E). 

4 October 1960. A Lockheed Electra turbo-prop ingested European starlings into all 

four engines during takeoff from Boston Logan Airport (Massachusetts). The plane 

crashed into Boston Harbor, killing 62 people. Following this accident, the FAA initiated 

action to develop minimum bird ingestion standards for turbine-powered engines. 

26 February 1973. On departure from Atlanta's Peachtree-Dekalb Airport (Georgia), a 

Lear 24 jet struck a flock of brown-headed cowbirds attracted to a nearby trash disposal 

area. Engine failure resulted. The aircraft crashed, killing seven people and seriously 

injuring one person on the ground. This incident prompted the FAA to develop 

guidelines for the location of solid waste disposal facilities on or near airports. 

12 November 1975. On departure roll from John F. Kennedy International Airport (New 

York), the pilot of a DC-10 aborted takeoff after ingesting gulls into one engine. The 

plane ran off runway and caught fire as a result of engine fire and overheated brakes. 

The resultant fire destroyed the aircraft. All 138 people on board, airline personnel 

trained in emergency evacuation, evacuated safely (see photo page 18). Following this 

accident, the National Transportation Safety Board recommended the FAA evaluate the 

effect of bird ingestion on large, high-bypass, turbofan engines and the adequacy of 

engine certification standards. The FAA initiated a nationwide data collection effort to 

document bird strike and engine ingestion events. 
18 Wildlife Strike Database Chapter 2 

25 July 1978. A Convair 580 

departing Kalamazoo Airport 

(Michigan) ingested one American 

kestrel into an engine on takeoff. The 

aircraft auto-feathered and crashed in 

a nearby field, injuring 3 of the 43 

passengers. 

18 June 1983. The pilot of a Bellanca 

1730, landing at Clifford, Texas, saw 

two “buzzards” on final approach. He 

added power and maneuvered to avoid 

them, then continued approach. This 

resulted in a landing beyond the 

intended point. The middle of the 

runway was higher than either end; 

therefore, the pilot was unable to see a 

large canine moving toward the 

landing area until aircraft was halfway down the runway. A go-around was initiated, but 

the lowered landing gear hit some treetops causing the pilot to loose control. The 

aircraft came to rest in a milo field about 250 yards from initial tree impact after flying 

through additional trees. The aircraft suffered substantial damage, and two people in 

the aircraft were seriously injured. 

This DC-10 was destroyed by fire when several

herring gulls were ingested into an engine during

takeoff from JFK International Airport, November

1975 (see story on page 17; photo courtesy Port

Authority New York and New Jersey). 

6 January 1985. A Beechcraft King Air 90 departing Smith Reynolds Airport (North 

Carolina) at dusk hit a large feral dog on the runway just at rotation. The aircraft 

suffered substantial damage. 

17 March 1987. A Boeing-737 struck an 80-pound deer at Chicago O’Hare (Illinois) 

airport. The aircraft suffered over $114,000 in damage. 

5 November 1990. During takeoff at Michiana Regional Airport (Indiana), a BA-31 flew 

through a flock of mourning doves. Several birds were ingested in both engines, and 

takeoff was aborted. Both engines were destroyed. Cost of repairs was $1 million, and 

time out of service was 60 hours. 

30 December 1991. A Citation 550, taking off from Angelina County Airport (Texas), 

struck a turkey vulture. The strike caused major damage to the #1 engine and resulting 

shrapnel caused minor damage to the wing and fuselage. Cost of repairs was $550,000 

and time out of service was 2 weeks. 

2 February 1992. A Piper Cherokee struck a deer at rotation during takeoff from 

Sandstone Municipal Airport (MN). The pilot attempted to turn back to the airport but 

collided into trees just south of airport. The aircraft was destroyed and the pilot 

seriously injured. 

3 December 1993. A Cessna 550 struck a flock of geese during the initial climb out of 

DuPage County Airport (Illinois). The pilot heard a loud bang, and the aircraft yawed to 

the left and right. Instruments showed loss of power to the #2 engine and a substantial 

fuel leak on the left side. An emergency was declared, and the aircraft landed at 
Chapter 2 Wildlife Strike Database 19 

Midway Airport. The cost to repair two engines was $800,000, and time out of service 

was about 3 months. 

21 October 1994. A Cessna 210 struck a coyote during the landing roll at Higginsville 

Industrial Municipal Airport (Missouri) at night. The nose gear collapsed and the 

propeller hit the runway, resulting in major damage to the engine and crankshaft. 

3 June 1995. An Air France Concorde, at about 10 feet AGL while landing at John F. 

Kennedy International Airport (New York), ingested one or two Canada geese into the 

#3 engine. The engine suffered an uncontained failure. Shrapnel from the #3 engine 

destroyed the #4 engine and cut several hydraulic lines and control cables. The pilot 

was able to land the plane safely, but the runway was closed for several hours. 

Damage to the Concorde was estimated at over $7 million. The French Aviation 

Authority sued the Port Authority of 

New York and New Jersey and 

eventually settled out of court for $5.3 

million. 

22 September 1995. A U.S. Air Force 

Airborne Warning and Control System 

(AWACS) aircraft (modified Boeing 

707) crashed, killing all 24 on board, 

after ingesting four Canada geese into 

the #1 and #2 engines during takeoff 

from Elmendorf Air Force Base 

(Alaska). This was the first crash of an 

AWACS plane since the Air Force 

began using them in 1977. 

5 October 1996. A Boeing-727 

departing Washington Reagan 

National Airport (District of Columbia) 

struck a flock of gulls just after takeoff, ingesting at least one bird. One engine began to 

vibrate and was shut down. A burning smell entered the cockpit. An emergency was 

declared, and the aircraft, carrying 52 passengers, landed at Washington Reagan 

National. Several engine blades were damaged. 

A USAF AWACS aircraft similar to this was lost in

1995 and 24 airmen were killed when Canada geese

were struck just after rotation. The USAF was aware

of geese living on the airbase, yet had taken no direct

action to eliminate the birds (photo courtesy USAF). 

7 January 1997. An MD-80 aircraft struck over 400 blackbirds just after takeoff from 

Dallas-Fort Worth International Airport (Texas). Almost every part of the plane was hit. 

The pilot declared an emergency and returned to land without event. Substantial 

damage was found on various parts of the aircraft, and the #1 engine had to be 

replaced. The runway was closed for 1 hour. The birds had been attracted to an unharvested wheat field on the airport. 

9 January 1998. While climbing through 3,000 feet, following takeoff from Houston 

Intercontinental Airport (Texas), a Boeing-727 struck a flock of snow geese with three to 

five birds ingested into one engine. The engine lost all power and was destroyed. The 

radome was torn from aircraft and leading edges of both wings were damaged. The 

pitot tube for the first officer was torn off. Intense vibration was experienced in the 

airframe and the noise level in the cockpit increased to the point that communication 
20 Wildlife Strike Database Chapter 2 

among crewmembers became difficult. An emergency was declared. The flight 

returned safely to Houston with major damage to aircraft. 

22 February 1999. A Boeing-757 departing Cincinnati/Northern Kentucky International 

Airport (Kentucky) had to return and make an emergency landing after hitting a large 

flock of starlings. Both engines and one wing received extensive damage. About 400 

dead starlings were found on the runway area. 

7 February 2000. An American-owned cargo company’s DC-10-30 departing Subic 

Bay, Philippines, ingested a fruit bat into one engine at 250 feet AGL. The aircraft 

returned to the airport. Five damaged fan blades had to be replaced. Time out of 

service was 3 days. Total repair and related costs exceeded $3 million. 

21 January 2001. An MD-11 departing Portland International Airport (Oregon) ingested 

a herring gull into the #3 engine during the takeoff run. The engine stall blew off the 

nose cowl that was sucked back into the engine and shredded. The engine had an 

uncontained failure. The pilot aborted takeoff and blew two tires. The 217 passengers 

were safely deplaned and rerouted to 

other flights. Smithsonian Feather Lab 

identified bird. 

09 March 2002. A Canadair RJ 200 

at Dulles International Airport 

(Virginia) struck two wild turkeys 

during the takeoff roll. One shattered 

the windshield spraying the cockpit 

with glass fragments and remains. 

Another hit the fuselage and was 

ingested. There was a 14-by 4-inch 

section of fuselage skin damaged 

below the windshield seal on the flight 

officer’s side. The cost of repairs was 

estimated at $200,000. Time out of 

service was at least 2 weeks. 

19 October 2002. A Boeing 767 

departing Logan International Airport (Massachusetts) encountered a flock of over 20 

double-crested cormorants. At least 1 cormorant was ingested into the #2 engine. There 

were immediate indications of engine surging followed by compression stall and smoke 

from the engine. The engine was shutdown. An overweight landing with one engine 

was made without incident. The nose cowl was dented and punctured. There was 

significant fan blade damage with abnormal engine vibration. One fan blade was found 

on the runway. The aircraft was towed to the ramp. Hydraulic lines were leaking, and 

several bolts were sheared off inside engine. Many pieces fell out when the cowling was 

opened. The aircraft was out of service for 3 days. The cost of repairs was $1.7 million. 

One of the two turkeys that penetrated a Canadair RJ

200 fuselage below the windshield; parts of the bird

entered the cockpit.

8 January 2003. A Bombardier de Havilland Dash 8 collided with a flock of lesser 

scaup at 1,300 feet AGL on approach to Rogue Valley International Airport (Oregon). 

At least one bird penetrated the cabin and hit the pilot who turned control over to the 

first officer for landing. Emergency power switched on when the birds penetrated the 
Chapter 2 Wildlife Strike Database 21 

radome and damaged the DC power system and instruments systems. The pilot was 

treated for cuts and released from the hospital. 

4 September 2003. A Fokker 100 

struck a flock of at least five Canada 

geese over the runway shortly after 

takeoff at LaGuardia Airport (New 

York), ingesting one or two geese into 

the #2 engine. Engine vibration 

occurred. The pilot was unable to shut 

the engine down with the fuel cutoff 

lever, so the fire handle was pulled and 

the engine finally shut down, but the 

vibration continued. The flight was 

diverted to nearby JFK International 

Airport where a landing was made. 

The NTSB found a 20- by 36-inch wide 

depression on the right side of nose 

behind radome. Maximum depth was 4 

inches. Impact marks were found on 

the right wing. A fan blade separated 

from the disk and penetrated the fuselage. Several fan blades were deformed. Holes 

were found in the engine cowling. Bird remains were recovered and identified by 

Wildlife Services. 

17 February 2004. A Boeing 757 during a takeoff run from Portland International 

Airport (Oregon) hit five mallards and returned with one engine out. At least one bird 

was ingested, and parts of five birds were collected from the runway. Engine damage 

was not repairable, and the engine had 

to be replaced. The cost was $2.5 

million, and time out of service was 3 

days. 

15 April 2004. An Airbus 319 climbing 

out of Portland International Airport 

(Oregon) ingested a great blue heron 

into the #2 engine, causing extensive 

damage. The pilot shut the engine 

down as a precaution and made an 

emergency landing. The runway was 

closed 38 minutes for cleaning. The 

flight was cancelled. The engine and 

nose cowl were replaced. Time out of 

service was 72 hours. The damage 

totaled $388,000. 

14 June 2004. A Boeing 737 struck a 

great horned owl during a nighttime landing roll at Greater Pittsburgh International 

Airport (Pennsylvania). The bird severed a cable in the front main gear. The steering 

This picture shows a close-up of the #2 engine from

the Fokker-100 that ingested Canada geese on 4

September 2004. 

This is the #1 engine of the MD-80 after ingesting at

least 1 double-crested cormorant on 16 September

2004. (See story on page 22.) 
22 Wildlife Strike Database Chapter 2 

failed, and the aircraft ran off the runway and became stuck in mud. Passengers were 

bused to the terminal. Two nose wheels, two main wheels, and brakes were replaced. 

The aircraft was out of service 24 hours. The cost was estimated at $20,000. 

16 September 2004. A MD 80 departing Chicago O’Hare (Illinois) hit several doublecrested cormorants at 3,000 feet AGL and 4 miles from airport. The #1 engine caught 

fire and failed, sending metal debris to the ground in a Chicago neighborhood. The 

aircraft made an emergency landing back at O’Hare with no injuries to the 107 

passengers. (See photo on page 21.) 

24 October 2004. A Boeing 767 departing Chicago O’Hare (Illinois) hit a flock of birds 

during the takeoff run. A compressor stall caused the engine to flame out. A fire 

department got calls from local residents who reported seeing flames coming from the 

plane. The pilot dumped approximately 11,000 gallons of fuel over Lake Michigan 

before returning to land. Feathers found in engine were sent to the Smithsonian, 

Division of Birds, for identification. 

Besides having the potential to cause damaging

strikes, small mammals, such as this prairie dog at a

southwestern USA airport, can create problems by

burrowing, gnawing on wiring, and serving as a food

attractant for large birds of prey. 

2.7 CONCLUSIONS

Wildlife strikes can cause serious 

damage to aircraft and the 

occasional loss of human life. 

Because most strikes occur on or 

near airports, airports are the logical 

locations to place emphasis in 

addressing the problem. The 

following chapters and appendices, 

coupled with guidance from 

professional wildlife biologists trained 

in wildlife damage management, 

provide the information needed to 

develop, implement, and evaluate 

wildlife hazard management 

programs to minimize the likelihood 

of wildlife strikes on airports. 
 23 

CHAPTER 3: 

AGENCIES AND ORGANIZATIONS IMPACTING WILDLIFE 

HAZARD MANAGEMENT ON AIRPORTS 

In December 2002, this Dash-8 struck a deer while landing at a southeastern USA airport. The impact

caused the nose gear to collapse. The white-tailed deer population in the USA increased from a low

of about 350,000 in 1900 to at least 24 million in 2004. 

3.1 INTRODUCTION

Wildlife management is a complex mixture of science, experience, and art, regulated 

and implemented by various federal, state, and local governmental agencies. 

Overlapping federal, state, and local regulations enforced by various governmental 

organizations protect wildlife and associated wildlife habitat. This chapter provides an 

overview of the roles and responsibilities of various agencies and organizations that 

influence wildlife management on or near airports. 
24 Agencies and Organizations Chapter 3 

3.2 FEDERAL AGENCIES 

3.2.A U.S. DEPARTMENT OF TRANSPORTATION, FEDERAL AVIATION 

ADMINISTRATION 

3.2.A.I MISSION

The mission of the Federal Aviation Administration (FAA) is to provide a safe, secure, 

and efficient global aviation system that contributes to national security and the 

promotion of U.S. aviation. As the leading authority in the international aerospace 

community, the FAA is responsive to the dynamic nature of customer needs, economic 

conditions, and environmental concerns. 

3.2.A.II AUTHORITY

Since 1970, Section 612 of the 

Federal Aviation Act of 1958, as 

amended (49 U.S.C. 1432), has 

empowered the FAA Administrator 

to issue airport operating certificates 

to airports serving certain air carriers 

and to establish minimum safety 

standards for the operation of those 

airports. Some of these regulations 

and policies directly involve the 

management of wildlife and wildlife 

hazards on and/or near airports. 

3.2.A.III ROLE AND 

RESPONSIBILITY

Among its other responsibilities, the 

FAA is responsible for enforcement 

of Title 14 Code of Federal Regulations, part 139 (14 CFR 139). To carry out this role, 

the FAA has responsibilities for various aspects of aviation that include air navigation, 

air traffic control, aviation certification and regulation, aviation security, environmental 

impact minimization, and aviation research and development. 

High-profile species such as bald eagles present

special problems for airport managers (photo by E.

Cleary, FAA). 

The FAA roles and responsibilities relating to wildlife hazards and their associated 

human health and safety concerns are addressed in 14 CFR 139.337. The FAA's Office 

of Airport Safety and Standards' 150/5200 series Advisory Circulars (AC), Program 

Policy and Guidance, and Certalerts further clarify this information. 

3.2.A.III.A OFFICE OF AIRPORT SAFETY AND STANDARDS

A staff wildlife biologist is assigned to the Office of Airport Safety and Standards, 

Washington, DC. The biologist works with airport operators and certificate holders 

through the FAA regional and district offices in matters related to wildlife hazards on 

airports. Responsibilities of the staff wildlife biologist include reviewing development 

plans of all certificated airports to minimize wildlife hazards; managing the wildlife 

aircraft strike database designed to document the history of reported strikes at airports 
Chapter 3 Agencies and Organizations 25 

throughout the USA and its territories; and serving as an internal consultant to the FAA 

on the appropriateness of Wildlife Hazard Management Plans, wildlife hazard research, 

and other wildlife management issues 

of concern to the FAA. 

The FAA staff wildlife biologist 

examines all wildlife aircraft strike 

reports submitted to the FAA. Copies 

of major strike reports (14 CFR 

139.337(b)(1-4)), together with the 

strike history for the particular airport, 

are forwarded to the appropriate FAA 

regional personnel. See also FAA 

Office of Airport Safety and Standards' 

Policies and Program Guidance Policy 

No. 79, Review of Airport Wildlife 

Hazard Management Plans (Appendix 

D). 

3.2.A.III.B WILDLIFE HAZARD 

ASSESSMENTS 

Operators of certificated airports are 

required by regulation to conduct a Wildlife Hazard Assessment when specific wildlife 

events occur, as discussed in Chapter 6 (14 CFR 139.337(b)(1-4), see Appendix P). 

FAA Office of Airport Safety and Standards' Program Policy and Guidance No. 77, 

Initiation of Wildlife Hazard Assessments at Airports (Appendix D), establishes the 

procedures followed by FAA Airport Certification Safety Inspectors when it is 

determined that an airport needs to conduct a Wildlife Hazard Assessment. Under 

terms of the Memorandum of Understanding between the FAA and U.S. Department of 

Agriculture, Wildlife Services (USDA/WS, Appendix G), the USDA/WS program can 

provide assistance with the conduct of Wildlife Hazard Assessments and the 

development of Wildlife Hazard Management Plans. FAA Office of Airport Safety and 

Standards' Certalert No. 04-09, Relationship Between FAA and WS (Appendix E), 

further clarifies the roles of, and relationship between, the FAA and USDA/WS with 

regard to wildlife hazards on or near airports. See Chapter 6 for a discussion of the 

contents of a Wildlife Hazard Assessment. 

Airport operators are required to conduct a Wildlife

Hazard Assessment when wildlife capable of causing

substantial aircraft damage are observed to have

access to the aircraft movement area (photo courtesy

USDA). 

3.2.A.III.C WILDLIFE HAZARD MANAGEMENT PLANS

The FAA Administrator considers the Wildlife Hazard Assessment, aeronautical activity 

at the airport, views of the airport operator and its users, and other pertinent factors in 

determining whether a Wildlife Hazard Management Plan is needed (14 CFR 

139.337(d)(1-6), see Appendix P). See Chapter 6 for a discussion of the contents of a 

Wildlife Hazard Management Plan. 

3.2.A.III.D ADVISORY CIRCULARS (150/5200 SERIES) 

The FAA issues Advisory Circulars (AC) to systematically inform the aviation public of 

nonregulatory material of interest. The standards, practices, and suggestions contained 
26 Agencies and Organizations Chapter 3 

in AC are recommended by the FAA for use by the operators and sponsors of all publicuse airports. An AC provides guidance and information in its designated subject area 

and/or shows methods acceptable to the FAA Administrator for complying with 14 CFR 

139. Unless incorporated into regulation by reference, the contents of an AC are not 

binding on the public. FAA Advisory Circulars germane to airport wildlife issues can be 

found in Appendix C. 

3.2.B U.S. DEPARTMENT OF AGRICULTURE, WILDLIFE SERVICES 

3.2.B.I MISSION

The mission of the U.S. Department of 

Agriculture/Wildlife Services (USDA/ 

WS) is to provide federal leadership in 

managing problems caused by wildlife. 

USDA/WS helps manage wildlife to 

reduce damage to agriculture, natural 

resources, and property; minimizes 

potential threats to human health and 

safety; and assists in the protection of 

threatened and endangered species. 

3.2.B.II AUTHORITY

The primary statutory authority for the 

USDA/WS program is the Animal 

Damage Control Act of March 2, 1931, 

as amended (7 U.S.C. 426-426c; 46 

Statute 1468)(See Appendix B). 

USDA/WS has the authority to manage 

migratory bird damage only as specified in the Code of Federal Regulations and under 

permits issued by the U.S. Fish and Wildlife Service (USFWS) (50 CFR 21). USDA/WS 

does not have the authority to issue migratory bird depredation permits. 

Bayberry bushes produce fruits that often attract

large flocks of tree swallows along the east coast of

the USA during fall migration. Identifying and

removing such preferred food plants is an important

part of a wildlife hazard management control program

(photo by R. A. Dolbeer, USDA). 

3.2.B.III ROLE AND RESPONSIBILITY

Wildlife is a public resource greatly valued by the citizens of the USA. However, wildlife 

can cause damage to agricultural and industrial resources, pose risks to human health 

and safety, and impact other natural resources. USDA/WS has the federal 

responsibility to help resolve conflicts that occur when human activity and wildlife are in 

proximity to one another. USDA/WS has primary responsibility of responding to threats 

caused by migratory birds. 

Wildlife Services Directive 2.305, Wildlife Hazards to Aviation (Appendix F), provides 

guidance for USDA/WS wildlife biologists in providing technical assistance or direct 

control to airport managers, state aviation agencies, the aviation industry, the FAA, and 

the Department of Defense (DOD) on hazards caused by wildlife to airport safety. 

USDA/WS assists federal, state, and local agencies; airport managers; the aviation 

industry; and the military in reducing wildlife hazards on and in the vicinity of airports 
Chapter 3 Agencies and Organizations 27 

and air bases according to the Memoranda of Understanding with the FAA (Appendix 

G) and Department of Defense and guidelines published elsewhere. 

In addition, it is the responsibility of USDA/WS personnel that observe existing or 

potential wildlife hazards at airports or air bases to immediately notify the appropriate 

aviation authorities. 

USDA/WS may enter into cooperative agreements to develop Wildlife Hazard 

Assessments and Wildlife Hazard Management Plans and to conduct direct wildlife 

hazard reduction programs. These activities are performed pursuant to agreements 

that are funded by cooperating entities. 

USDA/WS biologists may provide training for airport and air base personnel in wildlife 

and hazard identification and the safe and proper use of wildlife control equipment and 

techniques. 

Birds are not the only wildlife that pilots must watch

out for. Proper fencing would have prevented this

incident. 

USDA/WS biologists may provide 

recommendations and assistance to 

airport managers and air base 

commanders in obtaining federal, 

state, and local permits to remove 

protected wildlife species. 

3.2.C U.S. DEPARTMENT OF 

DEFENSE 

3.2.C.I MISSION 

The U.S. Department of Defense 

(USDOD) is responsible for providing 

the military forces needed to deter war 

and protect the security of the USA. 

3.2.C.II AUTHORITY

The USDOD is the successor agency to the National Military Establishment created by 

the National Security Act of 1947 (50 U.S.C. 401). It was established as an executive 

department of the Government by the National Security Act Amendments of 1949 with 

the Secretary of Defense as its head (5 U.S.C. 101). The USDOD’s primary authority is 

established under 32 CFR 1-2900. 

3.2.C.III ROLE AND RESPONSIBILITY

Each military department (Department of the Navy includes the U.S. Marine Corps) is 

separately organized under its own Secretary and functions under the authority, 

direction, and control of the Secretary of Defense. The commanders of unified and 

specified combat commands are responsible to the President and the Secretary of 

Defense for accomplishing the military missions assigned to them and exercising 

command authority over forces assigned to them. 

The U.S. Air Force (USAF) Bird Aircraft Strike Hazard (BASH) Team, HQ Air Force 

Safety Center, Kirtland Air Force Base, New Mexico, oversees the USAF wildlife strike 

reduction efforts. The BASH team maintains a wildlife strike database for strikes 
28 Agencies and Organizations Chapter 3 

involving USAF aircraft (http://afsafety.af.mil/afsc/Bash/home.html) similar to the 

database maintained by the FAA for civil aircraft (Chapter 2). 

3.2.D U.S. ARMY CORPS OF ENGINEERS 

3.2.D.I MISSION

The U.S. Army Corps of Engineers (COE) is charged with a wide range of functions 

related to water resources. Among these is the protection of navigation and 

safeguarding the nation’s water resources. 

3.2.D.II AUTHORITY

Regulatory authorities of the COE include Section 10 of the Rivers and Harbors Act of 

1899 (33 U.S.C. 403), which prohibits the obstruction or alteration of navigable waters 

of the U.S. without a COE permit; Section 404 of the Clean Water Act (33 U.S.C. 

1344), which regulates the excavation and discharge of dredged or fill materials into 

waters of the U.S.; and Section 103 of 

the Marine Protection, Research, and 

Sanctuaries Act of 1972, which 

regulates deposition of fill material into 

ocean waters. 

Recognizing that landfills can attract hazardous birds,

the USEPA requires municipal solid waste landfills to

be operated in a manner that does not pose a hazard

to aviation safety (photo by E. Cleary, FAA). 

3.2.D.III ROLE AND RESPONSIBILITY

The COE regulatory branch 

administers a permit system under 

Section 404 of the Clean Water Act. 

All proposed management actions 

involving any wetland habitat 

modification or excavation of fill 

material from or discharged into waters 

of the USA must be evaluated for 

Section 404 applicability and permit 

requirements. Projects requiring 

permits might require mitigation of 

impacted resources. 

3.2.E U.S. ENVIRONMENTAL PROTECTION AGENCY 

3.2.E.I MISSION

The mission of the U.S. Environmental Protection Agency (USEPA) is to safeguard the 

nation’s environment. 

3.2.E.II AUTHORITY

The USEPA was established in 1970 in response to concerns about polluted air and 

rivers, unsafe drinking water, endangered species, and waste disposal. The USEPA's 

primary regulatory responsibilities are established under 40 CFR 1-799. 

3.2.E.III ROLE AND RESPONSIBILITY

USEPA functions include setting and enforcing environmental standards and 
Chapter 3 Agencies and Organizations 29 

regulations related to air and water pollution, hazardous wastes, pesticides, and toxic 

substances. The USEPA’s mission is accomplished through partnerships with state and 

local governments. USEPA responsibilities include pesticide registration and regulation 

and siting and construction of wastewater treatment and solid waste disposal facilities, 

which are permitted through state and local agencies. The FAA and USDA/WS may be 

consulted by airport authorities or state and local agencies to review impacts of 

proposed USEPA-regulated projects on aviation safety. 

3.2.E.III.A LANDFILLS 

Approval or disapproval of a landfill site is the responsibility of the USEPA, state and 

local governing bodies, and zoning boards. Other federal agencies, such as the FAA 

and USDA/WS, may only comment as to whether they would consider the proposed 

landfill to be compatible or non-compatible with their mission requirements. 

3.2.E.III.B PESTICIDES 

Before any pesticide may be used, it 

must be registered with the USEPA 

and with the appropriate state 

pesticide regulating authority. 

Pesticides are generally classified as 

either restricted use or general use. 

Restricted-use pesticides may only 

be sold to and used by Certified 

Applicators or persons under their 

direct supervision and only for those 

uses covered by the Certified 

Applicator's certification. There are 

few restrictions on who may purchase 

or use general-use pesticides. 

Persons who want to use restricteduse pesticides, apply any pesticide to 

the land of another, or apply any 

pesticides for hire must be a Certified 

Applicator or working under the direct 

supervision of a Certified Applicator, 

and then only use pesticides covered by the Certified Applicator’s certification (see state 

EPA below). 

As one facet of an integrated hazardous wildlife

management program, licensed falconers may

occasionally use trained raptors, such as this peregrine

falcon, at airports to repel other birds (photo by E.

Cleary, FAA). 

3.2.F U.S. DEPARTMENT OF INTERIOR, U.S. FISH AND WILDLIFE SERVICE 

3.2.F.I MISSION

The mission of the U.S. Fish and Wildlife Service (USFWS) is to conserve, protect, and 

enhance the nation’s fish and wildlife and their habitats for the continuing benefit of all 

people. 

3.2.F.II AUTHORITY

The USFWS has management authority for migratory birds and federally listed 
30 Agencies and Organizations Chapter 3 

threatened and endangered wildlife species. The USFWS primary regulatory 

responsibilities are established under 50 CFR 1-199. 

3.2.F.III ROLE AND RESPONSIBILITY

The USFWS is responsible for the conservation and enhancement of migratory birds, 

threatened and endangered species, certain marine mammals, anadromous fishes, and 

wetlands. The USFWS also manages the National Wildlife Refuge System, enforces 

federal wildlife laws, and conducts biological reviews of the environmental impacts of 

development projects. 

The USFWS renders biological opinions on 

proposed federal activities that might impact 

federally listed or proposed endangered or 

threatened species or result in the 

destruction or adverse modification of 

designated or proposed critical habitat. 

These opinions are solicited through a 

“Section 7 consultation”, as required under 

the Endangered Species Act of 1973 (16 

U.S.C. 1531-1544, 87 Statute 884, as 

amended). 

Most mammals are protected by state wildlife

agencies, and it is generally necessary to

obtain a State Depredation Permit before

taking these species on an airport. The first

step in obtaining such a permit is to contact the

nearest office of USDA Wildlife Services (see

Appendix A). 

3.3 STATE AGENCIES

Specific state regulations and their 

enforcement are not addressed in this 

manual because of their wide variability. 

The following general comments are 

provided as background information. 

Consult state and local regulatory agencies 

having jurisdiction over wildlife and natural 

resources, environmental protection, health, 

law enforcement, transportation, and others 

as applicable, when working with airport 

wildlife issues. 

3.3.A STATE WILDLIFE MANAGEMENT AGENCIES

Wildlife management authority for resident nonmigratory birds, terrestrial mammals, 

freshwater fish, reptiles, and other taxa rest with state wildlife management agencies. 

These agencies establish the take and possession regulations for all state-protected 

species. States set their migratory game-bird hunting seasons and bag limits within the 

guidelines established by the USFWS. States also may list certain wildlife and plant 

species as threatened or endangered that are not considered as such at the federal 

level. 

Persons needing to take state-protected species outside of the legal hunting season or 

beyond the established bag limits to promote airport safety must first secure a state 
Chapter 3 Agencies and Organizations 31 

depredation permit. Contact the nearest USDA/WS office (Appendix A) for assistance 

in obtaining any necessary state depredation permits. 

3.3.B STATE ENVIRONMENTAL PROTECTION AGENCIES

3.3.B.I LANDFILL SITING PERMITS AND INSPECTIONS 

With concurrence from the USEPA, state EPAs, local governing bodies, and zoning 

boards have the final responsibility for issuing landfill permits. It is also a state 

responsibility to inspect all landfills to ensure compliance with all applicable federal and 

state regulations. 

3.3.B.II PESTICIDE REGISTRATION 

Before a pesticide may be sold or used, it must be registered with the USEPA and with 

the respective state’s pesticide regulatory agency. Special Local Need (SLN) registered 

pesticides may only be used in the state—and in some cases, the specific geographical 

location—for which the SLN registration has been issued. 

3.3.B.III PESTICIDE APPLICATOR LICENSING 

With USEPA concurrence, each state is responsible for establishing pesticide applicator 

licensing requirements and applicator training procedures. The retail sale and use of 

restricted-use pesticides is limited to 

Certified Applicators or persons 

working under their direct supervision 

and only for those uses covered by the 

Certified Applicator's certification. 

Anyone who uses restricted-use 

pesticides, applies any pesticides for 

hire, or applies any pesticide to the 

land of another must be a Certified 

Applicator or working under the direct 

supervision of a Certified Applicator, 

and may only use pesticides covered 

by the Certified Applicator's 

certification. 

3.4 AIRPORTS 

3.4.A AIRPORT OPERATOR

The operator of a certificated airport1

must demonstrate that the airport is properly and adequately equipped and programs 

are in place to provide a safe airport-operating environment in accordance with all 

sections of 14 CFR 139 subpart D. Included in this regulation is the need to address 

 

1 Airports that have received an Airport Operating Certificate from the FAA, issued under 14 CFR 139, to 

operate a Class I, II, III, or IV airport. 

Within 2 weeks of completion, starlings and pigeons

had started roosting in this canopy constructed over

the passenger drop-off area at a major USA airport

(photo by S. Gordon). 
32 Agencies and Organizations Chapter 3 

wildlife hazard issues, conduct Wildlife Hazard Assessments, and develop Wildlife 

Hazard Management Plans, as conditions dictate. 

In accordance with its Airport Certification Manual and the requirements of section 

139.337(a), each certificate holder must take immediate action to alleviate wildlife 

hazards whenever they are detected. An important part of this process is establishing 

procedures for airport employees or tenants to report hazardous wildlife on or near the 

air operation areas (AOA) to the appropriate airport personnel. 

3.4.B AIR TRAFFIC CONTROL 

Air traffic control personnel must 

report any unsafe conditions, 

including hazardous wildlife on or 

near the AOA, to the appropriate 

airport personnel anytime they are 

observed. 

Also, to the extent permitted by 

higher priority duties and other 

circumstances, air traffic controllers 

are required to— 

• Issue advisory information on 

pilot-reported, tower-reported, 

or radar-observed and pilotverified bird activity; 

• Relay bird activity information to 

adjacent facilities and to Flight 

Service Stations (FSS) 

whenever it appears the wildlife 

hazard will become a factor in 

the area (FAA Order 7110.65, 

2-1-22). 

3.4.C PILOTS

Pilots have a responsibility to report 

all unsafe conditions on or near an 

airport, including birds or other 

wildlife that could pose a threat to 

aircraft safety. Pilots and other 

airline or airport personnel should 

report all known wildlife strikes. 

Strikes can be reported 

electronically at http://wildlife-mitigation.tc.faa.gov. Wildlife strikes can also be reported 

by completing and mailing FAA Form 5200-7 Bird/Other Wildlife Strike Report

(Appendix I). No postage is required if this form is mailed within the USA. This form 

can be downloaded and printed from the above website and duplicated as needed. All 

strike reports are closely screened and edited to prevent duplicate entries in the 

Pilots using uncontrolled airports need to be alert to the

possibility of wildlife on the runway. This Learjet was

destroyed when it struck two deer on landing at a

southern USA airport, January 2001. In 2004, there

were 3,344 airports in the FAA’s National Plan of

Integrated Airport Systems; less than 650 had an air

traffic control tower. 
Chapter 3 Agencies and Organizations 33 

database. 

3.5 BIRD STRIKE COMMITTEE–USA 

Bird Strike Committee–USA (BSC–USA) was formed in 1991 to facilitate the exchange 

of information, promote the collection and analysis of accurate wildlife strike data, 

promote the development of new technologies for reducing wildlife hazards, promote 

professionalism in wildlife management programs on airports through training and 

advocacy of high standards of conduct of airport biologists and bird patrol personnel, 

and serve as a liaison to similar organizations in other countries. 

Bird Strike Committee USA is directed by a 9- to 12-person steering committee 

consisting of two to three members each from the FAA, USDA/WS, DOD, and the 

aviation industry. The organization meets annually, in conjunction with Bird Strike 

Committee Canada, at an airport in 

the USA or Canada. There are 

generally four parts to a BSC–USA 

meeting. Part 1 is classroom and field 

training sessions on wildlife control at 

airports, which cover both civil and 

military aviation. Part 2 consists of the 

presentation of technical papers and 

posters. Part 3 comprises exhibits and 

demonstrations with vendors. Part 4 is 

a field trip that generally covers the 

host airport and surrounding areas to 

observe management programs and 

habitat issues related to wildlife and 

aviation safety. Participation in the 

annual meetings is open to any 

person interested in reducing wildlife 

hazards to aviation and in 

environmental and land-use issues related to airports. BSC–USA does not charge 

membership fees; however, a registration fee is charged for attendance at annual 

meetings. 

Between 1990 and 2003, deer were responsible for

16 (76 percent) of the mammal strikes that resulted in

injury or death and for 23 (77 percent) of the 30

deaths or injuries resulting from wildlife strikes with

civil aircraft in the USA (photo by S. Wright, USDA). 

Additional information about BSC–USA can be found at BSC–USA's website: 

http://www.birdstrike.org. 
34 Agencies and Organizations Chapter 3 

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 35 

CHAPTER 4: 

FEDERAL REGULATIONS AND DEPARTMENTAL POLICIES 

IMPACTING AIRPORT WILDLIFE MANAGEMENT 

Four men escaped unhurt when their Learjet 36 struck an elk and caught fire during takeoff at a

western USA airport in December 2002. The pilot was able to bring the plane to a stop in a marsh just

off the end of the runway and evacuate the aircraft before it was destroyed by fire. 

4.1 INTRODUCTION

Wildlife is often protected by overlapping federal, state, and local laws, regulations, and 

ordinances, enforceable by a diversity of governmental organizations. Chapter 3 

provided an overview of the roles and responsibilities of the various agencies. This 

chapter will discuss some of the more important federal regulations and departmental 

policies that influence wildlife management on or near airports. 
36 Regulations and Policies Chapter 4 

4.2 SUMMARY OF APPLICABLE FEDERAL REGULATIONS 

4.2.A TITLE 14, CODE OF FEDERAL REGULATIONS, PART 139 

14 CFR 139 governs the certification and operation of land airports that serve any 

scheduled or unscheduled passenger operation of an air carrier that is conducted with 

an aircraft having a seating capacity of more than 9 passengers. Part 139.337 

(Appendix P) speaks specifically to the airport operator’s responsibilities when dealing 

with the reduction of wildlife strike hazards on and around airports. A detailed 

discussion of Part 139.337 can be found in Chapter 6. 

4.2.B TITLE 40, CODE OF FEDERAL REGULATIONS, PART 258.10 

The U.S. Environmental Protection Agency (USEPA), recognizing that birds can be 

attracted in large numbers to municipal solid waste landfills (MSWLF) and recognizing 

the potential threat posed by birds to aircraft safety, requires owners or operators of 

new MSWLF units—or lateral expansions of existing MSWLF units that are located 

within 10,000 feet of any airport runway used by turbojet aircraft or within 5,000 feet of 

any airport runway used only by piston-type aircraft—to demonstrate successfully that 

such units do not create hazardous conditions for aircraft. 

The USEPA also requires any 

operator proposing a new or expanded 

waste disposal operation within 5 

statute miles of a runway end to notify 

the appropriate FAA Regional Airports 

Division Office and the airport operator 

of the proposal. 

4.2.C TITLE 50, CODE OF 

FEDERAL REGULATIONS, PARTS 1 

TO 199 

These regulations govern the 

management of federally protected 

wildlife within the United States and its 

territories based on the authority 

established in the Migratory Bird 

Treaty Act (see below). These 

regulations also establish procedures 

for issuing permits to take federally 

protected species. In general, a 

federal depredation permit, issued by the U.S. Fish and Wildlife Service (USFWS), must 

be obtained before any non-game migratory birds may be taken, or before any 

migratory game birds may be taken outside of the normal hunting season or beyond 

established bag limits. 

Because of conservation efforts by government

agencies and private organizations, many wildlife

species once on the brink of extinction are now on

the road to recovery. This juvenile bald eagle,

hatched in New York, was rescued after a storm in

Indiana. Management of migratory bird species is

the responsibility of the USFWS (photo by E. Cleary,

FAA).

Federal law protects all migratory birds, including their nests and eggs: 

"A migratory bird [is]...any bird whatever its origin and whether or not raised in captivity, 
Chapter 4 Regulations and Policies 37 

which belongs to a species listed in sect. 10.13 [of 50 CFR] or which is a mutation or a 

hybrid of any such species, including any part, nest, or egg of any such bird, or any 

product, whether or not manufactured, which consist, or is composed in whole or part, 

of any such bird, or any part, nest, or egg there of." (50 CFR 10.12). This list includes 

almost all native bird species in the United States, with the exception of nonmigratory 

game birds, such as turkeys and grouse, and some introduced game birds, such as 

pheasants and chukars. Exotic and feral species, such as graylag geese, muscovy 

ducks, European starlings, house (English) sparrows, and rock doves (pigeons), are not 

listed in 50 CFR 10.13 and are therefore not protected by federal law. 

In addition to federal protection, all states protect migratory birds as well as game birds, 

such as pheasants, turkeys, grouse, and partridges. States might or might not protect 

exotic or feral species. 

With the exception of federally listed or proposed threatened or endangered species, 

federal law does not protect terrestrial mammals, reptiles, or other wildlife taxa (e.g., 

deer, coyotes, raccoons, groundhogs, 

snakes, turtles, and freshwater fish). 

Protection of these wildlife groups is 

left to the individual states. 

4.2.C.I DEPREDATION PERMITTING 

REQUIREMENTS AND 

PROCEDURES 

Persons wishing to take migratory 

birds, nests, or eggs as part of an 

airport wildlife management program 

must first secure a depredation permit 

from the USFWS. Some state wildlife 

management agencies may require 

that a state permit be obtained also. 

Persons wishing to take stateprotected species must first secure a 

permit from their respective state 

wildlife management agency. For 

assistance in obtaining federal and state depredation permits, contact the local U.S. 

Department of Agriculture, Wildlife Services (USDA/WS) office (Appendix A). 

Blackbirds traveling to and from roosting sites near

an airport can create hazardous conditions for

aircraft. A federal permit is not required to control

blackbirds when "concentrated in such numbers and

manner as to constitute a health hazard or other

nuisance” (photo by R. A. Dolbeer, USDA). 

4.2.C.II STANDING DEPREDATION ORDERS

Federal law allows people to protect themselves and their property from damage 

caused by migratory birds. Provided no effort is made to kill or capture the birds, a 

depredation permit is not required to merely scare or herd depredating migratory birds 

other than endangered or threatened species or bald or golden eagles (50 CFR 21.41). 

In addition, certain species of migratory birds may be killed or captured without a federal 

permit under specific circumstances, most of which relate to agricultural situations. A 

Standing Depredating Order that has applicability at airports relates to blackbirds and 

related species: 
38 Regulations and Policies Chapter 4 

“A federal permit shall not be required to control yellow-headed, red-winged, rusty and 

Brewer's blackbird, cowbirds, all grackles, crows, and magpies, when found committing 

or about to commit depredation upon ornamental or shade trees, agricultural crops, 

livestock, or wildlife, or when 

concentrated in such numbers and 

manner as to constitute a health 

hazard or other nuisance ...“ (50 CFR 

21.43). 

However, state laws may not mirror 

federal law in this respect. For 

example, in Ohio, crows may not be 

killed in any circumstances, outside of 

the state crow-hunting season, without 

a state-issued depredation permit, and 

blackbirds may not be killed on 

Sundays. 

Persons wishing to take any other 

migratory birds, or to take migratory 

birds in situations other than those 

described above, must first secure a 

federal Migratory Bird Depredation 

Permit from the USFWS, and in some 

case a State Depredation Permit. The 

first step in obtaining the necessary permits is to contact the nearest USDA/WS state 

office (Appendix A). 

This Navy T-44A suffered a turkey vulture strike to

the right horizontal stabilizer during a routine training

flight in October 2002 in Texas. The T-44A is the

U.S. Navy’s version of a Beechcraft King Air 90, a

twin turboprop corporate and utility transport aircraft.

The turkey vulture population in the USA increased at

a mean annual rate of over 2% from 1980–2004. 

4.2.D THE MIGRATORY BIRD TREATY ACT OF 1918, AS AMENDED (U.S. CODE

603–711; 40 STATUTE 755) 

The United States of America, Canada, the United Mexican States, Russia and Japan 

are signatories to the Migratory Bird Treaty Act (MBTA). This act provides the statutory 

foundation for the federal protection and management of migratory birds in the United 

States (50 CFR, Parts 1–199). 

4.2.E THE ANIMAL DAMAGE CONTROL ACT OF 1931, AS AMENDED 

(7 U.S. CODE 426–426C; 46 STATUTE 1468) 

This act authorizes and directs the Secretary of Agriculture to manage wildlife injurious 

to agricultural interests, other wildlife, or human health and safety, including wildlife 

hazards to aviation (Appendix B). The U.S. Department of Agriculture’s Wildlife 

Services (USDA/WS) is the agency that carries out this mandate. USDA/WS, because 

of the experience, training, and background of its personnel, is recognized throughout 

the world for expertise in dealing with wildlife damage management issues. USDA/WS 

has an active presence in all U.S. states and territories. USDA/WS also has a National 

Wildlife Research Center in Colorado and eight regional research field stations. 
Chapter 4 Regulations and Policies 39 

4.2.F FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT, AS AMENDED 

(7 U.S. CODE 136; PUBLIC LAW 104.317) 

This act, administered by USEPA, governs the registration, labeling, classification, and 

use of pesticides. Any substance used as a pesticide must be registered with the 

USEPA and with the respective state pesticide-regulatory agency. Anyone wishing to 

use restricted-use pesticides, applying 

any pesticides to the land of another, 

or applying any pesticides for hire, 

must be a Certified Applicator, or 

working under the direct supervision of 

a Certified Applicator, and then may 

only use pesticides covered by the 

Certified Applicator's certification. 

4.3 DEPARTMENTAL 

POLICIES

4.3.A FAA ADVISORY 

CIRCULARS 

The FAA recommends that public-use 

airport operators implement the 

standards and practices contained in 

all applicable Advisory Circulars (AC). 

Holders of Airport Operating 

Certificates issued under Title 14, 

Code of Federal Regulations (CFR), 

Part 139, Certification of Airports, 

Subpart D (Part 139), may use the standards, practices, and recommendations 

contained in an AC to comply with the airport management requirements of Part 139. In 

general, airports that have received federal grant-in-aid assistance must use the 

standards presented in an AC. See Appendix C for copies of the current version (as of 

July 2005) of AC mentioned in this Manual. AC are revised on an irregular schedule. 

Copies of revised AC can be accessed at: http://www.faa.gov/arp/ 

This engine on an A320 ingested a great blue heron

on departure from a western USA airport in 2002.

The pilot observed the bird just prior to impact. The

aircraft made an emergency landing with the engine

out. The engine and nose cowl were replaced. The

runway was closed for 38 minutes while fire trucks

washed the debris from the runway (photo courtesy

S. Gordon). 

4.3.A.I 150/5200-32A. REPORTING WILDLIFE AIRCRAFT STRIKES. 

This AC explains the importance of reporting wildlife strikes. It also examines recent 

improvements in the FAA’s Bird/Other Wildlife Strike Reporting system, how to report a 

wildlife strike, what happens to the wildlife strike report data, how to access the FAA 

National Wildlife Aircraft Strike Database, and the FAA’s Feather Identification Program. 

4.3.A.II 150/5200-33A. HAZARDOUS WILDLIFE ATTRACTANTS ON OR NEAR 

AIRPORTS. 

This AC provides guidance on locating certain land uses having the potential to attract 

hazardous wildlife to or in the vicinity of public-use airports. It also provides guidance 

on the placement of new airport development projects (including airport construction, 

expansion, and renovation) pertaining to aircraft movement in the vicinity of hazardous 
40 Regulations and Policies Chapter 4 

wildlife attractants. 

4.3.A.III 150/5200-34. CONSTRUCTION OR ESTABLISHMENT OF LANDFILLS NEAR 

PUBLIC AIRPORTS. 

This AC provides guidance on meeting the requirements of Section 503 of the Wendell 

H. Ford Aviation Investment and Reform Act for the 21st Century (Public Law 106–181) 

(AIR 21), which prohibits the construction or establishment of a new Municipal Solid 

Waste Landfill within 6 statute miles of certain public-use airports. Before these 

prohibitions apply, both the airport and the landfill must meet very specific conditions. 

These restrictions do not apply to 

airports or landfills located within the 

state of Alaska (see § 5.3.A.I of this 

manual). 

4.3.B FAA, AIRPORTS: AIRPORT 

CERTIFICATION PROGRAM POLICIES 

AND GUIDANCE 

Program Policies and Guidance 

documents provide FAA personnel 

with interpretations of and directions 

for applying various aspects of federal 

regulations related to aviation safety. 

See Appendix D for Program Policies 

and Guidance related to airport wildlife 

management. 

4.3.B.I POLICY NO. 77. INITIATION 

OF WILDLIFE HAZARD ASSESSMENTS 

AT AIRPORTS. 

Between 1990 and 2003, vultures were involved in

374 reported wildlife strikes to US civil aircraft; 219

(59%) of those strikes caused damage to the aircraft.

Vultures readily feed at landfills (photo by M.

Colunga, Aeropuertos y Servicios Auxiliares). 

This policy establishes the procedures for FAA Airport Certification Safety Inspectors to 

follow when it is determined that an airport needs to conduct a Wildlife Hazard 

Assessment to address an airport wildlife hazard. 

4.3.B.II POLICY NO. 78. SECTION 7 CONSULTATION ON ENDANGERED OR 

THREATENED SPECIES. 

This policy establishes the procedures for coordinating and documenting FAA 

compliance with the Endangered Species Act when requiring an airport operator to 

develop, submit for approval, and implement a Wildlife Hazard Management Plan. 

4.3.B.III POLICY NO. 79. REVIEW OF AIRPORT WILDLIFE HAZARD MANAGEMENT 

PLANS. 

This policy establishes the procedures to be followed when an incident occurs that 

would initiate a Wildlife Hazard Assessment under 14 CFR 139.337(b)(1-4), and directs 

Airport Certification Safety Inspectors to review an airport’s Wildlife Hazard 

Management Plan to ensure that it meets all requirements of 14 CFR 139.337(e) and 

(f), as part of their preparation for a certification inspection. 
Chapter 4 Regulations and Policies 41 

4.3.B.IV POLICY NO. 82. WASTE DISPOSAL FACILITY COORDINATION. 

This policy establishes the procedures for coordinating and documenting FAA 

determinations on developing new, or expanding existing, waste disposal sites within 5 

miles of a public-use airport. 

4.3.C FAA, AIRPORTS, OFFICE 

OF AIRPORT SAFETY AND 

STANDARDS, CERTALERTS 

RELATING TO AIRPORT WILDLIFE 

MANAGEMENT 

Certalerts provide non-directive 

advisory or cautionary information 

dealing with aviation safety to the 

aviation community. See Appendix 

E for Certalerts dealing with aviation 

wildlife hazards. 

4.3.c.I CERTALERT NO. 98-05. 

GRASSES ATTRACTIVE TO 

HAZARDOUS WILDLIFE. 

This Certalert warns airport 

operators against the use of millet 

and any other large-seed producing 

grasses or other plants attractive to hazardous wildlife for revegetation of construction 

sites or other disturbed areas on the airport 

This retention pond, located less than 2,000 feet from the

main runway at a major USA airport, had 3 duck and 1

Canada goose nests when surveyed in 2002 (photo by E.

Cleary, FAA). 

4.3.C.II CERTALERT NO. 04-09. THE RELATIONSHIP BETWEEN FAA AND USDA/WS. 

This Certalert clarifies the roles of and relationship between the Federal Aviation 

Administration (FAA) and the United States Department of Agriculture, Animal and Plant 

Health Inspection Service, Wildlife Services (USDA/WS) with regards to wildlife hazards 

on or near airports. 

4.3.C.III CERTALERT NO 04-16. DEER HAZARDS TO AVIATION AND DEER FENCING. 

In light of recent incidents where a Learjet landing at an airport in Alabama and a 

Learjet departing an airport in Oregon were destroyed after colliding with deer or elk, 

airport operators are reminded of the importance of controlling deer and other wild 

ungulates on and around airfields. 

4.3.D USDA, WILDLIFE SERVICES DIRECTIVE 2.305, WILDLIFE HAZARDS TO 

AVIATION 

This directive provides general guidelines for USDA/WS technical and direct control 

assistance to airport managers, state aviation agencies, aviation industry, FAA, and 

Department of Defense about hazards caused by wildlife to airport safety (Appendix F). 
42 Regulations and Policies Chapter 4 

4.3.E MEMORANDUM OF UNDERSTANDING: FAA AND USDA/WS 

A Memorandum of Understanding 

between the FAA and USDA/WS 

(No. 12-14-71-0003-MOU), 

establishing a cooperative 

relationship between the two 

agencies, has been in effect since 

1989. The FAA relies heavily on the 

assistance of USDA/WS for 

resolving problems involving wildlife 

hazards to aviation at airports 

(Appendix G). 

4.3.F INTERAGENCY 

MEMORANDUM OF AGREEMENT 

The Federal Aviation Administration, 

the U.S. Air Force, the U.S. Army 

Corps of Engineers, the U.S. 

Environmental Protection Agency, 

the U.S. Fish and Wildlife Service, 

and the U.S Department of Agriculture/Wildlife Services signed a Memorandum of 

Agreement (MOA) (finalized July 2003) to acknowledge their respective missions in 

protecting aviation from wildlife hazards. Through the MOA, the agencies established 

procedures necessary to coordinate their missions to address more effectively existing 

and future environmental conditions contributing to collisions between wildlife and 

aircraft (wildlife strikes) throughout the United States. These efforts are intended to 

minimize wildlife risks to aviation and human safety while protecting the Nation’s 

valuable environmental resources (Appendix H). 

A well-maintained fence, at least 10-feet high with no

gaps at the bottom, is the primary defense to keep deer

and other large animals off the airport’s AOA. Deer can

easily jump fences that are only 6 feet high (right)

(photo by R. A. Dolbeer, USDA). 
 43 

CHAPTER 5: 

RECOGNIZING HAZARDOUS WILDLIFE ATTRACTANTS 

 ON OR NEAR AIRPORTS 

A Eurasian crane penetrated the windshield of this Israeli helicopter in March 2003. In the USA,

vultures and waterfowl have been responsible for the most losses of military aircraft to bird strikes. 

5.1 INTRODUCTION

Land-use practices and habitat are the key factors determining the wildlife species and 

the size of wildlife populations that are attracted to airport environments. The 

recognition and control of those land-use practices and habitats on or near airports that 

attract hazardous wildlife are fundamental to effective Wildlife Hazard Management 

Plans. 

The FAA (through Advisory Circular 150/5200-33A, Hazardous Wildlife Attractants on or 

Near Airports, Appendix C) provides guidance on locating certain land uses that have 

the potential to attract hazardous wildlife on or near public-use airports. It also 

discusses airport development projects (including airport construction, expansion, and 

renovation) affecting aircraft movement near hazardous wildlife attractants.
44 Wildlife Attractants Chapter 5 

5.2 SEPARATION CRITERIA FOR HAZARDOUS WILDLIFE ATTRACTANTS ON 

OR NEAR AIRPORTS

The minimum separation criteria outlined below are recommended for land-use 

practices that attract hazardous wildlife to the vicinity of airports. Please note that these 

criteria include land uses that cause movement of hazardous wildlife onto, into, or 

across the approach or departure airspace, air operation area (AOA), loading ramps, or 

aircraft parking area of airports. 

The basis for the separation criteria 

contained in this section can be 

found in existing FAA regulations. 

The separation distances are based 

on (1) flight patterns of pistonpowered aircraft and turbinepowered aircraft, (2) the altitude at 

which most strikes happen (81 

percent occur under 1,000 feet and 

92 percent occur under 3,000 feet 

above ground level), and (3) 

National Transportation Safety 

Board (NTSB) recommendations. 

The recommended separation 

distances are diagramed in 

Figure-5-1. 

5.2.A AIRPORTS SERVING 

PISTON-POWERED AIRCRAFT

Airports that do not sell Jet-A fuel 

normally serve piston-powered 

aircraft. Notwithstanding more stringent requirements for specific land uses, a minimum 

separation distance of 5,000 feet is recommended at these airports for known 

hazardous wildlife attractants or for new airport development projects meant to 

accommodate aircraft movement. This distance is to be maintained between an 

airport’s AOA, loading ramps, and aircraft parking areas and the hazardous wildlife 

attractant. Figure 5-1 depicts this separation distance measured from the nearest AOA. 

Piston engines are not as susceptible to bird-strike

damage as turbine engines. However, other parts of

piston-powered aircraft can be severely damaged. This

Rockwell Commander, flying at 1,500 feet AGL and 130

knots, struck a large bird. This was the second

damaging bird strike this aircraft had suffered in less

than 10 years (photo courtesy B. McKinnon, Transport

Canada). 

5.2.B AIRPORTS SERVING TURBAN-POWERED AIRCRAFT

Airports selling Jet-A fuel normally serve turbine-powered aircraft. Notwithstanding 

more stringent requirements for specific land uses, a minimum separation distance of 

10,000 feet is recommended at these airports for known hazardous wildlife attractants 

or for new airport development projects meant to accommodate aircraft movement. 

This distance is to be maintained between an airport’s AOA, loading ramps, and aircraft 

parking areas and the hazardous wildlife attractant. Figure 5-1 depicts this separation 

distance measured from the nearest AOA. 
Chapter 5 Wildlife Attractants 45 

5.2.C PROTECTION OF APPROACH OR DEPARTURE AIRSPACE 

For all airports, a minimum separation distance of 5 statute miles is recommended 

between the farthest edge of the airport’s AOA and known hazardous wildlife attractant 

if the attractant could cause hazardous wildlife movement into or across the approach or 

departure airspace. Figure 5-1 depicts this separation distance measured from the 

nearest AOA. 

5.3 LAND-USE PRACTICES THAT POTENTIALLY ATTRACT HAZARDOUS 

WILDLIFE

The wildlife species and the size of the 

populations attracted to the airport 

environment vary considerably, 

depending on several factors, including 

land-use practices on or near the 

airport. This section discusses landuse practices having the potential to 

attract hazardous wildlife and threaten 

aviation safety. 

5.3.A WASTE DISPOSAL 

OPERATIONS

Municipal solid waste landfills (MSWLF) 

are known to attract large numbers of 

hazardous wildlife, particularly birds. 

Because of this, these operations, when 

located within the separations identified 

in the siting criteria in AC 150/5200-33A 

(see above and Appendix C), are 

considered incompatible with safe airport operations. 

Because most agricultural crops attract birds at some

point during their production cycle, the FAA

recommends against allowing farming on airport

property (photo by R. DeFusco, BASH, Inc.). 

5.3.A.I SITING NEW MUNICIPAL SOLID WASTE LANDFILLS SUBJECT TO AIR 21 

Section 503 of the Wendell H. Ford Aviation Investment and Reform Act for the 21st 

Century (Public Law 106–181) (AIR 21) prohibits the construction or establishment of a 

new MSWLF within 6 statute miles of certain public-use airports. Before these 

prohibitions apply, both the airport and the landfill must meet the very specific conditions 

described below. These restrictions do not apply to airports or landfills located within 

Alaska. 
46 Wildlife Attractants Chapter 5 

PERIMETER A

PERIMETER B

Apron Parking 

Area

Runway

Taxiway Runway

Taxiway

PERIMETER C

Perimeter A: 

For airports serving piston-powered aircraft, hazardous wildlife attractants must be 5,000 feet from the 

nearest air operations area. 

Perimeter B: 

For airports serving turbine-powered aircraft, hazardous wildlife attractants must be 10,000 feet from the

nearest air operations area.

Perimeter C: 

5-mile range to protect approach, departure, and circling airspace. 

Figure 5-1. Separation distances within which hazardous wildlife attractants should be avoided, 

eliminated, or mitigated. 
Chapter 5 Wildlife Attractants 47 

The airport must (1) have received a federal grant(s) under 49 U.S.C. § 47101, et. seq.; 

(2) be under control of a public agency; (3) serve some scheduled air carrier operations 

conducted in aircraft with less than 60 seats; and (4) have total annual enplanements 

consisting of at least 51 percent of scheduled air carrier enplanements conducted in 

aircraft with less than 60 passenger seats. 

The proposed MSWLF must (1) be within 6 miles of the airport, as measured from 

airport property line to MSWLF property line, and (2) have started construction or 

establishment on or after April 5, 2001. Public Law 106–181 only limits the construction 

or establishment of some new 

MSWLF. It does not limit the 

expansion, either vertical or 

horizontal, of existing landfills. 

Consult the most recent version of AC 

150/5200-34, Construction or 

Establishment of Landfills Near Public 

Airports (Appendix C), for a more 

detailed discussion of these 

restrictions. 

5.3.A.II SITING NEW MUNICIPAL 

SOLID WASTE LANDFILLS NOT 

SUBJECT TO AIR 21 

If an airport and MSWLF do not meet 

the restrictions of Public Law 106–

181, do not locate new MSWLF within 

the separation distances identified in 

AC 150/5200-33A (see above and 

Appendix C). Measure the separation 

distances from the closest point of the airport’s AOA to the closest planned MSWLF cell. 

It is widely recognized that open-faced, putrescible

waste landfills attract gulls. However, these landfills

also attract other birds hazardous to aviation. Over

5,000 starlings were counted at this Midwestern USA

landfill (photo by E. Cleary, FAA). 

5.3.A.III CONSIDERATIONS FOR EXISTING WASTE DISPOSAL FACILITIES WITHIN THE 

LIMITS OF SEPARATION CRITERIA 

Do not locate airport development projects that would increase the number of aircraft 

operations or accommodate larger or faster aircraft near MSWLF operations within the 

separations identified in AC 150/5200-33A (see above and Appendix C). In addition, in 

accordance with 40 CFR 258.10, owners or operators of existing MSWLF units that are 

located within the separations listed in AC 150/5200-33A (see above and Appendix C) 

must demonstrate that the unit is designed and operated so it does not pose a bird 

hazard to aircraft. 

To claim successfully that a waste-handling facility sited within the separations identified 

in AC 150/5200-33A (see above and Appendix C) does not attract hazardous wildlife 

and does not threaten aviation, the developer must establish convincingly that the 

facility will not handle putrescible material other than in fully enclosed transfer stations 

(see 5.4.b, below). 

In their effort to satisfy the EPA requirement, some putrescible-waste facility proponents 
48 Wildlife Attractants Chapter 5 

might offer to undertake experimental measures to demonstrate that their proposed 

facility will not be a hazard to aircraft. To date, no such facility has been able to 

demonstrate an ability to reduce and sustain hazardous wildlife to levels that existed 

before the putrescible-waste landfill began operating. For this reason, the FAA does not 

consider the demonstration of experimental wildlife control at putrescible-waste landfills 

within the separation distances specified in AC 150/5200-33A to be an acceptable 

alternative to locating the landfill beyond the separation distances. 

5.3.B TRASH TRANSFER STATIONS 

Enclosed waste-handling facilities that receive garbage behind closed doors; process it 

via compaction, incineration, or similar manner; and remove all residue by enclosed 

vehicles generally are compatible with 

safe airport operations, provided they 

are not located on airport property or 

within the Runway Protection Zone 

(RPZ). Do not handle or store 

putrescible waste outside or in a 

partially enclosed structure accessible 

to hazardous wildlife at these facilities. 

Trash transfer facilities that leave the 

main doors open during normal 

operations, are open on one or more 

sides, that temporarily store uncovered 

quantities of municipal solid waste 

outside, that use semi-trailers that leak 

or have trash clinging to the outside, or 

that do not control odors by ventilation 

and filtration systems (odor masking is 

not acceptable) do not meet the FAA’s 

definition of fully enclosed trash 

transfer stations. The FAA considers 

these facilities incompatible with safe airport operations if they are located closer than 

the separation distances specified in AC 150/5200-33A (see above and Appendix C). 

Open-sided trash transfer stations attract gulls,

starlings, and other birds that can pose a hazard to

aviation safety. Any waste-management facility that

has exposed putrescible waste must not be located

closer to an airport than the separation distance

specified in AC 150/5200-33A (Appendix C) (photo

by L. Henze, USDA). 

5.3.C COMPOSTING OPERATIONS ON OR NEAR AIRPORT PROPERTY 

Composting operations that accept only yard waste (e.g., leaves, lawn clippings, or 

branches) generally do not attract hazardous wildlife. Sewage sludge, woodchips, and 

similar material are not municipal solid wastes and may be used as compost bulking 

agents. The compost, however, must never include food or other municipal solid waste. 

Do not locate composting operations on airport property. Do not locate off-airport 

property composting operations closer than the greater of the following distances: 1,200 

feet from any AOA, loading ramp, or aircraft parking space or the distance called for by 

airport design requirements (see AC 150/5300-13, Airport Design). This spacing is 

meant to prevent material, personnel, or equipment from penetrating any Object Free 

Area (OFA), Obstacle Free Zone (OFZ), Threshold Siting Surface (TSS), or Clearway. 

Monitor composting operations located in proximity to the airport to ensure that steam or 
Chapter 5 Wildlife Attractants 49 

thermal rise does not adversely affect air traffic. On-airport disposal of compost byproducts is not recommended. 

5.3.D UNDERWATER WASTE DISCHARGES

The underwater discharge of any food waste (e.g., fish processing offal) within the 

separations identified in AC 150/15200-33A (see above and Appendix C) is not 

recommended because it could attract scavenging hazardous wildlife. 

5.3.E RECYCLING CENTERS

Recycling centers that accept previously sorted non-food items, such as glass, 

newspaper, cardboard, or aluminum, are, in most cases, not attractive to hazardous 

wildlife and are acceptable. 

5.3.F CONSTRUCTION AND DEMOLITION DEBRIS FACILITIES

 

Small recycling bins and compactor stations, properly maintained so that putrescible waste is covered

at all times, are generally not attractive to birds (photos by E. Cleary, FAA). 

Construction and demolition debris (C&D) landfills do not generally attract hazardous 

wildlife and are acceptable if maintained in an orderly manner, admit no putrescible 

waste, and are not co-located with other putrescible waste disposal operations. C&D 

landfills have similar visual and operational characteristics to putrescible waste disposal 

sites. When co-located with putrescible waste disposal operations, C&D landfills are 

more likely to attract hazardous wildlife because of the similarities between these 

disposal facilities. Site C&D landfills co-located with other putrescible waste disposal 

operations outside of the separations identified in AC 150/5200-33A (see above and 

Appendix C). 

5.3.G FLY ASH DISPOSAL

The incinerated residue from resource recovery power/heat-generating facilities that are 

fired by municipal solid waste, coal, or wood is generally not a wildlife attractant 

because it no longer contains putrescible matter. Landfills accepting only fly ash are 

generally not considered to be wildlife attractants and are acceptable as long as they 

are maintained in an orderly manner, admit no putrescible waste of any kind, and are 

not co-located with other disposal operations that attract hazardous wildlife. 
50 Wildlife Attractants Chapter 5 

Since varying degrees of waste 

consumption are associated with general 

incineration (not resource recovery 

power/heat-generating facilities), the FAA 

considers the ash from general incinerators 

a regular waste disposal by-product and, 

therefore, a hazardous wildlife attractant if 

disposed of within the separation criteria 

outlined in AC 150/5200-33A (see above 

and Appendix C). 

5.4 WATER MANAGEMENT 

FACILITIES

Drinking water intake and treatment 

facilities, storm water and wastewater 

treatment facilities, associated retention and 

settling ponds, ponds built for recreational 

use, and ponds that result from mining 

activities often attract large numbers of potentially hazardous wildlife. To prevent 

wildlife hazards, land-use developers and airport operators might need to develop 

management plans, in compliance with local and state regulations, to support the 

operation of storm water management facilities on or near public-use airports to ensure 

a safe airport environment. 

Water detention basins at airports, such as

this French-drain system at an eastern US

5.4.A EXISTING STORM WATER MANAGEMENT FACILITIES

On-airport storm water management facilities allow the quick removal of surface water, 

including discharges related to aircraft 

deicing, from impervious surfaces, such as 

pavement and terminal/hangar building roofs. 

Existing on-airport detention ponds collect 

storm water, protect water quality, and control 

runoff. Because they slowly release water 

after storms, they create standing bodies of 

water that can attract hazardous wildlife. 

Using appropriate wildlife hazard mitigation 

techniques, airport management should take 

immediate corrective actions to address any 

wildlife hazards arising from existing storm 

water or other such facilities located on or 

near an airport (14 CFR 139.337 (a)). 

Develop measures to minimize hazardous 

wildlife attraction in consultation with a wildlife 

damage management biologist. 

Where possible, modify storm water detention ponds to allow a maximum 48-hour 

detention period for the design storm. Avoid or remove retention ponds and detention 

ponds featuring long-term storage to eliminate standing water. Design or modify 

A

airport, should be designed to completely drain

within 48 hours after the design storm event

(photo by R. A. Dolbeer, USDA). 

This storm water basin was designed to drain

within 48 hours following a major storm event

(the design storm). The rip-rap lining helps

prevent vegetation growth and bird use of the

pond (photo courtesy FAA). 
Chapter 5 Wildlife Attractants 51 

detention basins to remain totally dry between rainfalls. Where constant flow of water is 

anticipated through the basin, or where any portion of the basin bottom may remain wet, 

include a concrete or paved pad and/or ditch/swale in the bottom to prevent vegetation 

that may provide cover and food for wildlife. 

When it is not possible to drain a large detention pond completely, use physical barriers, 

such as bird balls, wires grids, pillows, or netting, to deter birds and other hazardous 

wildlife. When physical barriers are used, carefully evaluate their use and ensure they 

will not adversely affect water rescue. Before installing any physical barriers over 

detention ponds on Part 139 airports, get 

approval from the appropriate FAA Regional 

Airports Division Office. 

Encourage off-airport storm water treatment 

facility operators to incorporate appropriate 

wildlife hazard mitigation techniques into storm 

water treatment facility operating practices when 

their facility is located within the separation 

criteria specified in AC 150/5200-33A (see 

above and Appendix C). 

5.4.B NEW STORM WATER MANAGEMENT 

FACILITIES

Design and operate off-airport storm water 

management systems located within the 

separations identified in AC 150/5200-33A (see 

above and Appendix C) so as not to create 

above-ground standing water. Design, engineer, 

construct, and maintain on-airport storm water 

detention ponds for a maximum 48–hour 

detention period for the design storm and so the 

ponds remain completely dry between storms. 

Use steep-sided, narrow, linearly shaped water 

detention basins to facilitate the control of 

hazardous wildlife. When it is not possible to 

place these ponds away from the AOA, use 

physical barriers, such as bird balls, wires grids, 

pillows, or netting, to prevent access of hazardous wildlife to open water and minimize 

aircraft-wildlife interactions. When physical barriers are used, carefully evaluate their 

use and ensure they will not adversely affect water rescue. Before installing any 

physical barriers over detention ponds on Part 139 airports, get approval from the 

appropriate FAA Regional Airports Division Office. Eliminate all vegetation in or around 

detention basins that provides food or cover for hazardous wildlife. If soil conditions and 

other requirements allow, use underground storm water infiltration systems, such as 

French drains or buried rock fields, because they are less attractive to wildlife. 

Floating plastic balls can be used to

cover ponds and prevent birds from

using the site. FAA approval is required

before physical barriers may be used

over ponds at certificated airports (photo

courtesy Wildlife Materials, Inc.). 
52 Wildlife Attractants Chapter 5 

5.4.C EXISTING WASTEWATER TREATMENT FACILITIES

Immediately correct any wildlife 

hazards arising from existing 

wastewater treatment or similar 

facilities located on or near the 

airport (14 CFR 139.337). 

Encourage wastewater treatment 

facility operators to incorporate 

measures, developed in 

consultation with a wildlife damage 

management biologist, to minimize 

hazardous wildlife attractants. 

Encourage wastewater treatment 

facility operators to incorporate 

these mitigation techniques into 

their standard operating practices. 

In addition, consider the existence 

of wastewater treatment facilities 

when evaluating proposed sites for 

new airport development projects and avoid such sites when practicable. 

In tropical regions, cattle egrets appear to fill the

ecological niche occupied by gulls at waste

management facilities in North America. Over 13,000

cattle egrets were seen at this sewage treatment and

landfill complex near Mexico City (photo by E. Cleary,

FAA). 

5.4.D NEW WASTEWATER TREATMENT FACILITIES 

Do not construct new wastewater treatment facilities or associated settling ponds within 

the separations identified in AC 150/15200-33A (see above and Appendix C). 

Wastewater treatment facilities are “any devices and/or systems used to store, treat, 

recycle, or reclaim municipal sewage or liquid industrial wastes.” The definition includes 

any pretreatment involving the reduction of the amount of pollutants or the elimination of 

pollutants prior to introducing such pollutants into a publicly owned treatment works 

(wastewater treatment facility). Consider the potential to attract hazardous wildlife 

during the site-location analysis for wastewater treatment facilities if an airport is in the 

vicinity of the proposed site. Oppose such facilities if they are within the separations 

identified in AC 150/5200-33A (see above and Appendix C). 

5.4.E ARTIFICIAL MARSHES

In warmer climates, wastewater treatment facilities sometimes employ artificial marshes 

and use submergent and emergent aquatic vegetation as natural filters. These artificial 

marshes may be used by various species of birds, such as blackbirds and waterfowl, for 

nesting, feeding, or roosting. Do not establish artificial marshes within the separations 

identified in AC 150/5200-33A (see above and Appendix C). 
Chapter 5 Wildlife Attractants 53 

5.4.F WASTEWATER DISCHARGE AND SLUDGE DISPOSAL

Do not discharge of wastewater or sludge on airport property because it may improve 

soil moisture and quality on unpaved areas and lead to improved turf growth that can be 

an attractive food source for many species of animals. Also, the turf requires more 

frequent mowing, which in turn might mutilate or flush insects or small animals and 

produce thatch, both of which can attract hazardous wildlife. In addition, the improved 

turf might attract grazing wildlife, such as deer and geese. Problems might also occur 

when discharges saturate unpaved airport areas. The resultant soft, muddy conditions 

can severely restrict or prevent emergency vehicles from reaching accident sites in a 

timely manner. 

5.5 WETLANDS

Wetlands provide a variety of functions and can be regulated by local, state, and federal 

laws. Wetlands typically attract diverse species of wildlife, including many that rank 

high on the list of hazardous wildlife 

species (Table 7-1). 

This photo is from a National Wildlife Refuge located

adjacent to a major USA airport (note air traffic

control tower in background). These incompatible

land uses were established years ago, before the

FAA had set minimum separation distances. In this

type of situation, both the airport manager and the

refuge manager must be extra vigilant and ready to

respond to rapidly developing wildlife hazard

If questions exist as to whether an 

area qualifies as a wetland, contact the 

local division of the U.S. Army Corps of 

Engineers, the Natural Resources 

Conservation Service, or a wetland 

consultant qualified to delineate 

wetlands. A MOA among six federal 

agencies was signed in 2003 

(Appendix H) to facilitate, among other 

things, resolution of wetland 

management issues at airports without 

compromising aviation safety related to 

wildlife hazards. 

5.5.A EXISTING WETLANDS ON OR 

NEAR AIRPORT PROPERTY 

conditions (photo by E. Cleary, FAA). 

If wetlands are located on or near 

airport property, be alert to any wildlife 

use or habitat changes in these areas 

that could affect safe aircraft 

operations. At public-use airports, 

immediately correct, in cooperation with local, state, and federal regulatory agencies, 

any wildlife hazards arising from existing wetlands located on or near airports. Where 

required, a Wildlife Hazard Management Plan (WHMP) will outline appropriate wildlife 

hazard mitigation techniques. Develop measures to minimize hazardous wildlife 

attraction in consultation with a wildlife damage management biologist. 
54 Wildlife Attractants Chapter 5 

5.5.B NEW AIRPORT DEVELOPMENT

Whenever possible, locate new airports using the separations from wetlands identified 

in AC 150/5200-33A (see above and Appendix C). Where alternative sites are not 

practicable, or when expanding an existing airport into or near wetlands, in consultation 

with a wildlife damage management biologist, the U.S. Fish and Wildlife Service, the 

U.S. Army Corps of Engineers, and the state wildlife management agency, evaluate the 

wildlife hazards and prepare a WHMP that indicates methods of minimizing the hazards. 

5.5.C MITIGATION FOR WETLAND IMPACTS FROM AIRPORT PROJECTS

Wetland mitigation might be necessary 

when wetland disturbances result from 

new airport development projects or 

projects required to correct wildlife 

hazards from wetlands. Wetland 

mitigation must be designed so it does 

not create a wildlife hazard. Locate 

wetland mitigation projects that may 

attract hazardous wildlife outside of the 

separations identified in AC 150/5200-

33A (see above and Appendix C). 

5.5.C.I ON-SITE MITIGATION OF 

WETLAND FUNCTIONS

The FAA may consider exceptions to 

locating mitigation activities outside the 

separations identified in AC 150/5200-

33A (see above and Appendix C) if the 

affected wetlands provide unique 

ecological functions, such as critical 

habitat for threatened or endangered 

species or ground water recharge, 

which cannot be replicated when moved to a different location. Using existing airport 

property is sometimes the only feasible way to achieve the mitigation ratios mandated in 

regulatory orders and settlement agreements with the resource agencies. Conservation 

easements are an additional means of providing mitigation for project impacts. 

Typically the airport operator continues to own the property, and an easement is created 

stipulating that the property will be maintained as habitat for state or federally listed 

species. 

This water body at a major west coast USA airport

should be removed because it provides ideal habitat

for waterfowl and wading birds hazardous to aircraft.

However, the water has also been designated as

critical habitat for the endangered Riverside fairy

shrimp. Airports must work closely with multiple

federal and state agencies to resolve such conflicts

(Photo by T. Pitlik, USDA) 

Mitigation must not inhibit the airport operator’s ability to effectively control hazardous 

wildlife on or near the mitigation site or effectively maintain other aspects of safe airport 

operations. Avoid enhancing such mitigation areas to attract hazardous wildlife. The 

FAA may review any onsite mitigation proposals to determine compatibility with safe 

airport operations. In cooperation with a wildlife damage management biologist, 

evaluate any wetland mitigation projects that are needed to protect unique wetland 

functions and that must be located in the separation criteria in AC 150/5200-33A (see 
Chapter 5 Wildlife Attractants 55 

above and Appendix C) before the mitigation is implemented. Develop a WHMP to 

reduce any identified wildlife hazards. 

5.5.C.II OFF-SITE MITIGATION OF WETLAND FUNCTIONS

Site wetland mitigation projects that might attract hazardous wildlife outside of the 

separations identified in AC 150/5200-33A (see above and Appendix C) unless they 

provide unique functions that must remain onsite (see 2-4c(1)). Agencies that regulate 

impacts to or around wetlands recognize that it might be necessary to split wetland 

functions in mitigation schemes. Therefore, regulatory agencies may, under certain 

circumstances, allow portions of mitigation to take place in different locations. 

5.5.C.III MITIGATION BANKING

Wetland mitigation banking is the creation or restoration of wetlands in order to provide 

mitigation credits that can be used to offset permitted wetland losses. Mitigation 

banking benefits wetland resources by providing advance replacement for permitted 

wetland losses; consolidating small projects into larger, better-designed and managed 

units; and encouraging integration of wetland mitigation projects with watershed 

planning. This last benefit is most 

helpful for airport projects, as wetland 

impacts mitigated outside of the 

separations identified in AC 150/5200-

33A (see above and Appendix C) can 

still be located within the same 

watershed. Wetland mitigation banks 

meeting the separation criteria offer an 

ecologically sound approach to 

mitigation in these situations. Working 

with local watershed management 

agencies or organizations, develop 

mitigation banking for wetland impacts 

on airport property. See Appendix M 

for a more detailed discussion of this 

issue. 

5.6 DREDGE SPOIL 

CONTAINMENT AREAS

Do not locate dredge spoil containment 

areas (also known as Confined Disposal Facilities) within the separations identified in 

AC 150/5200-33A (see above and Appendix C) if the containment area has standing 

water or the spoils contain material that would attract hazardous wildlife. 

During the first winter following its completion, over

20,000 Bonaparte's gulls used this dredge spoil

containment area (far right of photo) constructed next

to an airport on Lake Erie's shoreline. The airport’s

main runway can be seen to the left (photo by E.

Cleary, FAA). 

5.7 AGRICULTURAL ACTIVITY

5.7.A CROP PRODUCTION

Because most, if not all, agricultural crops can attract hazardous wildlife during some 

phase of production, do not use airport property for crop production, including hay 
56 Wildlife Attractants Chapter 5 

crops, within the separations identified in AC 150/5200-33A (see above and Appendix 

C). 

If the airport has no financial alternative to agricultural crops to produce income 

necessary to maintain the viability of the airport, then the airport must follow the crop 

distance guidelines listed in the table titled "Minimum Distances between Certain Airport 

Features and Any On-Airport Agricultural Crops" found in AC 150/5300-13, Airport 

Design, Appendix 19. Avoid production of cereal grains and sunflowers. Weigh the 

cost of wildlife control and potential accidents against the income produced by the onairport crops when deciding whether to allow crops on the airport. 

5.7.B LIVESTOCK PRODUCTION 

Confined livestock operations (i.e., feedlots, dairy operations, hog or chicken production 

facilities, or egg-laying operations) often attract flocking birds, such as starlings, that 

pose a hazard to aviation. Therefore, keep such facilities outside of the separations 

identified in AC 150/5200-33A (see 

above and Appendix C). Develop 

a program to reduce the 

attractiveness of any livestock 

operation within these separations. 

Do not graze free-ranging livestock 

on airport property because the 

animals might wander onto the 

AOA. Livestock feed, water, and 

manure might attract hazardous 

birds. 

5.7.C AQUACULTURE

Aquaculture activities (e.g., catfish, 

trout, bait fish production) 

conducted outside of fully 

enclosed buildings are inherently 

attractive to a variety of birds. 

Existing aquaculture 

facilities/activities within the 

separations listed in AC 150/5200-33A (see above and Appendix C) must have a 

program developed to reduce the attractiveness of the sites to species that are 

hazardous to aviation safety. Oppose the establishment of new aquaculture 

facilities/activities within the separations listed in AC 150/5200-33A (see above and 

Appendix C). 

Various fish-eating birds are attracted to aquaculture

facilities as demonstrated by these great egrets at a

southern USA catfish pond complex. Attempts to repel

the birds using propane exploders failed because the

birds habituated to the sound (photo by D. LeBlanc,

USDA). 

5.7.D ALTERNATIVE USES OF AGRICULTURAL LAND

Some airports are surrounded by vast areas of farmed land within the distances 

specified in AC 150/5200-33A (see above and Appendix C). Seasonal uses of these 

agricultural lands for activities such as waterfowl hunting can create a hazardous wildlife 

situation. Rice farmers, for example, might flood their land during waterfowl hunting 

season and obtain additional revenue by renting out duck blinds. The duck hunters, 
Chapter 5 Wildlife Attractants 57 

using decoys and calls, draw in large numbers of birds, creating a threat to aircraft 

safety. It is recommended that a wildlife damage management biologist review, in 

coordination with local farmers and airport management, these types of seasonal land 

uses. Restrictions to seasonal land uses that are incompatible with aviation safety 

should be incorporated into the WHMP. 

5.8 GOLF COURSES, LANDSCAPING, AND OTHER LAND-USE 

CONSIDERATIONS

5.8.A GOLF COURSES 

The large grassy areas and open water found on most golf courses are attractive to 

hazardous wildlife, particularly Canada geese, mallards, and gulls. These species can 

pose a threat to aviation safety. Do not site new golf courses within the separations 

identified in AC 150/5200-33A (see above and Appendix C). Existing golf courses 

located within these separations must develop a program to reduce the attractiveness of 

the sites to species that are hazardous to aviation safety. Ensure these golf courses 

are monitored on a continuing basis for the presence of hazardous wildlife. If 

hazardous wildlife is detected, take 

corrective actions immediately. 

5.8.B LANDSCAPING AND 

LANDSCAPE MAINTENANCE 

Depending on geographic location and 

plant selection and spacing, airport 

landscaping can attract hazardous 

wildlife. Approach landscaping with 

caution, and confine it to airport areas 

not associated with aircraft 

movements. In cooperation with a 

wildlife damage management biologist, 

review all landscaping plans. Monitor 

all landscaped areas on a continuing 

basis for the presence of hazardous 

wildlife. If hazardous wildlife is 

detected, take corrective actions 

immediately. 

Turf grass areas can be highly 

attractive to a variety of hazardous 

wildlife species. Research conducted by the USDA/WS National Wildlife Research 

Center has shown that no one grass management regime will deter all species of 

hazardous wildlife in all situations. In cooperation with a wildlife damage management 

biologist, develop airport turf grass management plans on a prescription basis, 

depending on the airport’s geographic location and the type of hazardous wildlife likely 

to frequent the airport. See Chapter 9 and Appendix O for more information on 

vegetation management. 

Trees and shrubs that produce fruits that are

attractive to birds, such as these pyracanthas at a

western USA airport, should not be used in

Dense stands

of evergreen trees also should be avoided as the

landscape designs on airport property. 

y

provide ideal roosting sites for flocks of starlings and

blackbirds (photo by R. A. Dolbeer, USDA). 
58 Wildlife Attractants Chapter 5 

Ensure that plant varieties attractive to hazardous wildlife are not used on the airport. 

Do not plant disturbed areas or areas in need of re-vegetating with seed mixtures 

containing millet or any other large-seed producing grass. Prevent plant maturation and 

seed head production on airport property already planted with seed mixtures containing 

millet, rye grass, or other large-seed producing grasses by the use of disking, plowing, 

or another suitable agricultural practice. Follow the specific recommendations for grass 

management and seed and plant selection made by the State University Cooperative 

Extension Service, the local office of USDA/Wildlife Services, or a qualified wildlife 

damage management biologist. Consider developing and implementing a 

preferred/prohibited plant species list, reviewed by a wildlife damage management 

biologist, which has been designed for the geographic location to reduce the 

attractiveness to hazardous wildlife for landscaping airport property. Avoid installation 

of ponds, fountains, reflecting pools, and other water bodies as part of an airport’s 

landscaping scheme. 

5.8.C OTHER HAZARDOUS WILDLIFE ATTRACTANTS

Other specific land uses or activities (e.g., sport or commercial fishing, shellfish 

production or harvesting), perhaps unique to certain regions, have the potential to 

attract hazardous wildlife. Regardless of the source of the attraction, when hazardous 

wildlife is noted on a public-use airport, airport operators must take prompt remedial 

action to protect aviation safety. 

5.9 SYNERGISTIC EFFECTS 

OF SURROUNDING LAND USES

There might be circumstances where 

two (or more) different land uses that 

would not, by themselves, be 

considered hazardous wildlife 

attractants or that are located outside 

of the separations identified in AC 

150/5200-33A (see above and 

Appendix C) that are in such an 

alignment with the airport as to create 

a wildlife corridor directly through the 

airport and/or surrounding airspace. 

An example of this situation might 

involve a lake located outside of the 

separation criteria on the east side of 

an airport and a large hayfield on the 

west side of an airport—land uses that 

together could create a flyway for 

Canada geese directly across the 

airspace of the airport. There are numerous examples of such situations; therefore, 

airport operators and the wildlife damage management biologist must consider the 

entire surrounding landscape and community when developing the WHMP. 

This open dumpster at a park 0.5 mile from a west

coast USA airport served as a strong attractant for

gulls, pigeons, and crows. Airports must work with

surrounding landowners and local governments to

prevent bird attractants near airports (photo by R. A.

Dolbeer, USDA). 
 59 

CHAPTER 6: 

DEVELOPING WILDLIFE HAZARD MANAGEMENT 

PROGRAMS AT AIRPORTS 

The pilot of this Cessna 172 made a Mayday call to a nearby Air Traffic Control Tower in Texas after

hitting a bird (likely a vulture) with the left wing at 800 feet AGL on 8 July 2003. The pilot attempted

to make an emergency landing in a field but lost control and crashed, killing him and his passenger

(photo courtesy of FAA). 

6.1 INTRODUCTION

In recognition of the increased risk of serious aircraft damage or the loss of human life 

that can result from a wildlife strike, greater emphasis is being placed on preparing 

airport Wildlife Hazard Management Plans that effectively deal with the problem. This 

heightened awareness and increased effort has raised many questions about the 

preparation and content of an FAA-approved Wildlife Hazard Management Plan for an 

airport. The specific events that trigger a Wildlife Hazard Assessment and the specific 

issues that a Wildlife Hazard Management Plan must address for FAA approval and 

inclusion in the airport’s Airport Certification Manual (ACM)
60 Developing Control Programs Chapter 6 

 are described in 14 CFR 139.337 (Appendix P). 

It is important to note that regardless of whether a Wildlife Hazard Assessment has ever 

been required or a Wildlife Hazard Management Plan has been developed, airport 

operators must be ready to deal with hazardous wildlife on or near the airport. The 

airport operator must be prepared to take immediate action to deal with unexpected 

incursions of hazardous wildlife into the AOA, loading ramps, or parking areas (14 CFR 

139.337(a)). 

14 CFR 139.337 Comments 

(a). In accordance with its Airport

Certification Manual and the requirements 

of this section, each certificate holder shall 

take immediate action to alleviate wildlife 

hazards whenever they are detected. 

Public-use airport operators need to be 

aware of any hazardous wildlife 

attractants on or near their airport, even 

if a wildlife strike has never been 

reported from the airport. Airport 

personnel need at least a minimal 

understanding of wildlife hazard control 

issues. 

6.2 WILDLIFE HAZARD ASSESSMENT

The Air Traffic Control (ATC) Tower is a

good place to start a Wildlife Hazard

Assessment. The tower presents an

excellent overview of the airport and

provides an opportunity to talk to ATC

personnel about wildlife they have seen on

the airport (photo by A. Gosser, USDA). 

The first step in preparing an airport Wildlife 

Hazard Management Plan is to conduct a 

Wildlife Hazard Assessment. The Wildlife 

Hazard Assessment, conducted by a wildlife 

damage management biologist, provides the 

scientific basis for the development, 

implementation, and refinement of a Wildlife 

Hazard Management Plan. Though parts of 

the Wildlife Hazard Assessment may be 

incorporated directly into the Wildlife Hazard 

Management Plan, they are two separate 

documents. 

6.2.A REQUIREMENT FOR WILDLIFE 

HAZARD ASSESSMENT

Title 14 CFR 139.337(b)(1–4) requires that, in 

a manner authorized by the Administrator, 

each certificate holder must ensure that a 

Wildlife Hazard Assessment is conducted 

when any of the following events occurs on or 

near the airport: 

1. An air carrier aircraft experiences multiple 

wildlife strikes; 

2. An air carrier aircraft experiences 

substantial damage from striking wildlife; 
Chapter 6 Developing Control Programs 61 

3. An air carrier aircraft experiences an engine ingestion of wildlife; or 

4. Wildlife of a size, or in numbers, capable of causing an event described in paragraph 

(b)(1), (2), or (3) of this section is observed to have access to any airport flight 

pattern or aircraft movement area. 

The following provides a point-by-point comment on the regulations concerning the 

events that trigger a wildlife hazard assessment. 

14 CFR 139.337 Comments 

(b) In a manner authorized by the 

Administrator, each certificate holder 

shall ensure that a Wildlife Hazard 

Assessment is conducted when any of 

the following events occurs on or near 

the airport. 

A wildlife hazard assessment, conducted 

by a qualified wildlife damage 

management biologist, must be conducted 

if— 

(b) (1) An air carrier aircraft experiences 

a multiple wildlife strike 

Aircraft strikes more than one animal 

(geese, starlings, bats, deer, coyotes, 

etc.). 

(b) (2) An air carrier aircraft experiences 

substantial damage from striking wildlife. 

As used in this paragraph, substantial 

damage means damage or structural 

failure incurred by an aircraft that 

adversely affects the structural strength, 

performance, or flight characteristics of 

the aircraft and that would normally 

require major repair or replacement of 

the affected component 

The definition of substantial damage is 

taken directly form the International Civil 

Aviation Organization (ICAO) Manual on 

the International Civil Aeronautics 

Organization Bird Strike Information 

System.

(b) (3) An air carrier aircraft experiences 

an engine ingestion of wildlife; or 

Wildlife is ingested into a turboprop, 

turbofan, or turbojet engine. Engine 

damage does not have to result from the 

ingestion. 

(b) (4) Wildlife of a size, or in numbers, 

capable of causing an event described in 

paragraph (b)(1), (2), or (3) of this 

section is observed to have access to 

any airport flight pattern or aircraft 

movement area. 

Airports with a standing Notice to Airmen 

(NOTAM), announcements on their 

Automatic Terminal Information Service 

(ATIS), or comments in Airport/Facility 

Directory (A/FD) warning pilots of wildlife 

hazards on or near the airport meet this 

condition. 

6.2.B NECESSARY ELEMENTS OF A WILDLIFE HAZARD ASSESSMENT 

Title 14 CFR 139.337 (c)(1–5) provides specific guidance as to what facts must be 

addressed in a Wildlife Hazard Assessment. The following is a point-by-point comment 
62 Developing Control Programs Chapter 6 

on each section of the regulations concerning the factors to be addressed in a Wildlife 

Hazard Assessment. 

14 CFR 139.337 Comments 

(c) The Wildlife Hazard Assessment ... 

shall be conducted by wildlife damage 

management biologist ... having training 

or experience in wildlife hazard 

management at airports ... or working 

under the direct supervision ... 

The Wildlife Hazard Assessment (WHA) is 

to be conducted by someone having the 

following qualifications: 

Education: 

Meets U.S. Office of Personal 

Management standards for GS-486 

Wildlife Biologist. 

Work experience: 

Has prepared a WHA acceptable to 

the FAA. 

Has prepared a Wildlife Hazard 

Management Plan acceptable to the 

FAA. 

Or, is working under the direct 

supervision of someone who meets 

the above requirements. 

(c) cont. ... the Wildlife Hazard 

Assessment shall contain: 

(c) (1) Analysis of the event or 

circumstances that prompted the study. 

Who, what, when, where, why of the 

situation prompting the WHA. 

(c) (2) Identification of the wildlife species 

observed and their numbers, locations, 

local movements, and daily and seasonal 

occurrences. 

What wildlife species have access to the 

airport? What are their legal status, 

movement patterns, and seasonal 

patterns? Refer to Table 7-1 for a ranked 

listing of hazardous species. Pay 

particular attention to those species 

considered the most hazardous occurring 

on or near the airport. 

(c) (3) Identification and location of 

features on and near the airport that 

attract wildlife. 

Wildlife are attracted to an airport because 

something exists on or near the airport 

that they desire, such as large open areas 

where they can loaf in relative safety; 

abundant food or water; and escape, 

loafing, or nesting cover. These 

attractants need to be identified and 

evaluated. 
Chapter 6 Developing Control Programs 63 

14 CFR 139.337 Comments 

(c) (4) Description of the wildlife hazards 

to air carrier operations. 

This is a judgment call best made by a 

professional wildlife management biologist 

trained in dealing with airport issues. 

Hitting 3-4 swallows is much less 

hazardous than hitting one 12-pound 

Canada goose (see Table 7-1). 

(c) (5) Recommended actions for

reducing identified wildlife hazards to air 

carrier operations. 

The biologist preparing the WHA must 

provide prioritized recommendations for 

mitigating the hazardous wildlife 

attractants identified in (c)(3). 

6.2.C DURATION OF WILDLIFE HAZARD ASSESSMENT AND BASIC SURVEY 

TECHNIQUES

In conducting a Wildlife Hazard Assessment 14 CFR Part 139.337 (c)(2) requires the 

“identification of the wildlife species observed and their numbers, locations, local 

movements, and daily and seasonal occurrences.” In most cases, this requirement 

dictates that a 12-month assessment 

be conducted so the seasonal patterns 

of birds and other wildlife using the 

airport and surrounding area during an 

annual cycle can be properly 

documented. Most regions of the USA 

have dramatic seasonal differences in 

numbers and species of migratory 

birds. Even for non-migratory wildlife, 

such as deer and resident Canada 

geese, behavior and movement 

patterns can change significantly 

among seasons. Observations of 

wildlife at an airport and surrounding 

areas limited to a few days in a single 

season generally cannot adequately 

assess hazardous wildlife issues and 

associated habitat attractants. 

In order to adequately identify “the 

wildlife species observed and their 

numbers, locations, local movements, and daily and seasonal occurrences” during a 

Wildlife Hazard Assessment, the FAA and USDA/WS recommend that standardized 

survey procedures be used. These standardized procedures should provide an 

objective assessment of hazardous wildlife in the airport environment that can be 

repeated in future years for comparative purposes. One objective procedure for 

assessing bird populations, based on North American Breeding Bird Survey 

methodology, is the establishment of standardized survey points about 1⁄2 mile apart 

throughout the AOA (10-20 survey points are generally recommended depending on 

During the WHA, special attention must be paid to

the presence of domestic animals on the airport.

This Beachcraft Baron struck an 80-pound dog

(chow) during a night departure. The center landing

gear collapsed and both propellers struck the ground.
64 Developing Control Programs Chapter 6 

size of airport). Assigning each bird or bird flock observed during a point count to a grid 

location can be useful in further refining spatial distributions of birds on the airport. 

Additional survey points may be established in nearby off-airport areas (e.g., taxicab lot, 

golf course, or city park) suspected of attracting hazardous birds that move across the 

AOA. Standardized counts of birds should be made at each of these survey points at 

least twice monthly. In addition, specialized surveys might be needed as part of the 

overall assessment to document 

large-to-mid-sized mammals, such as 

deer or jackrabbits (from vehicle using 

spotlight or night vision equipment), 

and small mammals, such as voles 

and mice (snap traps), on the airport. 

These specialized mammal surveys 

should be conducted at least twice 

during a 12-month WHA. 

6.3 WILDLIFE HAZARD 

MANAGEMENT PLAN 

6.3.A REQUIREMENT FOR 

WILDLIFE HAZARD 

MANAGEMENT PLAN

When complete, the Wildlife Hazard 

Assessment is submitted to the FAA 

for evaluation and determination 

whether a Wildlife Hazard 

Management Plan needs to be 

developed for the airport. In reaching 

this decision, the FAA will consider 

the Wildlife Hazard Assessment, the 

aeronautical activity at the airport, the 

views of the certificate holder and airport users, and any other pertinent information (14 

CFR 139.337 (d)(1–6)). At a minimum, it is recommended that the airport manager 

develop and implement a plan to deal with any hazardous wildlife attractants or 

situations identified in the Wildlife Hazard Assessment. 

Bodies of open water adjacent to airports, such 

this 

as

drainage canal, are often magnets for waterfowl

and wading birds. Note the shallow slope that allows

birds easy access in and out of the water. Such

canals should be covered if possible or diverted away

from the airport (photo by E. Cleary, FAA). 

If the FAA determines that a Wildlife Hazard Management Plan is needed, the airport 

operator must then formulate and implement a Wildlife Hazard Management Plan, using 

the Wildlife Hazard Assessment as the basis for the plan (14 CFR 139.337 (e)(1–3)). At 

the same time, the FAA regional coordinator will contact the local U.S. Fish and Wildlife 

Service (USFWS), Ecological Services Field Office and request information about the 

presence of federally listed or proposed endangered or threatened species or 

designated or proposed critical habitat on or near the airport. (See FAA Airport 

Certification Program, Program Policy and Guidance No. 78, Section-7 Consultation on 

Endangered or Threatened Species, Appendix D.) The USFWS response will be 

forwarded to the airport operator to be taken into account when preparing the required 

plan. 
Chapter 6 Developing Control Programs 65 

If federally listed or proposed endangered or threatened species or designated or 

proposed critical habitat are present, the airport operator must prepare a Biological 

Assessment (50 CFR 402.13) assessing the impacts of the Wildlife Hazard 

Management Plan on these species or habitats. The Biological Assessment and draft 

Wildlife Hazard Management Plan must be submitted to the FAA for review and 

approval. 

Airport management may request the wildlife biologist who prepared the Wildlife Hazard 

Assessment to assist with the preparation of the Wildlife Hazard Management Plan and 

to review the finished plan. However, only the airport operator can commit airport 

resources (time, money, personal), and the ultimate responsibility for the development 

and implementation of the plan rests with the airport operator. When the plan is 

completed the airport operator must submit the draft plan, together with a copy of the 

Biological Assessment, to the FAA for approval. The FAA will conduct any needed 

Section 7 consultations with the USFWS. 

6.3.B. NATIONAL 

ENVIRONMENTAL POLICY ACT 

REVIEW

The FAA’s approval of a draft Wildlife 

Hazard Management Plan is covered 

by the categorical exclusion in FAA 

Order 1050.1E, paragraph 308e. 

Before the FAA approves a draft 

Wildlife Hazard Management Plan, the 

FAA must determine whether or not 

the draft Wildlife Hazard Management 

Plan involves extraordinary 

circumstances (see FAA Order 

1050.1E, paragraphs 303c and 304). 

• If a draft Wildlife Hazard 

Management Plan does not involve 

extraordinary circumstances, the 

FAA may categorically exclude the 

Wildlife Hazard Management Plan 

under FAA Order 1050.1E, 

paragraph 308e. 

• If a draft Wildlife Hazard 

Management Plan involves extraordinary circumstances, the FAA may require the 

airport sponsor to prepare an EA, or the FAA may prepare an EIS. 

The presence of a threatened or endangered species

on an airport, such as this nesting California least

tern, would constitute extraordinary circumstances

and require preparation of either an Environmental

Assessment or an Environmental Impact Statement

before the Wildlife Hazard Management Plan could

receive FAA approval (photo courtesy of USFWS,

NTCT Image Library). 

Once a draft Wildlife Hazard Management Plan is approved, the plan is returned to the 

airport sponsor for inclusion in the airport’s Airport Certification Manual and is 

enforceable. 
66 Developing Control Programs Chapter 6 

6.3.C NECESSARY ELEMENTS OF A WILDLIFE HAZARD MANAGEMENT PLAN 

The goal of an airport’s Wildlife Hazard Management Plan is to minimize the risk to 

aviation safety, airport structures or equipment, or human health posed by populations 

of hazardous wildlife on and around the airport. 

The Wildlife Hazard Management 

Plan must accomplish the 

following: 

As part of the Wildlife Hazard Management Plan, pilots

should be reminded to conduct a pre-flight inspection of

their aircraft for bird nesting material, especially if the

aircraft is parked outside or has not been used for some

time (photo courtesy USDA). 

• Identify personal responsible for 

implementing each phase of the 

plan, 

• Identify and provide information 

on hazardous wildlife 

attractants on or near the 

airport, 

• Identify appropriate wildlife 

management techniques to 

minimize the wildlife hazard, 

• Prioritize appropriate 

management measures, 

• Recommend necessary 

equipment and supplies, 

• Identify training requirements for the airport personnel who will implement the 

Wildlife Hazard Management Plan, and 

• Identify when and how the plan will be reviewed and updated. 

It is often helpful for the airport manager to appoint a Wildlife Hazards Working Group 

that periodically reviews the airport’s Wildlife Hazard Management Plan and the plan’s 

implementation to make recommendations for further refinements or modifications (see 

Chapter 7). 

14 CFR 139.337 (f)(1–7) provides specific guidance as to what facts must be addressed 

in a Wildlife Hazard Management Plan. The following table details how the 

requirements of Part 139.337 (f) (1–7) are to be addressed in an FAA-approved Wildlife 

Hazard Management Plan (see also Appendix E). 
Chapter 6 Developing Control Programs 67 

14 CFR 139.337 Comments 

(f). The Wildlife Hazard Management Plan 

shall include at least the following : 

(f) (1) A list of the individuals having 

authority and responsibility for 

implementing each aspect of the plan. 

Assign or delegate specific responsibilities 

for various sections of the Wildlife Hazard 

Management Plan to various airport 

departments, such as— 

• Airport Director 

• Operations Dept. 

• Maintenance Dept. 

• Security Dept. 

• Planning Dept. 

• Finance Dept. 

• Wildlife Coordinator 

• Wildlife Hazards Working Group 

• Local law enforcement authorities 

that might provide wildlife law 

enforcement and other support 

include — 

o U.S. Fish and Wildlife 

Service 

o State Wildlife Agency 

o City Police 

o County Sheriff 
68 Developing Control Programs Chapter 6 

14 CFR 139.337 Comments 

(f) (2) A list prioritizing the following 

actions identified in the wildlife hazard 

assessment and target dates for their 

initiation and completion: 

Provide a prioritized list of problem wildlife 

populations and wildlife attractants (food, 

cover, and water) identified in the WHA, 

proposed mitigation actions, and target 

starting and completion dates. A list of 

completed wildlife population management 

projects and habitat modification projects 

designed to reduce the wildlife strike 

potential can be included to provide a 

history of work already accomplished. It is 

helpful to group attractants by areas and 

ownership. 

Airport property: 

• Air Operations Area (AOA) 

• Within 2 miles of AOA 

• Airport structures 

Non-airport property 

• Within 2 miles of AOA 

• Within 5 miles of AOA 

(f) (2) (i) Wildlife population 

management; 

Address species-specific population 

management plans (e.g., deer, gulls, 

geese, and coyotes): 

• Habitat modification 

• Resource protection 

• Repelling/exclusion 

• Removal 

Chapter 9 provides a discussion of the 

various wildlife control methods. 
Chapter 6 Developing Control Programs 69 

14 CFR 139.337 Comments 

(f) (2) (ii) Habitat modification; and Food/prey management: 

• Rodents 

• Earthworms 

• Insects 

• Grain/seeds 

• Garbage—handling, storage 

• Handouts (feeding wildlife) 

Vegetation management: 

• AOA vegetation 

• Drainage ditch vegetation 

• Landscaping 

• Agriculture 

Water management: 

• Permanent Water 

• Wetlands 

• Canals/ditches/streams 

• Holding ponds 

• Sewage (glycol) treatment ponds 

• Other water areas 

• Ephemeral water 

o Runways, taxiways, aprons 

o Other wet areas 

Airport buildings: 

• Airfield structures 

• Abandoned structures 

• Terminal 

• Airport construction 
70 Developing Control Programs Chapter 6 

14 CFR 139.337 Comments 

(f) (2) (ii) [cont.] [and] land use changes. i.e., Elimination of agricultural activities on 

or near the airport, surface mining, urban 

development, creation of off-airport storm 

water management systems. 

(f) (3) Requirements for and, where 

applicable, copies of local, state, and 

federal wildlife control permits. 

Certain species of wildlife might be 

protected at all levels of government—

local, state, and federal—or might not be 

protected at all, depending on location and 

species. Address the specific species 

involved and their legal status in this 

section. Describe the wildlife management 

permitting requirements and procedures 

for all levels of government having 

jurisdiction, i.e.— 

• Federal – 50 CFR, Parts 1 to 199. 

• State – Fish and Game Code (or 

equivalent) 

• City, county – ordinances 

• If pesticides are to be used, the 

following are also needed: 

o Pesticide-use regulations: 

o Federal: Federal Insecticide, 

Fungicide, and Rodenticide 

Act. 

o State (varies by state) 

o Pesticide-use licensing 

requirements 

o State regulations 

Summaries are generally adequate. It is 

not necessary to quote chapter and verse 

of federal, state, and local laws and 

regulations. 
Chapter 6 Developing Control Programs 71 

14 CFR 139.337 Comments 

(f) (4) Identification of resources that the 

certificate holder will provide to implement 

the plan. 

Provide information identifying what 

resources the airport will supply in terms 

of— 

• Personal 

• Time 

• Equipment (e.g., radios, vehicles, 

guns, traps, propane cannons, etc.) 

• Supplies (e.g., pyrotechnics) 

• Pesticides (restricted/non-restricted 

use) 

• Application equipment 

• Sources of supply for equipment 

and supplies 

(f) (5) Procedures to be followed during air 

carrier operations that at a minimum 

includes— 

(f) (5) (i) Designation of personnel 

responsible for implementing the 

procedures; 

Who, when, what circumstances: 

• Wildlife Control Personnel 

• Wildlife Coordinator 

• Operations Dept. 

• Maintenance Dept. 

• Security Dept. 

• Air Traffic Control 

(f) (5) (ii) Provisions to conduct 

physical inspections of the aircraft 

movement areas and other areas critical to 

successfully manage known wildlife 

hazards before air carrier operations 

begin; 

Who, when, how, what circumstances: 

• Runway, taxiway sweeps 

• AOA monitoring 

• Other areas attractive to wildlife 
72 Developing Control Programs Chapter 6 

14 CFR 139.337 Comments 

(f) (5) (iii) Wildlife hazard control 

measures; and 

Who, what circumstances, when, and how 

are Wildlife Control Personnel contacted? 

What methods are to be used to— 

• Repel 

• Capture 

• Kill 

(f) (5) (iv) Ways to communicate 

effectively between personnel conducting 

wildlife control or observing wildlife 

hazards and the air traffic control tower. 

Training in communication procedures 

Equipment needed 

Radios, cellular phones, lights 

(f) (6) Procedures to review and evaluate 

the wildlife hazard management plan 

annually or following an event described in 

paragraphs (b)(1), (2), and (3) of this 

section, including: 

At a minimum, hold annual meetings, or 

meet after an event described in 

139.337(a)(1–3) with representatives from 

all airport departments involved in wildlife 

hazard management efforts and the 

wildlife damage management biologist 

who did the original Wildlife Hazard 

Assessment. 

(f) (6) (i) The plans effectiveness in 

dealing with known wildlife hazards on and 

in the airport’s vicinity and: 

Input from all airport departments, Air 

Traffic Control, and the wildlife biologist as 

to effectiveness of the plan. Good records 

are required for evaluating the 

effectiveness of a program (see Chapter 

7). 

(f) (6) (ii) Aspects of the wildlife 

hazards described in the wildlife hazard 

assessment that should be reevaluated. 

For example— 

• Number of times wildlife seen on 

AOA. 

• Requests for wildlife dispersal from 

air traffic control, pilots, or others. 

• Increased number of strikes. 
Chapter 6 Developing Control Programs 73 

14 CFR 139.337 Comments 

(f) (7) A training program conducted by a 

qualified wildlife damage management 

biologist to provide airport personnel with 

the knowledge and skills needed to 

successfully carry out the wildlife hazard 

management plan required by paragraph 

(d) of this section. 

Training for— 

• Wildlife control personnel 

• Other airport personnel 

• Pesticide user training and 

certification 

(See Chapter 8) 

(g) FAA Advisory Circulars contain 

methods and procedures for wildlife 

hazard management at airports that are 

acceptable to the Administrator. 

AC 150/5200-33A, Hazardous Wildlife 

Attractants on or Near Airports
74 Developing Control Programs Chapter 6 

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Chapter 6 Developing Control Programs 75 

Table 6-1. Airport Wildlife Hazard Review Worksheet. Page 1 of 5 

Airport Name (LOCID) 

City: State: FAA Region: 

Wildlife Hazard Assessment Evaluation 

Elements 

Reference 

14 CFR 

139.337 

Complete Comments 

The wildlife hazard assessment ... 

shall contain at least the following: (c) 

Analysis of event(s) or 

circumstances that prompted the 

assessment. 

(c) (1) 

Identification of the wildlife species 

observed, and ... . (c) (2) 

description of species numbers, (c) (2) 

description of species local 

movements, (c) (2) 

description of daily occurrences, (c) (2) 

description of seasonal 

occurrences. (c) (2) 

Identification and location of 

features on and near the airport 

that attract wildlife. 

(c) (3) 

Description of wildlife hazard to air 

carries operations. (c) (4) 

Recommendations for mitigation of 

identified wildlife attractants. (c) (5) 
76 Developing Control Programs Chapter 6 

Table 6-1. Airport Wildlife Hazard Review Worksheet. Page 2 of 5 

Airport Name (LOCID) 

City: State: FAA Region: 

Determination of Need for Wildlife Hazard Management Plan 

Elements 

Reference 

14 CFR 

139.337 

Complete Comments 

Review of Wildlife Hazard 

Assessment. (d) 

Wildlife Hazard Assessment. (d) (1) 

Actions recommended in WHA. (d) (2) 

Aeronautical activity. (d) (3) 

Certificate holder’s views. (d) (4) 

Airport users’ views. (d) (5) 

Other factors. (d) (6) 

Development of Wildlife Hazard 

Management Plan to be required 

by FAA. 

Yes No 

Endangered Species Act, Section 7 

consultation needed. Yes No 

Letter sent to USFWS. Yes No Date sent 

USFWS response received. Yes No Date received 

USFWS response forwarded to 

airport sponsor, if positive. Yes No Date sent 

FAA Official making this 

determination: 

Signature Date 
Chapter 6 Developing Control Programs 77 

Table 6-1. Airport Wildlife Hazard Review Worksheet. Page 3 of 5 

Airport Name (LOCID) 

City: State: FAA Region: 

Wildlife Hazard Management Plan Evaluation 

Elements 

Reference 

14 CFR 

139.337 

Complete Comments 

The plan shall include at least the 

following: (f) 

A list of the individuals having 

authority and responsibility for 

implementing each aspect of the 

plan (Airport and non-airport 

personnel). 

(f) (1) 

A list prioritizing the following 

actions identified in the wildlife 

hazard assessment and, target 

dates for their initiation and 

completion: 

(f) (2) 

Wildlife population management; (f) (2) (i) 

Habitat modification; and (f) (2) (ii) 

Land-use changes. (f) (2) (iii) 

Requirements for and, where 

applicable, copies of local, state, 

and federal wildlife control permits 

(Including pesticide use, where 

applicable). 

(f) (3) 

Identification of resources that the 

certificate holder will provide to 

implement the plan. 

(f) (4) 

Procedures to be followed during air 

carrier operations that at a minimum 

includes: 

(f) (5) 
78 Developing Control Programs Chapter 6 

Table 6-1. Airport Wildlife Hazard Review Worksheet. Page 4 of 5 

Airport Name (LOCID) 

City: State: FAA Region: 

Wildlife Hazard Management Plan Evaluation (Continued) 

Elements 

Reference 

14 CFR 

139.337 

Complete Comments 

Designation of personnel 

responsible for implementing the 

procedures; 

(f) (5) (i) 

Provisions to conduct physical 

inspections of the aircraft movement 

areas and other areas critical to 

successfully manage known wildlife 

hazards before air carrier operations 

begin; 

(f) (5) (ii) 

Wildlife hazard control measures; 

and (f) (5) (iii) 

Ways to communicate effectively 

between personnel conducting 

wildlife control or observing wildlife 

hazards and the air traffic control 

tower. 

(f) (5) (iv) 

Procedures to review and evaluate 

the wildlife hazard management 

plan annually or following an event 

described in paragraphs (b)(1), (2), 

and (3) of this section, including: 

(f) (6) 

The plans effectiveness in dealing 

with known wildlife hazards on and 

in the airport’s vicinity and: 

(f) (6) (1) 
Chapter 6 Developing Control Programs 79 

Table 6-1. Airport Wildlife Hazard Review Worksheet. Page 5 of 5 

Airport Name (LOCID) 

City: State: FAA Region: 

Wildlife Hazard Management Plan Evaluation (Continued) 

Elements 

Reference 

14 CFR 

139.337 

Complete Comments 

Aspects of the wildlife hazards 

described in the wildlife hazard 

assessment that should be 

reevaluated. 

(f) (6) (ii) 

A training program conducted by a 

qualified wildlife damage 

management biologist to provide 

airport personnel with the 

knowledge and skills needed to 

successfully carry out the wildlife 

hazard management plan required 

by paragraph (d) of this section. 

(f) (7) 

FAA Advisory Circulars contain 

methods and procedures for wildlife 

hazard management at airports that 

are acceptable to the Administrator.

(g) 

Section 7 Consultation completed 

with USFWS. Yes No Date completed 

NEPA coordination. Yes No 

Categorical exclusion. Yes No 

EA/EIS required. Yes No 

Wildlife Hazard Management Plan 

approved by: 

Signature Date 
80 Developing Control Programs Chapter 6 

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 81 

CHAPTER 7: 

EVALUATING WILDLIFE HAZARD MANAGEMENT 

PROGRAMS AT AIRPORTS 

This engine suffered major damage after ingesting a large bird on departure from a midwestern USA

airport. A UV emitting "black light" flashlight can be useful in detecting organic remains from birds in

the engine. 

7.1 INTRODUCTION

Wildlife populations on and in the vicinity of airports are constantly changing in response 

to changes in land use, state and federal management policies, and environmental 

factors. In addition, wildlife might adapt or habituate to control strategies that were once 

effective, or they might develop new behavioral or feeding patterns on or near the 

airport. New wildlife control technologies might become available, or established 

products or techniques might be withdrawn or banned. Finally, there might be changes 

in wildlife control and management personnel at an airport. Once a Wildlife Hazard 

Management Plan is in place, develop a process to evaluate the plan at least annually.
82 Evaluating Control Programs Chapter 7 

Update the plan as needed, based on the annual evaluation (14 CFR 139.337 [f][6]). 

This chapter outlines a means of conducting such evaluations. 

7.2 MONITORING AND RECORD KEEPING

The importance of accurate monitoring and record keeping cannot be overemphasized. 

Without consistently maintained records of wildlife activity, wildlife strikes, and wildlife 

management actions, the proper evaluation of a program is impossible. Without 

evaluation, no assessment of the effectiveness of a program can be made. 

Furthermore, without accurate records and proper evaluation, it might be difficult to 

justify and defend certain management actions, such as wildlife removal, or to defend 

the airport during litigation in the aftermath of a damaging wildlife strike (see Appendix 

N). 

7.2.A HAZARD ASSESSMENTS, PLANS, AND STUDIES

As discussed in Chapter 8, to facilitate access and reduce losses, keep all reference 

books, such as wildlife field guides, videos, posters, and other training and educational 

materials, in a specific location. For ready reference, have copies of Wildlife Hazard 

Assessments, Wildlife Hazard Management Plans, and other relevant wildlife studies 

conducted at the airport available at this site. Ideally, locate the wildlife library at the 

site where information on wildlife control activities and wildlife strikes is entered into 

logs, files, and databases. 

 

Sweep nets can be used to monitor and identify insect populations, such as Japanese beetles, that

attract gulls and other birds to an airport so pesticide applications and other control strategies can be

implemented in a timely manner (photos by T. W. Seamans, USDA). 

7.2.B DAILY LOG OF WILDLIFE CONTROL ACTIVITIES

Maintain a daily log of wildlife activity and management actions; important factors to 

record include— 

• Date, time, and location on airport where wildlife is observed. 

• Species of wildlife and approximate numbers. 
Chapter 7 Evaluating control Programs 83 

• Control actions taken and response of wildlife. 

Record this information on a standard form (see Table 7-1 for an example of a daily log 

form) that can be used by wildlife control personnel at the site where the activity takes 

place. If a form is not available, record the information in a log book kept at the 

operations base. 

The use of a standardized form or recording format, such as that presented in Table 7-

1, is strongly recommended. The information recorded will be most useful if it is 

summarized into monthly and annual statistics (see below). Use of a standardized 

format allows this summarization to be easily done. The use of computerized database 

systems customized to provide summaries of wildlife control activities is recommended. 

7.2.C DAILY LOG OF WILDLIFE 

STRIKES

Maintaining a consistent record of 

wildlife strikes is essential for defining 

the wildlife hazard level for an airport 

and for evaluating the airport’s Wildlife 

Hazard Management Plan. In addition 

to maintaining these strike records for 

internal use at the airport, surface-mail 

(using FAA Form 5200-7) or 

electronically submit strike reports to the 

FAA (http://wildlife.mitigation.tc.faa.gov). 

The FAA will incorporate the information 

into the National Wildlife Strike Database 

(Chapter 2). 

As defined in the glossary, a wildlife 

strike has occurred when— 

This Saab 340 hit a deer on landing at a Midwest

USA airport in April 2000, ripping the engine from

its mountings (photo courtesy Northwest Airlines).

1. A pilot reports striking one or more birds or other wildlife; 

2. Aircraft maintenance personnel identify aircraft damage as having been caused by a 

wildlife strike; 

3. Personnel on the ground report seeing an aircraft strike one or more birds or other 

wildlife; 

4. Bird or other wildlife remains are found within 200 feet of the centerline of a runway, 

unless another reason for the animal's death is identified; 

5. The animal's presence on the airport had a significant negative effect on a flight 

(e.g., aborted takeoff or landing, high-speed emergency stop, aircraft left pavement 

area to avoid collision with animal). 
84 Evaluating Control Programs Chapter 7 

 

 

Top Left. Bird strike remains on an aircraft. Top Right. Strike remains being collected.

(Smithsonian feather identification specialists refer to the collected material as “snarge.”) Lower

Left. Smithsonian feather identification specialist preparing snarge to identify the bird. Lower

Right. Micrograph of a downy feather recovered from the snarge. The feather belongs to a mallard

(photos by: Top – M. Begier, USDA; Bottom – C. Dove, Smithsonian Institution). 

Record each strike event under categories 1-3 or 5 (reported strike) on FAA Form 5200-

7 (Appendix I) and mail (the form is pre-addressed and franked on the back side) or 

transmit electronically to the FAA. Send photocopies of the form that do not have the 

address and frank on the back to— 

Federal Aviation Administration 

Office of Airport Safety and Standards, AAS-310 

800 Independence Avenue, SW 

Washington, DC 20591 
Chapter 7 Evaluating control Programs 85 

Copies of this form (with the address and frank) can be downloaded and printed from 

http://wildlife-mitigation.tc.faa.gov. The form also can be filled out and filed 

electronically at this site. 

When filling out Form 5200-7, include as much of the information requested as is 

available. Typically, not all information requested on the form will be available or 

known, but the report is valuable even if some information is missing. 

For category 4 strikes (wildlife remains found but no report of strike), a log of these 

incidents should be maintained with the date, location, number, and species of animals 

struck recorded (Table 7-2). A copy of this log should also be mailed monthly to the 

FAA at the above address, or these strikes should be reported individually on FAA Form 

5200-7 with a notation that a carcass was found but no strike was reported. 

For all strike reports, make every effort to have the wildlife correctly identified to 

species. Freeze specimens that cannot be readily identified in a labeled bag until a 

local wildlife expert can be consulted. 

If only feather remains are available, 

mail them to the Smithsonian 

Institution Feather Lab for identification 

(see instructions and address in 

Chapter 2, and in Advisory Circular 

150/5200-32A Reporting Wildlife 

Aircraft Strikes, Appendix C). There is 

no charge for this identification service. 

Please include a copy of the strike 

report or other relevant information 

with the bird remains to assist the 

feather experts in identifying the bird. 

7.2.D RECORDS OF SIGNIFICANT 

MANAGEMENT ACTIONS TAKEN

In addition to maintaining a daily log of 

wildlife control activities and wildlife 

strikes, it is important to keep records 

of other preventative management 

actions that might not be part of the daily routine of wildlife control. Examples of such 

actions might be installing or repairing fencing, thinning trees, clearing construction 

debris, applying pesticides or repellents, conducting grass-height management, 

installing netting in hangers or wires over ponds, and regrading pavement or grass 

areas to eliminate standing water. In addition, activities such as writing letters to 

catering services about proper storage of food waste are also important management 

actions. Documenting these activities in some type of summary file or table can aid in 

determining the total cost and effectiveness of the wildlife control program. 

One approach to controlling rodent populations at

airports is the periodic treatment of grass areas with

zinc phosphide-treated bait. The application must be

under the supervision of a person certified in

vertebrate pest control (Photo by R. A. Dolbeer,

USDA). 

7.2.E SUMMARY REPORTS BY MONTH AND YEAR

Periodically summarize information from the Daily Wildlife Control Activities log and 

from wildlife strikes records to provide baseline data for analyzing and evaluating the 
86 Evaluating Control Programs Chapter 7 

wildlife control program. A logical approach is to conduct monthly summaries that are 

then incorporated into an annual report. These summaries do not need to be complex 

but must reflect the level of activity for the common control techniques deployed. For 

example, monthly summaries of pyrotechnics fired, runway sweeps to clear birds, 

distress call deployments, birds and mammals removed by species, and wildlife strikes 

by species would be useful (Table 7-3). Prepare a short paragraph outlining other 

significant activities during the month, such as repairing a fence, meetings with airport 

tenants about wildlife issues (e.g., feeding birds in taxi stand area), or regrading an area 

to remove standing water. Prepare an annual report (Table 7-4) by combining data 

from the monthly reports. It is emphasized that Tables 7-3 and 7-4 are only presented 

as examples to provide guidance in developing a format to summarize data. A 

particular airport might use methods not listed in Tables 7-3 and 7-4, such as falconry, 

radio-controlled model airplanes, dogs, or propane cannons. The important point is that 

there must be an objective, numerical documentation of wildlife control methods 

deployed and wildlife strikes occurring on the airport. The use of a computer database 

program can be extremely helpful in 

producing these summary reports. 

7.2.F TRAINING

Maintain and annually summarize a 

record of all training that wildlife control 

personnel have received. Include 

attendance at conferences, courses 

and workshops (e.g., firearms safety), 

self-study courses, and specialized onthe-job training. 

7.3 ASSESSMENT OF 

WILDLIFE HAZARD MANAGEMENT 

PLAN 

All FAA approved Wildlife Hazard 

Management Plans must be reviewed 

at least annually or following an event 

that would normally trigger a Wildlife 

Hazard Assessment (see 14 CFR 

139.337 (b)(1-4) and 139.337 (f)(6)). 

The review must include: the plan's effectiveness in dealing with known wildlife hazards 

on and in the vicinity of the airport, and aspects of the wildlife hazards described in the 

Wildlife Hazard Assessment that should be reevaluated (14 CFR 139.337 (f)(6)). The 

wildlife damage management biologist that helped prepare the plan and a sub-group 

from the Airport’s Wildlife Hazard Working Group should conduct this review. 

All airport management, as well as airport operations

and maintenance personnel, need a basic

understanding of wildlife aircraft strike issues on their

airport. Specialized courses in managing wildlife

hazards at airports, taught by recognized experts,

provide a practical way of doing this. The FAA and

USDA/WS can provide this type of training (photo by

C. Steves, FAA). 

Appendix K describes a simple system (modified from Seubert 1994) for assessing a 

Wildlife Hazard Management Plan at an airport. Five assessment categories are used 

to indicate the adequacy of a Wildlife Hazard Management Plan and how well the plan 

is being implemented: 
Chapter 7 Evaluating control Programs 87 

Category 1. Management functions related to wildlife hazards on or in the vicinity of the 

airport. 

Category 2. Bird control on or in the vicinity of the airport. 

Category 3. Mammal control on or in the vicinity of the airport. 

Category 4. Management of habitat and food sources on airport property related to 

wildlife hazards. 

Category 5. Land uses and food sources off of the airport potentially related to wildlife 

hazards on airport. 

Within Categories 1-4 (activities on the 

airport), a series of elements are listed 

that are evaluated as either 

“Satisfactory”, “Unsatisfactory”, “Needs 

Improvement”, or “Not Applicable”. For 

Category 5 (off-airport attractants), the 

elements are scored on a scale of 0 

(not present) to 3 (site creates 

significant wildlife hazard for airport; 

action should be taken). Those 

elements deemed “Unsatisfactory” or 

“Needs Improvement” (in Categories 1-

4) or that are scored 2 or 3 (in 

Category 5) are then commented on in 

a summary form. The elements listed 

within each category are not intended 

to cover every possibility at every 

airport. The elements can be modified 

or expanded to meet situations unique 

to an airport. 

Wetlands on airport provide both habitat and food for

wildlife. Such areas can be eliminated through

wetland mitigation programs (photo by E. Cleary,

FAA). 

7.4 AIRPORT WILDLIFE HAZARDS WORKING GROUP

7.4.A FUNCTION

Wildlife hazard management on an airport often requires communication, cooperation, 

and coordination among various groups on the airport and with various local, state, and 

federal agencies and private entities. For many airports, the establishment of a Wildlife 

Hazards Working Group (WHWG) will greatly facilitate this communication, cooperation, 

and coordination. 

7.4.B MEMBERSHIP

Include a representative from each of the key groups and agencies that have a 

significant involvement or interest in wildlife issues on the airport in the WHWG. Airport 

groups might include representatives from security, maintenance, operations, and air 

traffic control. From government, representatives from the state wildlife agency, the 

U.S. Fish and Wildlife Service and USDA/WS might be appropriate. Include 

representatives from any facility near the airport that significantly attracts wildlife (such 
88 Evaluating Control Programs Chapter 7 

as a landfill or wildlife refuge). 

In general, do not exceed 10 people in the core WHWG. This will keep meetings from 

becoming unwieldy. In addition to regular members, invite people with specialized 

knowledge, interest, or concerns to the meetings as appropriate. Typically, someone 

from airport management chairs the WHWG. The chair can be rotated among various 

airport departments. 

7.4.C MEETINGS

At least annually hold a meeting of the 

WHWG to conduct a general review of 

the overall wildlife hazard 

management program for the airport 

and to discuss special issues or 

problems as needed. Include the 

following in the general discussion: 

• Strike trends and significant strike 

events (based on data summarized 

using formats in Tables 7-3 and 7-

4). 

• Source of wildlife causing strike 

problems. 

• Wildlife control activities (based on 

data and commentary summarized 

using formats in Tables 7-3 and 

7-4. 

• Wildlife Hazard Management Plan evaluation (based on most recent assessment 

using format in Appendix K). 

Airports should establish a Wildlife Hazards Working

Group (WHWG) that meets at least annually to

facilitate communication, cooperation, and

coordination among the various agencies and airport

departments. The WHWG also provides a forum to

review and update the airport’s Wildlife Hazard

Management Plan (photo by R. A. Dolbeer, USDA). 

Special issues to be discussed might include projected impacts of land-use changes on 

or near the airport, trends in populations or behavior of various species of wildlife, 

wildlife removal permits, evaluation of new wildlife control technologies, and clarification 

of roles and responsibilities. A good way to end the meeting might be with a field 

demonstration of a wildlife management activity on the airport or a site visit to a nearby 

wildlife attractant (e.g., sewage treatment facility) that might need addressing. 

Special meetings of the entire WHWG or a subgroup might be needed after significant 

strike events or other developments affecting wildlife hazards if a regular meeting is not 

scheduled for the near future. 

7.4.D MEETING REPORTS

Make arrangements to have minutes taken and a summary report written for each 

meeting. Include in the report a list of attendees, decisions made by the group, 

deadlines and responsible parties for task assignments, and a list of critical issues that 

were not resolved. 
Chapter 7 Evaluating control Programs 89 

7.5 SUMMARY AND CONCLUSIONS

Periodic evaluations of an airport’s Wildlife Hazard Management Plan and the activities 

undertaken to implement the plan are 

critical because of the dynamic nature 

of wildlife hazards and control 

technologies. The foundation for 

these evaluations is the maintenance 

of consistent records of wildlife control 

activities and wildlife strikes. The use 

of standardized formats for keeping 

these records, such as those 

presented in Tables 7-1 to 7-4, permits 

easy compilation of events and 

activities into monthly and annual 

statistical and narrative summaries. 

Once these summaries are available, 

objective examinations and 

comparisons can be made of trends in 

strikes, wildlife activities, control 

methods deployed, and other factors. 

All wildlife carcasses found during aircraft movement

area 

Unless 

wildlife strike and recorded in the 

inspections should be removed immediately.

another reason for the animal’s death can be

determined, the incident should be reported as a

airport’s wildlife

strike database (photo courtesy USDA). 

An objective, standardized format for assessing a Wildlife Hazard Management Plan 

and its implementation is presented in Appendix K. This format allows an outside 

biologist or evaluation group to systematically review the actions being taken and make 

recommendations in areas where improvement is needed. The availability of summary 

statistics, such as provided through records maintained in Tables 7-1 to 7-4, is essential 

for this assessment. 

Finally, the establishment of a WHWG provides an excellent means of improving 

communication, coordination, and cooperation among the diverse groups involved in 

wildlife hazard management on an airport. The WHWG also can provide an important 

forum for reviewing, evaluating, and improving an airport’s wildlife hazard management 

program. 
90 Evaluating Control Programs Chapter 7 

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Chapter 7 Evaluating control Programs 91 

Table 7-1. Example of a daily log of wildlife control activities. 

Airport Month Year

Wildlife

Date Time

Location 

(Grid) Species No. 

Control 

method Results/comments Initials
92 Evaluating Control Programs Chapter 7 

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Chapter 7 Evaluating control Programs 93 

Table 7-2. Example of a Wildlife Strike Log for recording bird or other wildlife remains 

found within 200 feet of runway centerline that, in the judgment of wildlife 

control personnel, were killed as a result of interacting with an aircraft. 

Airport Month Year 

Date 

Time 

found Species Runway

Location on 

runway 

Was strike 

reported1

? Comments 

1

If strike was reported, complete FAA Form 5200-7. 
94 Evaluating Control Programs Chapter 7 

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Chapter 7 Evaluating control Programs 95 

Table 7-3. Example of a form to provide monthly summary of wildlife control activities. 

Airport Month Year 

Control activity 

(modify list as 

appropriate) 

This 

month 

Same 

month 

last 

year 

Comments (list wildlife dispersed or removed 

by species and method) 

No. of 

pyrotechnics fired 

No. of times 

distress calls 

deployed 

No. of runway 

sweeps to clear 

birds 

No. of wildlife 

removed 

Miles driven by 

wildlife patrol 

No. of reported 

strikes 

No. of reported 

strikes with 

damage 

No. of carcasses 

found (no strike 

reported) 

Summary paragraph of other wildlife control activities: 
96 Evaluating Control Programs Chapter 7 

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Chapter 7 Evaluating control Programs 97 

Table 7-4. Example of a form to provide annual summary of wildlife control activities 

derived from monthly reports (Table 7-3). Modify each airport’s form to 

reflect the common control activities undertaken during the year. The data 

may also be presented graphically. 

Airport Year 

Number of: 

Month 

Pyrotechnics 

fired 

Times 

distress 

calls 

deployed 

Runway 

sweeps to 

clear birds 

Wildlife 

dispersed

Wildlife 

removed1

Miles 

driven 

by 

wildlife 

patrol 

Reported 

strikes2

Reported 

strikes 

with 

damage 

Carcasses 

found (no 

strike 

reported)2

Jan 

Feb 

Mar 

Apr 

May 

Jun 

Jul 

Aug 

Sep 

Oct 

Nov 

Dec 

Total 

1

Provide separate list by species and method. 

2

Provide separate list by species. 
98 Evaluating Control Programs Chapter 7 

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 99 

CHAPTER 8: 

WILDLIFE HAZARD MANAGEMENT TRAINING 

FOR AIRPORT PERSONNEL 

Populations of most bird species weighing over 4 pounds have increased dramatically in the USA

since 1980. These large birds can cause substantial damage when struck by aircraft (photo courtesy

USAF). 

8.1 INTRODUCTION

The management of wildlife is a complex endeavor that often attracts public interest. 

Once an assessment of hazards has been completed and a Wildlife Hazard 

Management Plan has been developed, the plan must be implemented by well-trained 

and knowledgeable individuals if it is to be successful in reducing wildlife strikes and 

accepted by the public. 

Depending on the size of an airport and the level of wildlife hazard, the Wildlife Hazard 

Management Plan may be implemented by a single airport employee undertaking 

wildlife control activities on an occasional “as needed” basis or by a full-time wildlife 

biologist with a staff of operations personnel providing continuous bird patrols.
100 Training Chapter 8 

Some of the personnel involved in these control activities, hereafter referred to as 

wildlife control personnel (WCP), might not have formal education in wildlife biology. All 

WCP must have sufficient training to be knowledgeable in the basic principles of wildlife 

management and in the identification, behavior, general life history, and legal status of 

the hazardous species in the area. WCP also must be trained in the proper 

implementation or deployment of various control strategies and techniques outlined in 

the Wildlife Hazard Management Plan. Finally, an awareness of endangered and 

threatened wildlife species that might visit or reside on the airport is critical. 

8.2 TRAINING

The following areas of training and 

levels of skill are suggested for WCP 

implementing control activities on 

airports under a Wildlife Hazard 

Management Plan. It is emphasized 

that, once a plan is in place, in addition 

to the training provided to WCP, there 

must be periodic oversight and review 

of the plan and its implementation by a 

professional biologist trained in wildlife 

damage control (14 CFR 139.337 

(f)(7)). 

8.2.A BIRD IDENTIFICATION

There are over 600 species of birds 

that reside in or migrate through the 

USA. Many of these species, such as 

gulls, have quite different plumage patterns and bill colors as subadults (year of 

hatching up to 3 years in some species) than as adults (as an example, see Appendix J 

for a fact sheet on North American gulls). Some birds, such as laughing gulls, 

European starlings, and black-bellied plovers, have different summer and winter 

plumage patterns and bill colors. In other species, such as northern harriers and redwinged blackbirds, males and females appear quite different. Some species are 

present in an area all year, others only in migration (spring, fall), and others only in 

winter or in summer. All species have unique vocalizations, behaviors, and habitat 

preferences that are useful in field identification. Thus, to become an expert in field 

identification of all bird species at a location requires many years of training and 

practice. WCP require basic training so they can identify, in all plumages, commonly 

seen hazardous birds, as well as those rarer species that are considered hazardous 

when present or are of concern because of endangered- or threatened-species status. 

Table 8-1 provides a list of the relative hazard of various species groups based on the 

percent of reported strikes that cause damage or an effect-on-flight. 

Training, provided by recognized experts, should

include classroom instruction, fieldwork, and

attendance at conferences, such as Bird Strike

Committee USA/Canada (photo by C. Steves, FAA).
Chapter 8 Training 101

Table 8-1. Ranking of 25 species groups as to relative hazard to aircraft (1=most hazardous) 

based on three criteria (damage, major damage, and effect-on-flight), a composite 

ranking based on all three rankings, and a relative hazard score. Data were 

derived from the FAA National Wildlife Strike Database, January 1990–April 20031

. 

Ranking by criteria 

Species group Damage2 Major damage3 Effect on flight4

Composite 

ranking5

Relative 

hazard score6

Deer 1 1 1 1 100 

Vultures 2 2 2 2 64 

Geese 3 3 6 3 55 

Cormorants/pelicans 4 5 3 4 54 

Cranes 7 6 4 5 47 

Eagles 6 9 8 6 41 

Ducks 5 8 10 7 39 

Osprey 8 4 8 8 39 

Turkey/pheasants 9 7 11 9 33 

Herons 11 14 9 10 27 

Hawks (buteos) 10 12 12 11 25 

Gulls 12 11 13 12 24 

Rock pigeon 13 10 14 13 23 

Owls 14 13 20 14 23 

Horned lark/snow bunting 18 15 15 15 17 

Crows/ravens 15 16 16 16 16 

Coyote 16 19 5 17 14 

Mourning dove 17 17 17 18 14 

Shorebirds 19 21 18 19 10 

Blackbirds/starling 20 22 19 20 10 

American kestrel 21 18 21 21 9 

Meadowlarks 22 20 22 22 7 

Swallows 24 23 24 23 4 

Sparrows 25 24 23 24 4 

Nighthawks 23 25 25 25 1 

1

 Excerpted from the Special Report for the FAA, Ranking the Hazard Level of Wildlife Species to Civil Aviation in the 

USA: Update #1, July 2, 2003. Refer to this report for additional explanations of criteria and method of ranking. 2

 Aircraft incurred at least some damage (destroyed, substantial, minor, or unknown) from strike. 3

 Aircraft incurred damage or structural failure that adversely affected the structure strength, performance, or flight 

characteristics and that would normally require major repair or replacement of the affected component, or the damage 

sustained makes it inadvisable to restore aircraft to airworthy condition. 4

 Aborted takeoff, engine shutdown, precautionary landing, or other. 5

 Relative rank of each species group was compared with every other group for the three variables, placing the species 

group with the greatest hazard rank for > 2 of the 3 variables above the next highest ranked group, then proceeding 

down the list. 

 6 Percentage values, from Tables 3 and 4 in Footnote 1 of the Special Report, for the three criteria were summed and 

scaled down from 100, with 100 as the score for the species group with the maximum summed values and the greatest 

potential hazard to aircraft. 
102 Training Chapter 8 

Binoculars are essential for detailed, close-up observations sometimes necessary for 

identification as well as for the detection and identification of birds or other wildlife at a 

distance. Provide WCP with a quality pair of binoculars, and train WCP in their use. 

Equip each WCP with his or her own bird identification field guide, to be carried in the 

vehicle while on patrol. As a learning aid, encourage WCP to make annotations in their 

field guides regarding behavior or appearance next to identified birds. 

There are a number of excellent field guides available from bookstores, some of which 

are listed at the end of this chapter. 

There are also bird identification 

guides available on CDs that provide 

useful life history information and 

vocalizations. 

8.2.B MAMMAL IDENTIFICATION

Unlike birds, there are typically only a 

few mammal species of importance 

on an airport. Train WCP to identify, 

not only by sight but also by sign (e.g., 

tracks, burrows, and fecal material), 

the common large and mid-sized 

mammals (e.g., deer, raccoons, 

woodchucks, coyotes) that live around 

the airport. Train WCP to identify 

signs (e.g., trails in grass, burrows) 

indicative of a population eruption of 

field rodents, such as voles, deer 

mice, or rats. A survey by a biologist 

using snap traps might be necessary 

to identify the species and relative 

abundance of rodents occupying various airport habitats. In addition, rodent species 

can be identified by examination of skull remains in pellets (boluses) regurgitated by 

hawks and owls. These pellets are often found on the ground beneath perching sites 

used by raptors. 

Grass areas at airports often contain several species

of small mammals that are an attractive food for

hawks, owl, herons, and egrets. Vagrant shrews,

deer mice, gray-tailed voles, and Townsend’s voles

(left to right) were all captured during one night of

trapping at a western USA airport in September 2003

(photo by R. A. Dolbeer, USDA). 

Citations for field guides covering mammals and their tracks throughout the USA are 

provided at the end of this chapter. In addition, there are many state and regional field 

guides for identifying mammals and their signs. A good field guide to mammals is a 

necessary part of any airport’s hazardous wildlife control library. 

8.2.C BASIC LIFE HISTORIES AND BEHAVIOR OF COMMON SPECIES

In addition to learning to identify the hazardous birds and mammals on the airport, WCP 

should have some understanding of the biology and behavior of these species. This 

information will make the job of wildlife hazard management more interesting and be 

useful in anticipating problems and deploying control measures more effectively. 

For each species of bird, it is important to know if it is present year round or only in 

summer, in winter, or during migration. For example, in which habitats and at what time 
Chapter 8 Training 103

of year do locally breeding bird species nest and when are young fledged from nests? 

What are the daily movement patterns between roosting, feeding and loafing areas in 

relation to the airport? What are the feeding behaviors and food preferences of each 

species on the airport? Which habitats does each species prefer? How does weather 

influence the presence and behavior of various species on the airport? How does each 

species react to approaching aircraft and to various repellent devices? By being 

observant and noting the behavior of these hazardous species, useful insights can be 

gained that will lead to more effective habitat management or repellent strategies. 

Most bird and mammal field guides provide 

information on geographic range, feeding habits, 

and habitat preferences for each species. Alsop 

(2001), Sibley (2001), and Ehrlich et al. (1988) 

provide concise summaries of life history 

information (nesting, feeding, habitat 

preferences) for most birds in North America. 

Appendix J provides some life history facts for 

various gull species in the USA. Such books and 

fact sheets provide an excellent starting point for 

knowledge about a species. However, the most 

useful information will come from careful 

observation of what the birds and mammals are 

doing on your airport. 

8.2.D WILDLIFE AND ENVIRONMENTAL LAWS 

AND REGULATIONS

As presented in Chapter 4, there is a complexity 

of federal and state laws protecting wildlife and 

regulating the issuance of permits to take 

(capture or kill) individuals causing problems. In 

addition, environmental laws and regulations 

regarding pesticide applications, drainage of 

wetlands, and endangered species must be 

considered in implementing Wildlife Hazard 

Management Plans. All WCP should have a basic understanding of the federal 

Migratory Bird Treaty Act (MBTA) whereby almost all native migratory birds are 

protected regardless of their abundance (see Chapter 4). WCP must understand that 

federal and often state permits must be issued before protected species can be taken 

on an airport. WCP must know that wild mammals are regulated at the state level, 

which may require permits for activities involving removal (killing or trapping/relocating). 

Non-native birds, such as pigeons, house sparrows, and starlings, and gallinaceous 

game birds, such as turkeys, grouse, and pheasants, are not protected by the MBTA 

but often have state protection. WCP involved in taking any wildlife species must have 

a clear understanding of which species have no legal protection and, for all others, the 

species and numbers allowed to be taken under permits issued. Permits also will list 

the methods of removal allowed and acceptable procedures for disposing of removed 

wildlife. Detailed records must be maintained of wildlife taken under permit. 

Canada geese have adapted to nesting

on rooftops, often well away from water

(photo courtesy USDA). 
104 Training Chapter 8 

8.2.E WILDLIFE CONTROL TECHNIQUES

Chapter 9 provides a brief description of most wildlife control techniques used on 

airports. WCP will need training to deploy these techniques safely and effectively. 

 

The use of pyrotechnics, such as cracker shells fired from a 12-gauge shotgun (left) or screamers

fired from a pistol launcher, should be part of an airport’s integrated management program to disperse

hazardous birds. Occasional lethal control by shooting might be necessary to reinforce pyrotechnics

and other nonlethal dispersal techniques used against common species such as gulls and Canada

geese. Permits and proper training must be in place before lethal control is implemented (photos by

R. A. Dolbeer, USDA). 

Firearms. It is critical that only personnel trained in the use of firearms, authorized 

under depredation permit, and knowledgeable in field identification of the target and 

similar-looking non-target species are allowed to use firearms on the airport. Skill, 

experience, and the proper equipment are needed to be safe and to maximize the 

effectiveness of a shooting program, whether it is to remove specific problem animals or 

to kill one or more individuals to reinforce repellent techniques. All discharged shell 

casings are potential Foreign Object Debris (FOD) and must be picked up. 

Pyrotechnics. Pyrotechnics can cause injury or damage if discharged incorrectly or 

carelessly. For example, serious injuries have occurred when pyrotechnics were 

accidentally discharged inside vehicles. Proper equipment (safety glasses, ear 

protection) and training is essential for safe use of pyrotechnics. In addition, training is 

needed to deploy the correct pyrotechnic for each situation and wildlife species and to 

minimize habituation. It is critical that pyrotechnics (and other repellent devices) not be 

deployed in situations where the birds or mammals might be flushed into the path of 

departing or arriving aircraft. 

Pesticide application. WCP applying restricted-use pesticides, applying pesticides for 

hire, or applying pesticides to the land of another must be Certified Applicators or 
Chapter 8 Training 105

working under the direct supervision of a Certified Applicator and then may only use 

pesticides covered by the Certified Applicator's certification. Proper application 

equipment and safety clothing must be used. Detailed records of pesticide applications 

must be maintained. 

For information on the training 

requirements for becoming a 

Certified Pesticide Applicator, contact 

the State University Cooperative 

Extension Service. 

Distress call tapes, propane cannons, 

and miscellaneous techniques. As

emphasized in Chapter 9, a major 

problem in the use of repellent 

techniques or devices is habituation 

of the wildlife species to the threats. 

These techniques all require training 

for their proper deployment. The 

most critical factor for most repellent 

devices is that they be deployed 

sparingly and appropriately when the 

target wildlife is present and be 

reinforced occasionally by a real 

threat such as shooting. More 

detailed information on the use of 

various repellent devices is presented in Chapter 9 and Hygnstrom et al. (1994). 

Propane cannons can be used as part of an integrated

program to disperse birds from airports. However,

birds quickly habituate to the loud bangs if the cannons

are used continuously and not integrated with other

frightening devices (photo by R. A. Dolbeer, USDA). 

8.2.F RECORD KEEPING AND STRIKE REPORTING

A key component of a Wildlife Hazard Management Plan is developing a system to (1) 

document the daily activities of WCP, (2) log information about wildlife numbers and 

behavior on the airport, and (3) record all wildlife strikes with aircraft. This information is 

essential to document the effort being made by the airport in reducing wildlife hazards. 

The information is also extremely useful during periodic evaluations of the Wildlife 

Hazard Management Plan and when revisions to the plan are proposed. Instruct WCP 

on the importance of record keeping and train them to record this information in a 

standardized format. Chapter 7 provides more details about record keeping and wildlife 

strike reporting. 
106 Training Chapter 8 

8.3 SOURCES OF TRAINING

Wildlife control workshops at airports. Books, manuals, and videos can provide a 

starting point for building skills to manage hazardous wildlife on airports. However, 

hands-on training is essential to develop the necessary skills and confidence to 

successfully and safely carry out wildlife control activities. Workshops on airport wildlife 

control offered by the USDA/WS or other entities are an excellent means of obtaining 

training in wildlife identification, legal issues, and the deployment of various control 

techniques specific for a given airport or region of the country. These workshops can 

be held for all WCP at a single airport or at a centralized airport with participants coming 

from airports throughout the state or region. 

 

A special classroom and field training program in the proper and safe use of pyrotechnics to disperse 

birds was provided at the 2002 and 2004 meetings of Bird Strike Committee–USA/Canada (photos by 

R. DeFusco). 

Contact the Wildlife Services office in your state (Appendix A) for more information. 

Bird Strike Committee USA meetings. Bird Strike Committee–USA (BSC–-USA) holds 

joint meetings annually with Bird Strike Committee Canada at a USA or Canadian 

airport. This annual meeting provides an excellent forum to discuss the latest issues 

and techniques in wildlife control for airports. The meeting includes a field trip to the 

host airport with demonstrations by vendors and wildlife specialists of various wildlife 
Chapter 8 Training 107

control equipment and techniques. Chapter 3 provides more information on BSC–USA. 

Information on annual meetings, as well as information on various aspects of wildlife 

hazard management for airports, can be found at BSC–USA’s web site: 

www.birdstrike.org. 

Hunter safety and firearms courses. Require airport personnel who will be using 

firearms to complete a hunter safety or firearms safety course. The state wildlife 

agency can provide information on these courses. 

Miscellaneous courses and activities. Many universities and some community colleges 

offer courses in ornithology, principles of wildlife management, principles of wildlife 

damage control, or other related topics. Local Audubon Society chapters or park 

districts sometimes offer workshops or short courses in field identification of birds. 

Participation in conservation organization activities, such as Christmas Bird Counts and 

spring migration counts, is an excellent means of building bird identification skills and 

developing contacts with local wildlife experts.

8.4 WILDLIFE HAZARD 

MANAGEMENT LIBRARY

Establish a designated location for 

reference books, such as wildlife field 

guides, videos, posters, and other 

training and educational materials and 

the airport’s Wildlife Hazard 

Management Plan if one has been 

developed. Ideally, locate this wildlife 

library at the site where information on 

wildlife control activities and wildlife 

strikes is entered into logs, files, and 

databases. 

8.5 FIELD GUIDES AND 

REFERENCE BOOKS

There are many excellent field guides 

and reference books for learning about 

wildlife. To provide examples, a 

selection of books that cover North 

America or large regions of the USA is 

listed below. This list is not intended as an endorsement of these books to the 

exclusion of others. There are also many field guides for individual states and 

specialized books for various wildlife species or species groups.

Birds and mammals are not the only wildlife groups

that can cause problems on airports. This 7-foot

alligator wandered onto the runway at a southern

USA airport in September 2002, threatening both

aircraft and personnel. The alligator was relocated

unharmed. For the 14-year period 1990–2003,

reports of 15 alligator-aircraft strikes with civil aircraft

were received by the FAA (photo by J. Metcalf). 
108 Training Chapter 8 

Field Guides–Birds

Bull, J., J. Farrand, Jr., and, L. Hogan. 1994. National Audubon Society field guide to 

North American birds: Eastern region. Alfred Knopf, New York, New York. 796 

pages. 2nd edition. 

National Geographic Society. 2002. 

Field guide to the birds of North 

America. National Geographic 

Society, Washington, District of 

Columbia. 480 pages. 4th edition. 

Airports should maintain a small library of field guides

that can be referenced by biologists and operations

personnel to identify and learn about birds, mammals,

plants, and insects found on the airport. These field

guides should be located with the Wildlife Hazard

Management Plan and other related documents

(photo by B. Washburn, USDA). 

Griggs, J. L. 1997. All the birds of 

North America: American Bird 

Conservancy’s field guide. Harper 

Collins, New York, New York. 172 

pages. 

Peterson, R. T. 1998. A field guide to 

the birds: a completely new guide to 

all the birds of Eastern and Central 

North America. Houghton Mifflin 

Company, New York, New York. 384 

pages. 4th edition. 

Peterson, R. T. 1990. A field guide to 

Western birds: a completely new 

guide to field marks of all species 

found in North America west of the 

100th meridian and north of Mexico. 

Houghton Mifflin Company, New York, 

New York. 431 pages. Reissue 

edition. 

Robbins, C. S., B. Bruun, and H. S. Zim. 1983. Birds of North America. Golden Press, 

New York, New York. 360 pages. 

Field Guides - Mammals

Burt, W. H., and R. P. Grossenheider. 1998. A field guide to the mammals: North 

America north of Mexico. Houghton Mifflin Company, New York, New York. 3rd 

edition. 289 pages. 

National Audubon Society. 2000. National Audubon Society field guide to North 

American mammals (revised and expanded). Alfred Knopf, New York, New 

York. 937 pages. 

Elbroch, M. 2003. Mammal tracks and sign: A guide to North American species. 

Stackpole Books, Mechanicsburg, Pennsylvania. 792 pages. 

Murie, O. J. 1954. A field guide to animal tracks. Houghton Mifflin Company, New 

York, New York. 374 pages. 
Chapter 8 Training 109

Life Histories

Alsop, F. J., III. 2001. Birds of North America, Eastern Region (751 pages), Western 

Region (752 pages). DK Publishing, Inc., New York, New York. 

An examination of the stomach contents of aircraft-struck

birds found on runways can often identify food sources

that are attracting the birds to the airport. A chicken neck

and undigested French-fried potato found in this laughing

gull stomach indicated a nearby source of uncovered

garbage (photo by G. E. Bernhardt, USDA). 

Ehrlich. P. R., D. S. Dobkin, and D. 

Wheye. 1988. The birder’s

handbook: a field guide to the 

natural history of North American 

birds, including all species that 

regularly breed north of Mexico. 

Simon and Schuster, New York. 

785 pages. 

Chapman, J. A., and G. A. 

Feldhamer (editors). 1982. Wild 

mammals of North America. Johns 

Hopkins University Press, 

Baltimore, Maryland. 1,147 pages. 

Sibley, D. A. 1991. The Sibley 

guide to bird life and behavior. 

Alfred A. Knopf, New York, New 

York. 580 pages. 
110 Training Chapter 8 

This page intentionally left blank 
 111 

CHAPTER 9: 

WILDLIFE CONTROL STRATEGIES AND TECHNIQUES AT

AIRPORTS 

A B-767 departing an east coast USA airport in October 2002 ingested at least one double-crested

cormorant into the #2 engine. Parts of the engine broke loose and penetrated the engine casing,

resulting in an uncontained engine failure. The strike also damaged the landing light and leading edge

of the right wing. The cormorant population increased at an annual rate of 7% in the USA from 1980–

2004. 

9.1 INTRODUCTION

No airport or aircraft type is immune from the hazards of wildlife strikes. Many species 

of birds and mammals have been involved in damaging strikes (Chapter 2). A flock of 

starlings suddenly rising from the ground, a lone kestrel hovering in search of prey, a 

pair of Canada geese taking flight after grazing in the infield, or a deer bounding across 

a runway—all can result in significant aircraft damage or in extreme cases, a crash and 

loss of human lives. In addition to strikes, wildlife that are roosting, nesting, or 

burrowing on airports can cause structural damage to buildings, equipment, and aircraft 

as well as nuisance and health problems for workers and passengers. 
112 Control Techniques Chapter 9 

As discussed in Chapters 5 and 6 about the conduct of Wildlife Hazard Assessments 

and development of Wildlife Hazard Management Plans, the first step in solving any 

wildlife damage problem is to answer the following nine questions for each species: 

1. What are the wildlife doing that make the control of their numbers or damage 

necessary? The type of activity that needs to be controlled will determine both the 

severity of the problem and the type of control methods used. 

2. Which species of wildlife are causing 

the problem? Accurate identification 

of the exact species is critical 

because different species often 

require different management 

techniques. 

3. Why are the wildlife on the airport? 

Are they attracted to the airport for 

food, water, or shelter; or are they 

just flying over the airport from 

nighttime roosting sites to daytime 

feeding sites? The answer to this 

question will determine, to a large 

extent, the most appropriate control 

methods to use. 

4. What are the daily and seasonal 

movement patterns of the wildlife 

among feeding, loafing, and 

roosting/nesting areas? Try to 

identify the times of day and 

seasons of year, as well as locations 

on airport, where the wildlife pose 

the most critical threat to aviation 

safety and where they are most 

vulnerable to management actions. 

5. What is the legal status at the 

federal, state, and local levels of the 

problem species? All wildlife 

species are not afforded equal legal 

protection by all levels of government. 

There should be zero tolerance for nesting by

Canada geese and other large birds at airports.

Permits should be in place so any nests discovered

can be destroyed immediately and adult nesting

birds dispersed or removed (photo by R. White,

USDA). 

6. What effective and legal management methods are available? In wildlife hazard 

management, effective and legal are not necessarily synonymous. 

7. How selective are these control methods? The objective is to control only the target 

wildlife, not every species in the area. 

8. How much will it cost to apply the selected control methods? The cost of control 

might dictate which methods are practical, given the seriousness of the threat 

caused by the species. 
Chapter 9 Control Techniques 113 

9. What are public attitudes toward the problem wildlife species and the hazards that 

these species pose? Public opinion also may influence the type of management 

actions taken. 

This chapter presents the overall 

approach to be taken when managing 

wildlife hazards on airports. Once the 

overall approach is established, the 

chapter outlines the strengths and 

weaknesses of various wildlife control 

methods recommended for use on 

airports, as well as certain methods 

that should not be used. This chapter 

is not the final word on this subject. 

Wildlife damage control is a dynamic 

field, and new products, technologies, 

and innovations are continuously 

being introduced. In addition, changes 

in the legal status of control 

techniques, chemical registrations, 

and wildlife species occur at the 

federal and state level. Thus, this 

chapter is only a starting point for 

information on wildlife control 

techniques. 

Elimination of wildlife habitat and attractants on or

near airports will reduce wildlife strikes. Exposed I

beams, such as used in the canopy over the

passenger pick-up area at a Midwestern USA airport,

make ideal roosting habitat for flocks of European

starlings (photo by R. White, USDA). 

It is recommended that this chapter be used in conjunction with the two-volume manual 

Prevention and Control of Wildlife Damage published in 1994 by Cooperative Extension, 

University of Nebraska at Lincoln (see full citation at end of this chapter). This manual, 

written by various experts in the field of wildlife damage control, provides detailed 

information on the techniques, equipment, chemical registrations, species-specific 

management recommendations, and sources of supply for the various control strategies 

presented in this chapter. This manual is also available online in a periodically updated 

version at: ianrwww.unl.edu/wildlife/solutions/handbook/. 

9.2 WILDLIFE CONTROL STRATEGIES

Four basic control strategies are available to solve wildlife problems on airports: 

1. Aircraft flight schedule modification; 

2. Habitat modification and exclusion; 

3. Repellent and harassment techniques; and 

4. Wildlife removal. 

Integrate all four control strategies into the Wildlife Hazard Management Plan as 

appropriate. 
114 Control Techniques Chapter 9 

9.2.A AIRCRAFT FLIGHT SCHEDULE MODIFICATION

Although not generally practical for regularly scheduled commercial traffic on larger 

airports, there may be various situations when flight schedules of some aircraft can be 

adjusted to minimize the chance of a strike with a wildlife species that has a predictable 

pattern of movement. For example, pilots could be 

advised not to depart during a 20-minute period at 

sunrise or sunset during winter when large flocks of 

blackbirds cross an airport going to and from an offairport roosting site. In situations such as at Midway 

Atoll where albatrosses and other seabirds are 

abundant during parts of the year, scheduling 

nighttime arrivals and departures, when birds are not 

flying, might be the only means of avoiding strikes. 

Finally, air traffic controllers on occasion might need 

to temporarily close a runway with unusually high 

bird activity or a large mammal (e.g., deer) incursion 

until wildlife control personnel can disperse the 

animals. 

9.2.B HABITAT MODIFICATION AND EXCLUSION

Habitat modification means changing the 

environment to make it less attractive or 

inaccessible to the problem wildlife. All wildlife 

require food, cover, and water to survive. Any action 

that reduces, eliminates, or excludes one or more of 

these elements will result in a proportional reduction 

in the wildlife population at the airport. Habitat 

modifications to make the airport and surrounding 

area as unattractive as possible to hazardous 

wildlife must be the foundation of every airport’s 

Wildlife Hazard Management Plan. 

 

Poles and other structures that are

no longer in use should be removed

from airport property. Such

structures make ideal perching sites

for hawks and owls searching for

prey. The pellets at the base of this

pole are undigested fur and bones

of rodents that were regurgitated by

red-tailed hawks (photo by R. A.

Dolbeer, USDA). 

Initially, management actions to reduce food, cover, and water on an airport might be 

expensive. However, when costs are amortized over several years, these actions might 

be the least expensive approach to reducing wildlife populations on the airport. Once a 

habitat modification is done correctly, it is generally not necessary to go back and do it 

again. Also, these control methods are generally well accepted by the public and 

minimize the need to harass or kill wildlife on the airport. 

9.2.B.I FOOD

Some of the more common urban food sources for birds on and near airports include 

handouts from people in taxi stands and parks, grain elevators, feed mills, sewer 

treatment plants, and improperly stored food waste around grocery stores, restaurants, 

and catering services. Rural food sources attractive to birds include sanitary landfills, 

feedlots, certain agricultural crops (especially cereal grains and sunflower), and spilled 

grain along road and rail rights-of-way. 
Chapter 9 Control Techniques 115 

Be aware of food attractants for birds that exist on and in proximity to the airport. On 

the airport, require bird-proof storage of food waste, prohibit bird feeding, and promote 

good sanitation and litter control programs. 

Because most, if not all, agricultural 

crops can attract hazardous wildlife 

during some phase of production, the 

FAA recommends against the use of 

airport property for agricultural 

production, including hay crops, within 

the separations identified in Chapter 5, 

§ 5.2. If the airport has no financial 

alternative to agricultural crops to 

produce income necessary to maintain 

the viability of the airport, then the 

airport must follow the crop distance 

guidelines listed in the table titled 

"Minimum Distances between Certain 

Airport Features and Any On-Airport 

Agricultural Crops" found in AC 

150/5300-13, Airport Design, Appendix 

19 (see Appendix C). Weigh the cost 

of wildlife control and potential 

accidents against the income produced by the on-airport crops when deciding whether 

to allow crops on the airport (AC 150/5200-33A) (see Chapter 5 and Appendix C). For 

nearby off-airport areas, work closely with local governmental entities and landowners 

to discourage land-use practices and activities that provide food sources for problem 

bird species. 

Gulls and other birds concentrate at locations where

people regularly provide food such as bread and

seeds. Feeding birds should be prohibited on and in

the vicinity of airports (photo by R. White, USDA). 

Do not use trees and other landscaping plants for the street side of airports that produce 

fruits or seeds attractive to birds. On airside areas, the large expanses of grass and 

forbs can sometimes provide ideal habitat for rodent and insect populations that attract 

raptors, gulls, other bird species, and mammalian predators such as coyotes. In 

addition, grasses allowed to produce seed heads can provide a desirable food source 

for doves, blackbirds, and other flocking species. The management of airside 

vegetation to minimize rodents, insects, and seeds might be complex, requiring 

insecticide, herbicide, and rodenticide applications; changes in vegetation cover; and 

adjustments in mowing schedules (e.g., mowing at night to minimize bird feeding on 

insects exposed by the mowing). Such management plans will need to be developed in 

conjunction with professional wildlife biologists and horticulturists knowledgeable with 

the local wildlife populations, vegetation, and growing conditions (see below). 

9.2.B.II COVER

All wildlife require cover for resting, roosting, escape, and reproduction. Non-migratory 

Canada geese in urban areas, left undisturbed, will establish territories on corporate 

lawns, golf courses, and even building roofs associated with nearby ponds. Pigeons, 

house sparrows, and European starlings use building ledges, abandoned buildings, 

open girders and bridge work, and dense vegetation for cover. Blackbirds use marsh 
116 Control Techniques Chapter 9 

vegetation, such as cattails, for nesting and roosting. Many bird problems can be 

solved by eliminating availability of such areas either through removal or by exclusion. 

Take care when selecting and spacing 

plants for airport landscaping. Avoid 

plants that produce fruits and seeds 

desired by birds. Also avoid the 

creation of areas of dense cover for 

roosting, especially by European 

starlings and blackbirds. Thinning the 

canopy of trees, or selectively 

removing trees to increase their 

spacing, can help eliminate bird roosts 

that form in trees on airports. 

The management of an airport’s 

airside ground cover to minimize bird 

activity is a controversial subject in 

North America. The general 

recommendation, based on studies in 

England in the 1960s and 1970s, has 

been to maintain a monoculture of 

grass at a height of 6-10 inches 

(Transport Canada) or 7-14 inches 

(U.S. Air Force). Tall grass, by 

interfering with visibility and ground 

movements, is thought to discourage many species of birds from loafing and feeding. 

However, the limited studies conducted in North America have not provided a 

consensus of opinion on the utility of tall-grass management for airports. For example, 

Canada geese do not appear to be discouraged by tall grass. In addition, maintenance 

of tall grass can result in increased rodent populations, a food source for raptors. 

Finally, maintenance of monotypic, uniform stands of tall grass is difficult and expensive 

on many airports because of varying soil conditions and the need for fertilizer and 

herbicide applications. Arid regions in the western USA cannot maintain tall grass 

without irrigation. 

The maintenance of monotypic, uniform stands of tall

(e.g., 10-inch) grass is difficult and expensive at most

airports, requiring fertilizer, herbicides, and water

(photo by R. A. Dolbeer, USDA). 

A promising approach to reducing wildlife attraction to airport ground cover, irrespective 

of the height, is the use of vegetation that is undesirable or mildly toxic to wildlife. For 

example, there are varieties of fescue grass that contain fungal endophytes. Some of 

these endophytes are unpalatable to grazing birds, such as geese, as well as to rodents 

and deer. These endophytic grasses might also support fewer insect numbers. Other 

ground cover, such as wedelia or Bermuda grass, might be appropriate for subtropical 

airfields. Finally, artificial (synthetic) turf in selected areas might be useful in providing a 

more sterile environment for wildlife at airports. 

Until more research is completed, no general guidelines on grass height or vegetation 

type for airside ground cover will be made. See Appendix O, Summary of Studies on 

Vegetation Management for North American Airfields, for a literature review of the 

current state of knowledge on airport grass management. Consult with professional 
Chapter 9 Control Techniques 117 

wildlife hazard management biologists and horticulturists to develop a vegetation type 

and mowing schedule appropriate for the growing conditions and wildlife at the location. 

The main principles to follow are to use a vegetation cover and mowing regime that do 

not result in a build-up of rodent numbers or the production of seeds, forage, or insects 

desired by birds. 

Finally, dense stands of trees and undergrowth on airport property can provide excellent 

cover for deer, coyotes, nesting geese and raptors, roosting blackbirds, rodents, and 

other wildlife. In general, clear or at least sufficiently thin these habitats to eliminate the 

desired cover and to allow easy visual and physical access by wildlife control personnel. 

Remove all unnecessary posts, fences, and other structures that can be used as 

perches by raptors and other birds. 

Piles of construction debris and 

discarded equipment, unmowed fence 

rows, and other unmanaged areas are 

not only esthetically unpleasing but 

typically provide excellent cover for 

commensal rodents (rats and house 

mice) and den sites for woodchucks, 

feral dogs and coyotes. Eliminate 

such areas on airports. 

9.2.B.III WATER

Water acts as a magnet for birds; 

therefore, eliminate all standing water 

on an airport to the greatest extent 

possible. Fill or modify to allow rapid 

drainage of depressions in paved and 

vegetated areas, and disturbed areas 

at construction sites that accumulate 

standing water after rain. This is particularly important at coastal airports where fresh 

water is highly attractive to birds for drinking and bathing. Do not establish retention 

ponds, open drainage ditches, outdoor fountains and other wetland sites on or adjacent 

to airports. 

Standing water is a strong attractant to waterfowl,

gulls, and wading birds such as egrets and herons.

Airport managers should strive to eliminate all

standing water (photo by R. A. Dolbeer, USDA). 

Where possible, modify storm water detention ponds to allow a maximum 48-hour 

detention period for the design storm. Avoid or remove retention ponds and detention 

ponds featuring dead storage to eliminate standing water. Design detention basins to 

remain totally dry between rainfalls. Where constant flow of water is anticipated through 

the basin, or where any portion of the basin bottom might remain wet, design the 

detention facility to include a concrete or paved pad and/or ditch/swale in the bottom to 

prevent vegetation that might provide nesting habitat. 

When it is not possible to drain a large detention pond completely, use physical barriers, 

such as bird balls, wires grids, pillows, or netting, to deter birds and other hazardous 

wildlife. Evaluate the use of physical barriers and ensure they will not adversely affect 

water rescue. Before installing any physical barriers over detention ponds on Part 139 
118 Control Techniques Chapter 9 

certificated airports, obtain approval from the appropriate FAA Regional Airports 

Division Office. 

Encourage off-airport storm water 

treatment facility operators to 

incorporate appropriate wildlife hazard 

mitigation techniques into their 

operating practices when the facility is 

located within the separation criteria 

specified in AC 150/15200-33A (see 5-2 

above and Appendix C). 

9.2.B.IV EXCLUSION TECHNIQUES

Birds are permanently excluded from this storm

water detention facility through the use of a floating

permeable barrier (Photo courtesy Industrial &

Environmental Concepts, Inc.). 

If food, water, or cover cannot be 

eliminated by habitat modification, then 

actions can sometimes be taken to 

exclude the wildlife from the desired 

resource. Exclusion involves the use of 

physical barriers to deny wildlife access 

to a particular area. As with habitat 

modification, exclusion techniques, such 

as installing a covered drainage ditch instead of an open ditch, can initially be costly. 

However, exclusion provides a permanent solution that is not only environmentally 

friendly, but when amortized over many years, might actually be the least expensive 

solution. 

9.2.B.IV.A EXCLUSION OF BIRDS

Architects should consult biologists 

during the design phase of buildings, 

hangers, bridges, and other structures at 

airports to minimize exposed areas that 

birds can use for perching and nesting. 

For example, tubular steel beams are 

much less attractive as perching sites for 

starlings and pigeons than are I-beams. 

If desirable perching sites are present in 

older structures, access to these sites 

(such as rafter and girded areas in 

hangers, warehouses, and under 

bridges) often can be eliminated with 

netting. Curtains made of heavy-duty 

plastic sheeting, cut into 12-inch strips, 

and hung in warehouse or hanger 

doorways, can discourage birds from 

entering these openings. Anti-perching devices, such as spikes, can be installed on 

ledges, roof peaks, rafters, signs, posts, and other roosting and perching areas to keep 

certain birds from using them. Changing the angle of building ledges to 45 degrees or 

 

Light posts and other structures in taxicab lots at

airports can be fitted with anti-perching devices to

discourage gulls and other birds from using the

area. Feeding of birds should also be prohibited

on airport property. 
Chapter 9 Control Techniques 119 

more will deter birds. However, it is emphasized that incorporating bird exclusion or 

deterrence into the design of structures is the most effective, long-term solution. 

Gull and waterfowl use of retention ponds and drainage ditches can be reduced with 

over-head wire systems. A system of wires spaced 10 feet apart or in a 10- x 10-foot 

grid will discourage most gulls and waterfowl from landing. Similar wire systems have 

been successfully used to keep gulls off roofs and out of landfills and crows out of 

electrical substations. When it is 

desirable to eliminate all bird use, 

netting can be installed over small 

ponds and similar areas. However, 

birds are sometimes tangled in the 

netting and maintenance problems 

arise with high winds and freezing 

weather. Complete coverage of 

ponds with plastic, 3-inch diameter 

“bird balls” or floating mats will 

completely exclude birds and yet 

allow evaporation of water. 

Designing ponds with steep slopes 

will discourage wading birds such as 

herons. Use of culverts to totally 

cover water in drainage ditches is 

recommended whenever possible. 

9.2.B.IV.B EXCLUSION OF MAMMALS

Institute a “zero tolerance” policy for 

deer, livestock, and other large 

mammals in the AOA because of 

their severe threat to aviation safety 

(see Table 8-1). The best, albeit 

most costly, procedure for excluding 

these animals off the AOA is proper 

fencing. The FAA recommends a 10-

12 foot chain link fence with 3-strand 

barbed wire outriggers. In some 

cases, an airport might be able to use 

an 8-foot chain link fence with 3-

strand barbed outriggers, depending 

on the amount of deer activity in the 

area (see Certalert No. 04-16, 

Appendix E). A 4-foot skirt of chainlink fence material, attached to the bottom of the fence and buried at a 45o

 angle on the 

outside of the fence will prevent animals from digging under the fence and reduce the 

chance of washouts. This type of fencing also greatly increases airport security. There 

are also numerous electric-fence designs for excluding deer, discussed in Hygnstrom et 

al. (1994), that are not as costly as permanent fencing but have drawbacks in safety 

A well-maintained fence, at least 10-feet high with no

gaps at the bottom, is the primary defense to keep

deer and other large animals off of the AOA at airports.

Gates must also be close-fitting, and water drains

under the fence must be equipped with exclusion

devices (top photo by E. Cleary, FAA). 
120 Control Techniques Chapter 9 

and maintenance. 

Properly install and maintain all fencing. Keep the fence line right-of-way free of excess 

vegetation. Patrol the fence line at least daily, and fix any washouts, breaks, or other 

holes in the fence as soon as they are discovered. Take immediate action to remove 

any deer or other large mammals observed on or near the AOA. 

Cattle Guards are widely used to prevent hoofed livestock from traversing across 

fenced areas through permanent openings maintained for vehicular access. These 

devices, if at least 15 feet in length perpendicular to the fence, will prevent deer from 

entering through gated areas on airports. 

9.2.C REPELLENT TECHNIQUES

Repellent and harassment techniques 

are designed to make the area or 

resource desired by wildlife 

unattractive or to make the wildlife 

uncomfortable or fearful. Long term, 

the cost-effectiveness of repelling 

wildlife usually does not compare 

favorably with habitat modification or 

exclusion techniques. No matter how 

many times wildlife are driven from an 

area that attracts them, they or other 

individuals of their species will return 

as long as the attractant is accessible. 

However, habitat modifications and 

exclusion techniques will never 

completely rid an airport of problem 

wildlife; therefore, repellent techniques 

are a key component of any wildlife 

hazard management plan. 

Under low-light conditions, specially designed lasers

can be effective in dispersing geese, cormorants, and

other bird species. 

Repellents work by affecting the animal's senses through chemical, auditory, or visual 

means. Habituation or acclimation of birds and mammals to most repellent devices or 

techniques is a major problem. When used repeatedly without added reinforcement, 

wildlife soon learn that the repellent devices or techniques are harmless. The devices 

become a part of their “background noise”, and they ignore them. 

Critical factors to be recognized in deploying repellents are— 

1. There are no “silver bullets” that will solve all problems; 

2. Likewise, there is no standard protocol or set of procedures that is best for all 

situations. Repelling wildlife is an art as much as a science. The most important 

factor is having motivated, trained, appropriately equipped personnel who 

understand the wildlife situation on their airport; 

3. Each wildlife species is unique and will often respond differently to various repellent 

techniques. Even within a group of closely related species, such as gulls, the 
Chapter 9 Control Techniques 121 

various species will often respond differently to various repellent techniques; and 

4. Habituation to repellent techniques can be minimized by— 

a) using each technique sparingly and appropriately when the target wildlife is 

present, 

b) using a variety of repellent techniques in an integrated fashion, and 

c) reinforcing repellents with occasional lethal control (with necessary permits in 

place) directed at abundant problem species such as gulls or geese. 

Advances in electronics, remote sensing capabilities, and computers are resulting in the 

development of “intelligent” systems that can automatically deploy repellent devices 

(e.g., noisemakers, chemical sprays) when targeted wildlife enter a designated area. 

These devices might help reduce habituation and increase effectiveness of repellents in 

some situations. However, these devices will never replace the need for trained people 

on the ground to respond appropriately to incursions by a variety of highly adaptable, 

sentient wildlife species. 

9.2.C.I WILDLIFE PATROLS AND RUNWAY SWEEPS IN VEHICLES

Regular patrols of airside areas to disperse birds and other hazardous wildlife are a 

critical component of an integrated program of wildlife hazard management on airports. 

Often, driving a vehicle toward the wildlife will be enough to cause the wildlife to 

disperse, especially if the driver has been deploying repellent and removal techniques 

and strategies as outlined below. 

Regular patrols and sweeps also 

permit wildlife control personnel to 

learn the daily movement patterns, 

habitat preferences, and behavior of 

wildlife on the airport. This information 

can be useful in determining wildlife 

attractants on the airport that need to 

be removed (e.g., low areas that 

gather standing water after rains) and 

in anticipating problem situations. All 

wildlife carcasses found during runway 

sweeps should be removed, identified 

to species, and documented on a 

wildlife strike log for carcass remains 

(Table 7-2). 

9.2.C.II CHEMICAL REPELLENTS FOR 

BIRDS

Chemical repellents, toxicants, and 

capturing agents must be registered with the U.S. Environmental Protection Agency 

(USEPA) or Food and Drug Administration (FDA) before they can be used to manage 

wildlife on airports. Products must also be registered in each state. Hygnstrom et al. 

(1994) provides a listing of chemical products, by active ingredient and by company 

Chemical repellents, such as methyl anthranilate, can

be applied to temporary pools of standing water on

airports to repel birds until the water evaporates. The

preferred long-term solution is to improve drainage to

avoid standing water after significant rain events

(photo courtesy USDA). 
122 Control Techniques Chapter 9 

name, registered for birds and mammals. The following chemical repellents, listed by 

active ingredient, are presently available for use on airports. 

Perching structures (polybutenes). Several commercial products are available in liquid 

or paste form. These sticky formulations make birds uncomfortable when they alight on 

them, encouraging the birds to look elsewhere to perch or roost. To be effective, all 

perching surfaces in a problem area must be treated, or the birds will move a short 

distance to an untreated surface. Under normal conditions, the effective life of these 

materials is 6 months to 1 year. Dusty environments can substantially reduce the life 

expectancy. Once the material loses effectiveness, it is necessary to remove the old 

material and apply a fresh coat. Applying the material over duct tape, rather than 

directly to the building ledge or rafter surface, will facilitate clean up. 

Turf feeding (methyl anthranilate, anthraquinone). There are two chemicals presently 

(2005) registered as bird repellents for turf (grass). One repellent is an anthraquinone 

formulation for repelling geese from turf. Anthraquinone apparently acts as a 

conditioned-aversion repellent with birds. Birds ingesting food treated with 

anthraquinone become slightly ill and develop a post-ingestion aversion to the treated 

food source. Birds visually identify anthraquinone in the UV light spectrum and become 

conditioned to avoid the treated food source. Because of its conditioned-aversion 

properties, anthraquinone use does not require treatment of the entire airfield, but only 

areas where birds are grazing and/or higher risk areas such as runway approaches. 

The other repellent is methyl anthranilate, an artificial grape flavoring commonly used in 

foods and beverages. Birds have a taste aversion to methyl anthranilate, apparently 

reacting to it in much the same way that mammals react to concentrated ammonia 

(smelling salts). Methyl anthranilate 

is registered under formulations as a 

feeding repellent for geese and other 

birds on turf. 

Both anthraquinone and methyl 

anthranilate products are liquid 

formulations applied by sprayer to 

the vegetation. Effectiveness of 

these sprays in repelling geese can 

be variable, depending on growing 

conditions, rainfall, mowing, and 

availability of alternate feeding areas. 

In general, repellency based on 

conditioned aversion is longer lasting 

than repellency based on taste. 

Water (methyl anthanilate). Methyl 

anthranilate formulations are also 

available for application to pools of standing water on airports and at other locations to 

repel birds from drinking and bathing. This application is probably best for temporary 

pools of water after rainfall, where repellency of only a few days is needed. 

A recent study showed that predator urines (coyote,

bobcat) had no influence on deer movements along

established trails or at feeding sites (photo by T.

Seamans, USDA). 

General area (fogging with methyl anthanilate). A methyl anthranilate formulation is 
Chapter 9 Control Techniques 123 

also available for use in fogging machines (thermal or mechanical) to disperse birds 

from hangers, lawns, and other areas. 

Frightening agent (Avitrol [4-Aminopyridine]). Avitrol is registered for repelling pigeons, 

house sparrows, black-birds, grackles, cowbirds, starlings, crows, and gulls from 

feeding, nesting, loafing, and roosting sites. Birds eating Avitrol-treated baits react with 

distress symptoms and calls, behaviors that frighten away other birds in the flock. 

Avitrol, although registered as a “frightening agent”, is lethal to the birds that eat treated 

baits. Therefore, recognize that Avitrol is a toxic to the birds that consume treated bait. 

Avitrol-treated bait is diluted with untreated bait so most birds in the flock do not ingest 

treated bait. The primary use of Avitrol at airports has been in pigeon control around 

buildings. The use of Avitrol requires knowledge of the feeding patterns of the birds, 

proper prebaiting procedures to ensure bait acceptance and avoidance of non-target 

species, and removal of dead birds after treatment. 

9.2.C.III CHEMICAL REPELLENTS FOR MAMMALS

There are a number of taste and odor 

repellents marketed to repel deer, rabbits, 

and other mammals from browsing on 

vegetation (Hygnstrom et al. 1994). These 

include products that are applied directly to 

the vegetation and general area (odor) 

repellents (e.g., predator urine). Some of 

these products might be appropriate for 

short-term protection of valuable landscaping 

plants and fruit trees. However, their use on 

airports to repel or discourage deer or other 

mammals is not recommended because they 

are unlikely to have any influence on wildlife 

movements in the airport operating area. 

9.2.C.IV AUDIO REPELLENTS FOR BIRDS

Propane cannons. Propane cannons 

(exploders) generate a shotgun-sounding 

blast. In general, birds quickly habituate to 

cannons that detonate at systematic or 

random intervals throughout the day. Thus, 

to ensure they remain effective, use cannons 

sparingly and only when birds are in the area. 

Reinforcement by occasional killing a few 

birds (of common species such as gulls and 

Canada geese under an appropriate permit) 

with a shotgun might also enhance effectiveness. Systems designed so cannons 

placed around an airport can be detonated remotely on demand by radio signal when 

birds are in the area are a useful means of reducing habituation. 

In most cases, birds rapidly adapt to and

then ignore recorded distress calls and other

noises produced by electronic auditory

devices. Such devices, as shown on the

pole in the photo, can be useful only if used

sparingly as part of an integrated program of

bird dispersal (photo by R. A. Dolbeer,

USDA). 

Distress-call and electronic noise-generating systems. Recorded distress calls are 

available for common birds on airports, such as gulls, crows, and starlings. Such calls, 
124 Control Techniques Chapter 9 

broadcast from speakers mounted on a vehicle, will often initially draw the birds toward 

the sound source to investigate the threat. The birds then can be dispersed by 

pyrotechnics or by using a shotgun to shoot an occasional bird. As with propane 

cannons, distress calls routinely broadcast from stationary speakers, with no associated 

follow-up stimuli that provide additional fear or stress, have little utility. Birds also 

habituate rapidly to other electronic sound systems that generate a variety of synthetic 

sounds from stationary speakers. 

Shell crackers and other 

pyrotechnics. There are a variety 

of projectiles that can be fired from 

breech-loaded shotguns or from 

specialized launchers to provide an 

auditory blast or scream, as well as 

smoke and flashing light, to 

frighten birds. Some of the newer 

cartridges have ranges of up to 

300 yards. These pyrotechnics, 

when used skillfully in combination 

with other harassment techniques 

and limited lethal control (shooting 

via shotgun), can be very useful in 

driving birds off of an airport. An 

advantage of these pyrotechnic 

devices is that they require a 

person to fire the projectile, thus 

ensuring that they are deployed 

directly at the target birds and that 

the birds associate the pyrotechnic 

with a threat (person). 

Taxidermy mounts of coyotes deployed to move in the

wind might be useful as part of an integrated program to

disperse Canada geese and other birds from airports.

Such effigies must be used sparingly and moved to

various locations to prevent habituation. Permanently

mounted effigies have little deterrent effect (photo by R.

A. Dolbeer, USDA). 

Ultrasonic devices. Ultrasonic (i.e., above the sound range detected by humans) 

devices have not proven to be effective bird repellents. In fact, most birds do not detect 

frequencies as high as humans can detect, much less frequencies above the level of 

human detection. During tests conducted by the U.S. Department of Agriculture’s 

National Wildlife Research Center, pigeons showed no response when exposed within 

10 feet to a fully functional, high-frequency sound generating device. Do not deploy 

these devices in hangers or other airport settings to deter birds. 

9.2.C.V AUDIO REPELLENTS FOR MAMMALS

Probably the most commonly used audio scaring device for deer is the propane cannon. 

However, deer rapidly habituate to propane cannons. Their use on airports to repel 

deer and other mammals from runways is not recommended except for short-term (i.e., 

several days), emergency situations until a more permanent solution (fencing or deer 

removal) can be achieved. Other electronic noise-generating devices also have proven 

ineffective in repelling deer or other mammals for more than a few days. Pyrotechnics 

also provide only short-term repellency for mammals. 
Chapter 9 Control Techniques 125 

9.2.C.VI VISUAL REPELLENTS FOR BIRDS

Most visual repellents are simply a variation on an ancient theme—the scarecrow. In 

general, visual repellents, such as hawk effigies or silhouettes, eye-spot balloons, flags, 

and Mylar reflecting tapes, have shown only short-term effectiveness and are 

inappropriate for use as a long-term solution to bird problems on airports. Most shortterm success achieved with these devices is likely attributable to "new object reaction" 

rather than to any actual frightening effect produced by them. For example, in a test in 

Ohio, a flag with a large eye-spot was exposed to pigeons in an abandoned building. 

As soon as the flag was put up, the pigeons left the building, giving the impression that 

the eye-spot was highly repellent to the birds. However, within 24 hours, the pigeons 

returned. From then on, the pigeons behaved in a completely normal fashion and 

showed no interest in, or reaction to, the flag. 

One visual deterrent that has been 

successfully used in recent years is the 

display of dead birds in a “death pose.” 

Several experiments and field 

demonstrations have shown that a dead 

turkey vulture (freeze-dried taxidermy mount 

with wings spread), hung by its feet in a 

vulture roosting or perching area, will cause 

vultures to abandon the site. Initial trials 

using dead gulls and ravens suspended 

from poles have also shown promising 

results in dispersing these species from 

feeding and resting sites. The dead bird 

must be hung in a “death pose” to be 

effective. Dead birds lying supine on the 

ground or in the roost are generally ignored 

or might even attract other birds. Permits 

must be in place before federally protected 

migratory birds can be obtained and used as 

“dead-bird deterrents.” Research is under 

way to determine if artificial “dead-bird 

effigies” can be developed that will be just as 

effective as the taxidermy mounts. 

Another new concept in visual repellency 

that has shown utility in recent years is the 

use of hand-held laser devices that project a 

1-inch diameter red beam to disperse birds. 

These devises have been used successfully 

to disperse birds such as Canada geese, 

double-crested cormorants, and crows from 

nighttime roosting areas in reservoirs and trees. Advantages are effectiveness at long 

range (over 1⁄4 mile) and lack of noise. Lasers have also shown some effectiveness in 

dispersing birds from hangers. Effectiveness is diminished or nonexistent in daylight 

The successful use of border collies to repel

birds requires a high degree of dedication and

commitment by the handlers. Jet was among

the first border collies to successfully work at

an airport to control birds. 
126 Control Techniques Chapter 9 

conditions. As with the use of firearms, the use of lasers in an airport environment 

obviously requires caution. 

9.2.C.VII VISUAL REPELLENTS FOR MAMMALS

For the most part, visual repellents such as flags and effigies have proven ineffective for 

repelling mammals. Their use is not recommended for keeping deer or other mammals 

off airports. Red lasers (see above) were ineffective in dispersing deer. 

9.2.C.VIII TRAINED FALCONS AND DOGS TO REPEL BIRDS

Trained falcons and other birds of prey 

have been used intermittently on 

various airports in Europe and North 

America to disperse birds since the 

late 1940s. The advantage of falconry 

is that the birds on the airport are 

exposed to a natural predator for which 

they have an innate fear. The 

disadvantage is that a falconry 

program is often expensive, requiring a 

number of birds that must be 

maintained and cared for by a crew of 

trained, highly motivated personnel. 

Furthermore, the effectiveness of 

falconry programs in actually reducing 

strikes has been difficult to evaluate. 

Blokpoel (1976) outlined the following 

summary of falconry for airports that is 

still a good overall assessment: (1) 

properly trained birds of prey of the 

right species for the job at hand, used regularly and persistently by skilled and 

conscientious personnel, are effective in clearing birds from airfields during daylight and 

good weather; (2) for good results, daily operations on a year-round basis are required 

in most cases, (3) several falcons are required to have at least one bird ready at all 

times, and (4) to obtain, train, operate, and care for falcons, a staff of at least two fulltime, well-trained personnel is required. 

Radio-controlled aircraft, such as this

Robo-FalconTM, can be useful as part of an

integrated program in dispersing birds from airports

and landfills. Considerable training is required to

operate these devices in the airport environment

(photo by R. A. Dolbeer, USDA). 

The use of trained dogs, especially border collies, to chase geese and other birds from 

golf courses, airports, and other sites is a recent development. As with falcons, the 

advantage is exposure to a natural predator. Likewise, the disadvantage is that the dog 

must be under the control of a trained person at all times, and the dog must be cared for 

and exercised 365 days a year. A dog will have little influence on birds that are flying 

over the airport. 

9.2.C.IX RADIO-CONTROLLED MODEL AIRCRAFT TO REPEL BIRDS

Radio-controlled (RC) model aircraft, which provide both visual and auditory stimuli, 

occasionally have been used to harass birds on airports. One advantage is that the RC 

aircraft is under the control of a person and can be directed precisely to herd the birds 
Chapter 9 Control Techniques 127 

away from the airport runway. A second advantage is that the RC aircraft can be 

deployed on an “as needed” basis with little maintenance needed between flights. 

Some RC aircraft have been designed to mimic the appearance of a falcon and even to 

remotely fire pyrotechnics. The disadvantage is that a trained person is required to 

operate the RC aircraft in an airport environment. Before using RC aircraft, ensure that 

the radio frequencies used are compatible with other radio uses in the airfield 

environment. 

9.2.C.X NONLETHAL PROJECTILES TO REPEL BIRDS

Paint balls and rubber or plastic projectiles, fired from paint-ball guns and 12-gauge 

shotguns, respectively, can be used to reinforce other dispersal techniques employed to 

repel Canada geese, roosting vultures, and perhaps other species of birds. With paint 

balls, a high-quality paint-ball gun should be used to provide sufficient accuracy and 

velocity (typically fired from 20 to 100 feet from bird). There are several types of rubber 

or plastic projectiles (slugs, buck 

shot, pellets, beads) for use in a 

shotgun. The proper distance from 

the bird for firing varies by 

projectile and species of bird. 

Personnel using these techniques 

need to be trained in firearm use 

and in the use of the particular 

projectiles being deployed. The 

objective is to shoot from a 

sufficient distance so that the 

projectile induces temporary pain, 

but no injury, in the bird struck. 

9.2.D WILDLIFE REMOVAL 

TECHNIQUES

Habitat modification, exclusion, and 

repellent techniques are the first 

lines of action in any Wildlife 

Hazard Management Plan. However, these actions will not solve every problem; 

therefore, hazardous wildlife sometimes must be removed from an airport. Such 

removal can be accomplished by capturing and relocating or by killing the target 

animals. With few exceptions, a federal Migratory Bird Depredation Permit, and in 

many cases a state permit, is required before any migratory birds may be taken 

(captured or killed). A state permit is generally necessary before any state-protected 

birds or mammals may be taken. Any capturing or killing must be done humanely and 

only by people who are trained in wildlife species identification and the techniques to be 

deployed. 

Birds of prey, such as this red-tailed hawk, are captured

with bal-chatri traps at some USA airports and relocated

50-100 miles from the airport. Studies have shown that

relocated juvenile hawks typically do not return to the

airport. Adult territorial birds will often return (photo

courtesy of L. Schafer, USDA). 

9.2.D.I CAPTURING BIRDS AND MAMMALS

The disposition of live-captured birds and mammals will depend on the legal, political, 

and social realities of each situation. State wildlife agencies are increasingly restrictive 
128 Control Techniques Chapter 9 

about the relocation of captured wild animals, particularly for common species, because 

of disease concerns and the creation of additional wildlife problems at release sites. 

When practical, euthanize unprotected birds, such as pigeons, house sparrows, and 

European starlings, using procedures recommended by the American Association of 

Wildlife Veterinarians (AAWV). Dispose of common mammals, such as raccoons, 

woodchucks, and coyotes, captured on airports by following state regulations. Resident 

Canada geese captured during molt or by nets can be euthanized and donated to soup 

kitchens or food banks, provided the necessary federal and state permits are in place. 

9.2.D.I.A CHEMICAL CAPTURE OF BIRDS 

Alpha Chloralose (A-C) is registered with the FDA as an immobilizing agent for use in 

capturing waterfowl, coots, and pigeons. A-C can only be used by people certified to 

use A-C working under the authority of personnel with the U.S. Department of 

Agriculture Wildlife Services (USDA/WS). A-C, incorporated into bread baits, is ideal for 

selectively capturing ducks, geese, and coots that can be hand-fed at urban ponds and 

parks. Corn baits are recommended 

for pigeons or groups of waterfowl or 

coots that cannot be individually 

baited. Birds ingesting a clinical dose 

of A-C can be captured in 30- to 90-

minutes. Complete recovery normally 

occurs within 8 hours but can take up 

to 24 hours. 

Cannon or rocket nets are well suited for capturing

up to 100 or more waterfowl, pigeons, or gulls in

situations where other methods might not be

practical. The net must be placed where it can be

safely discharged, and the target birds must be

trained to feed in front of it. Depending on the

situation, prebaiting can take several days. Here,

white pelicans are being captured for banding to

study migration patterns (photo by T. King, USDA). 

9.2.D.I.B LIVE-TRAPPING BIRDS

The major advantage of live trapping is 

selectivity: any non-target birds can be 

released unharmed. The major 

disadvantage is that live trapping is 

often labor intensive. Traps must be 

tended frequently to remove captured 

animals and, in the case of cage traps 

with decoy birds, to provide food and 

water. Hygnstrom et al. (1994) 

provides detailed descriptions of 

various trap designs. 

Trapping is used on some airports to remove raptors (hawks and owls) in the aircraft 

operating area. Bal-chatri, noose carpets, Swedish goshawk, or sliding padded pole 

traps are typically used. Because raptors are desirable components of bird 

communities, most permits for trapping raptors require that the birds be banded and 

relocated into suitable habitat at least 50 miles from the airport. 

Live trapping, using walk-in type traps on roofs or other isolated sites, can be used to 

remove pigeons at airports. Euthanize captured pigeons following AAWV guidelines. If 

relocated, pigeons can fly long distances to return to the site of capture. 

Net launchers use a blank rifle cartridge to propel a net. Fired from the shoulder much 
Chapter 9 Control Techniques 129 

like a shotgun or rifle, net launchers can capture individual or small groups of problem 

birds that can be approached within about 50 feet. 

9.2.D.I.C CHEMICAL CAPTURE OF MAMMALS

Large mammals, such as deer, can be captured with tranquilizer guns, but this is 

generally not a practical or desirable option for airports. Live capture and relocation of 

deer is not recommended or permitted in most states because deer populations are at 

or near carrying capacity. However, in those situations where the use of firearms is not 

safe or practical, the use of tranquilizer guns might be appropriate. The use of 

tranquilizer guns requires personnel with a high degree of skill and experience. If used 

in an airport environment, safeguards must be in place to ensure partially tranquilized 

deer do not enter runway areas. 

9.2.D.I.D LIVE-TRAPPING MAMMALS 

Specialized drop-door traps, drop nets, or rocket net set-ups can be used to live-capture 

deer, but live-capturing deer generally is not recommended for airport situations for 

reasons outlined above. However, smaller box-type or basket live-traps can be used to 

capture medium-sized mammals, such as raccoons, woodchucks, beavers, and feral 

dogs. Leg-hold traps and snares can be used to capture coyotes, feral dogs and 

raccoons. 

Successful mammal trapping, 

especially with leg-hold traps and 

snares, requires a high degree of skill 

and experience. Once set, traps must 

be checked frequently (at least once 

every 24 hours and more frequently in 

hot or cold weather). Trappers must 

be knowledgeable in procedures for 

handling and euthanizing mammals. 

State and local regulations might 

restrict the use of some types of traps. 

9.2.D.II KILLING BIRDS AND 

MAMMALS

In general, killing of wildlife on an 

airport is the last option deployed after 

habitat modification, exclusion 

techniques, and repellent actions have 

been implemented. However, the management of a wildlife hazard situation on an 

airport might require killing a particular animal or require that a local population of a 

problem species be reduced by lethal means until a long-term, nonlethal solution is 

implemented (e.g., erection of deer-proof fence, relocation of nearby gull nesting 

colony). In addition, lethal control of a few individuals is sometimes necessary to 

reinforce nonlethal frightening techniques. Some lethal control is usually necessary as 

part of an integrated Wildlife Hazard Management Plan for an airport. 

Hunting during the regular deer season should be

encouraged in areas adjacent to airports having deer

problems to reduce the population in the general

area. Archery hunting sometimes can be used in

areas closed to firearms (photo by E. Cleary, FAA).

The following information must be developed to justify lethal control and to minimize 
130 Control Techniques Chapter 9 

adverse public reaction to a program involving killing: 

• Documentation that the wildlife species is an economic, safety, or health threat. 

• Justification of why nonlethal options are not adequate to solve the problem. 

• An assessment of the impact that the killing will have on local and regional 

populations of the species (i.e., is the level of killing planned likely to result in a 

significant reduction in numbers of the species at the local or regional level?). 

• Assurance that the killing procedure is appropriate (i.e., safe, effective, and humane) 

and specific for the target wildlife species. 

• Documentation of the 

effectiveness of the killing 

program in helping to solve the 

problem (e.g., reduction in bird 

strikes). 

• Recommended steps to be taken, 

if any are feasible, to reduce the 

need for killing in the future. 

9.2.D.II.A DESTROYING EGGS AND 

NESTS

Do not allow Canada geese, mute 

swans, and gulls to nest on airport 

property. Provided the correct 

permits are in place, destroy (break 

eggs and remove nest material) any 

goose, mute swan, or gull nests with eggs found on an airport. Egg addling (oiling, 

shaking, or puncturing), whereby the birds continue to incubate nonviable eggs, is not 

recommended for airports. Egg addling encourages the nesting birds (and any 

nonbreeding birds associated with them) to stay on the airport. At the time of nest 

destruction, harass the adult birds from the airport. Check the nesting area weekly for 

renesting until the end of the nesting season (generally the end of June). As an 

alternative to harassment, it may be better to shoot nesting geese and mute swans (see 

below). 

Canada geese should not be allowed to nest on

airports. Nests and eggs should be destroyed after

appropriate permits are obtained (photo courtesy of

J. Bucknall, USDA).

Destroy pigeons, starlings, and house sparrows nests whenever they are encountered 

in airport buildings and structures. Where practical, install physical barriers, as 

discussed above, to prevent renesting. 

Nests of other birds hazardous to aviation generally also should be destroyed when 

encountered on airports. Remember that migratory bird nests are protected by federal 

law and may not be taken without a Depredation Permit. Each situation will have to be 

addressed on a case-by-case basis, depending on the species of bird and level of threat 

posed, location from runways, bird movement patterns, and other factors. 

9.2.D.II.B SHOOTING BIRDS

Shooting birds in an airport environment generally falls into two main categories. First, 
Chapter 9 Control Techniques 131 

pigeons using hangers, bridge girders, and other sites can be shot at night with an air 

rifle. This nighttime shooting is done quietly and discretely, with the objective being to 

disturb the birds as little as possible so that the maximum number can be removed. 

In the second category of shooting, common birds, such as gulls and geese, in the AOA 

that are not responding to various 

repellent methods can be shot with a 

12-gauge shotgun. This shooting is 

done during daylight in the open so 

that other birds can witness the action. 

Shooting a shotgun has several effects 

on a flock of birds. First, it reinforces 

other audio or visual repelling 

techniques. Second, the loud noise, 

coupled with the death of one or more 

of the flock members, can frighten the 

rest of the flock away. Third, the target 

birds are permanently removed. 

Four cardinal rules apply when using 

shooting as a control method at 

airports: 

1. Use only personnel who are trained 

in the use of firearms and who have 

an excellent knowledge of wildlife 

identification. 

2. Use the proper gun and 

ammunition for the situation. 

Compressed CO2-powered pellet rifles, with laser

pointers and telescopic sights, are an effective

means of removing rock doves (pigeons) from

hangers and other structures at airports. Personnel

must be properly trained in the use of all pyrotechnic

devices and firearms, and their use must be

coordinated with airport security (photo by R. A.

Dolbeer). 

3. Have necessary federal and state wildlife kill permits in place, and keep accurate 

records of birds killed by species and date. 

4. Notify airport security, air traffic control, and, if appropriate, the local law 

enforcement authority before instituting a shooting program. Local ordinances 

against the discharge of firearms within certain distances of buildings, or within the 

city limits, may need to be waived. 

9.2.D.II.C SHOOTING MAMMALS 

Adopt a “zero tolerance” for deer on airports. If fencing is inadequate to keep deer off 

an airport or if deer have gotten inside the airport’s fence, shooting is the best 

procedure for removing the deer. Because of inherent safety considerations and to 

ensure safe and efficient removal, shooting on airports must be by professional 

sharpshooters, using non-ricocheting bullets in rifles equipped with night-vision scopes 

and noise suppressers. Elevated shooting stands can be erected on the ground or on a 

truck bed to direct shots toward the ground. When practical, donate the meat from deer 

that are removed from airports to charity. Shooting of deer on airports must be 

coordinated through the state wildlife agency. 
132 Control Techniques Chapter 9 

Encourage hunting during the regular deer season in areas adjacent to airports with 

deer problems to reduce the population in the general area. Archery hunting sometimes 

can be used in areas closed to firearms. 

9.2.D.II.D ORAL TOXICANTS FOR BIRDS

Currently in the USA, only one oral toxicant, DRC-1339 or Starlicide (active ingredient 

3-chloro-p-toluidine hydrochloride), is registered with the USEPA for use in bird 

population management. Starlicide (0.1% active ingredient) is formulated in a pellet bait 

for use at feedlots to control starlings and blackbirds. DRC-1339 (98% active 

ingredient) can be formulated with a 

variety of baits and used to control 

starlings, pigeons, gulls, ravens, and 

blackbirds under certain conditions, 

some of which might be applicable at 

airports. The control of pigeons 

around airport buildings and starlings 

roosting on or near an airport are the 

situations most likely applicable. Only 

USDA/WS personnel or persons 

working under their direct supervision 

can use DRC-1339. 

The use of toxic baits to kill target birds 

without affecting non-target species 

requires considerable skill and 

patience. Daily movement patterns of 

the target birds among feeding, loafing, 

and roosting sites must be determined 

so attractive bait sites that are 

controlled from public access (such as 

a roof top) can be selected. The 

proper bait (a highly desired food) 

must be selected, and the birds then 

must be prebaited, often for a week or more, to ensure good bait acceptance and that 

non-target animals are not visiting the bait site. Proper prebaiting is the most critical 

step of a successful program. During the baiting period, all uneaten bait must be 

removed daily. With DRC-1339, birds typically die 1 to 3 days after bait ingestion; 

therefore, areas surrounding bait sites will need to be searched for several days after 

baiting to remove dead birds. 

This is the center portion of a zinc phosphide

rodenticide label showing the restricted use

statement, target species, and ingredients list. Other

parts of the label provide important information such

as the manufacturer, EPA registration number, and

the directions for use. Always read the entire label

before using any pesticide. 

9.2.D.II.E CONTACT TOXICANTS FOR BIRDS

Hollow metal perches containing a wick treated with the toxicant fenthion previously 

were used to control pigeons, house sparrows, and starlings in and around buildings. 

The USEPA has phased out the use of fenthion-treated perches because of concerns 

for secondary poisoning of raptors and mammalian scavengers feeding on dying birds. 

No replacement chemical has been registered at this time (2005). 

If toxic perches become available, their use outside of buildings is not recommended 
Chapter 9 Control Techniques 133 

because there is no way of preventing non-target birds from landing on them. Even 

when used inside buildings, careful placement of perches and monitoring must be done 

to ensure non-target birds such as swallows are not exposed to the toxicant. Pick up 

and properly dispose of all dead birds. 

9.2.D.II.F TOXICANTS FOR MAMMALS

Small rodent populations (e.g., voles, 

house and deer mice, Norway rats) 

might erupt in grassy and brushy 

areas or around construction debris 

on airports, attracting raptors and 

creating a hazard to aviation. In 

general, control rodent populations 

by habitat management (mowing, 

sanitation, clean-up of brushy areas 

and piles of debris). However, there 

might be situations where the use of 

a rodenticide is appropriate to reduce 

rodent populations in airside 

vegetation. The control of 

commensal rodents in airport 

terminal buildings and other facilities 

will not be discussed here because 

these jobs are usually handled by 

private pest control operators. 

There are two types of rodenticides 

that might be available for use in airside vegetation, anticoagulants and acute toxicants. 

Anticoagulants, of which there are several types registered, cause the rodent to die from 

internal bleeding. Some anticoagulants require multiple feedings to induce sufficient 

bleeding for death whereas others require only a single feeding. The only acute 

toxicant registered for above-ground treatment of field rodents is zinc phosphide, 

available in pellet and grain-bait formulations and as a concentrate for specialized bait 

formulations. 

Anticoagulant rodenticides in covered bait stations are

being used to control mice and voles in the AOA of this

airport in Mexico. The bait stations are checked

regularly and old, moldy bait is removed and properly

disposed. This airport also uses falconry as part of its

integrated program (photo by R. A, Dolbeer, USDA).

Depending on registration label instructions, rodenticide baits can be broadcast in the 

vegetation or hand-placed in burrows and runways. Anticoagulant baits can also be 

placed in various types of bait containers placed in areas of high rodent activity. Care 

must be taken to minimize non-target bird and mammal exposure with broadcast and 

hand-placed baits. 
134 Control Techniques Chapter 9 

9.2.D.II.G FUMIGANTS FOR MAMMALS

Burrowing rodents on airports, such as woodchucks (ground hogs) and prairie dogs, 

can be killed by fumigation of burrows 

with either gas cartridges or aluminum 

phosphide tablets. Gas cartridges, ignited 

from a burning fuse after placement in the 

burrow, generate carbon monoxide. 

Aluminum phosphide pellets react with 

moisture in the burrow to produce 

phosphine gas. Care must be taken to 

plug all burrow entrances with sod after 

placement of the cartridge or pellets in the 

burrow. Gas cartridges are a general use, 

over-the-counter pesticide. Aluminum 

phosphide pellets can only be applied by 

certified pesticide applicators and might 

not be available in all states. As with all 

pesticides, it is critical to make sure the 

wildlife species you are treating is covered 

under the registration for your state. 

9.2.D.II.H LETHAL TRAPS FOR MAMMALS 

Depending on state and local laws, 

Conibear® (body gripping) traps can be 

used to remove woodchucks, beaver, and 

other medium-sized mammals that create 

problems on airports. Neck snares can 

be used to capture coyotes, beaver, and 

certain other mammals. The use of these 

lethal traps requires a high degree of skill 

and experience to selectively capture the 

target animal. Once set, traps must be 

checked frequently (at least once every 

24 hours and more frequently in hot or 

cold weather) to euthanize any animals that might be captured but not killed. Trappers 

must be knowledgeable in procedures for handling and euthanizing captured mammals. 

Earthworms crawling onto runways after heavy

rains can be a strong attractant to gulls and other

birds. This runway in New Zealand uses slit

drains to block worms from reaching the runway.

Other options include brush-sweeping runway

edges to remove worms and deploying extra

personnel to disperse gulls. As of 2005, there

are no chemicals registered in the USA to control

earthworms (photo by R. A. Dolbeer, USDA). 

9.3 CONCLUSIONS

Habitat modifications to minimize food, cover, and water and physical barriers to 

exclude wildlife are the foundations of wildlife hazard management programs for 

airports. In addition, an integrated array of repellent techniques is necessary to disrupt 

normal behavior and to stress hazardous wildlife that attempt to use the airport. These 

repellent techniques must be used judiciously and backed by real threats to minimize 

habituation. To this end, lethal control of selected individuals of common species is 

sometimes necessary to reinforce repellent actions. Furthermore, the management of a 
Chapter 9 Control Techniques 135 

wildlife hazard situation on an airport 

might require removal of a particular 

animal or group of animals or require 

that a local population of a problem 

species be reduced by lethal means 

until a long-term, nonlethal solution is 

implemented. Finally, the most critical 

factor for the success of a wildlife 

hazard management program is to 

have motivated and trained 

professionals who are knowledgeable 

about the wildlife species attempting to 

use the airport environment and the 

techniques used to manage the 

problems these species create. 

9.4 OTHER SOURCES OF 

INFORMATION

For details on techniques, equipment, 

chemical registrations, species-specific 

management recommendations, and 

sources of supply, the reader is 

referred to— 

Hygnstrom, S. C., R. M. Timm, and G. 

E. Larson, editors. 1994. Prevention 

and control of wildlife damage. 

University of Nebraska Cooperative 

Extension Division, Lincoln, Nebraska. 

(This 2-volume manual is also 

available online at 

ianrwww.unl.edu/wildlife/solutions/handbook/.) 

The management of hazardous wildlife at airports

often generates interest from the public and news

media. Professional biologists and public relations

personnel at airports must be prepared to explain

and defend actions taken to protect the flying public

from wildlife hazards to aviation (photo by R. A.

Dolbeer, USDA). 

In addition, Appendix L provides a list of research publications by the U.S. Department 

of Agriculture, National Wildlife Research Center (NWRC), documenting results of 

evaluations of various wildlife control products and strategies. These evaluations were 

conducted between 1992 and 2004 with support from the FAA under an interagency 

agreement with NWRC. This is not a complete list of all evaluations that have been 

done on all wildlife control methods, but it does provide information on many of the 

control methods discussed in this chapter. 
136 Control Techniques Chapter 9 

Birds and aircraft will always share the skies, and there will always be the risk of collisions. To

minimize that risk, airports must be managed to be as unattractive to birds as possible. Integrating

various control strategies offers the maximum long-term effectiveness and immediate relief from a

hazardous situation and minimizes the need for the use of lethal control methods (photo by B.

Washburn, USDA). 
 137

ACKNOWLEDGEMENTS 

We thank J. L. Seubert (retired), S. E. Wright, and T. W. Seamans of the U.S. 

Department of Agriculture, Wildlife Services (USDA/WS) for assistance in the 

compilation of this manual and for helpful reviews of earlier drafts. E. LeBoeuf 

(presently with the U.S. Air Force BASH team); J. Rapol, Airports, Federal Aviation 

Administration (FAA); and A. Newman, Embry-Riddle Aeronautical University, were 

instrumental in the development of the computerized bird strike database. B. Castelano 

and E. Melisky (Airports, FAA) and B. MacKinnon (Airports Group, Transport Canada) 

also provided helpful comments. Funding for the writing and publishing of this manual 

was provided to USDA/WS through an interagency agreement with the FAA, William J. 

Hughes Technical Center. We thank S. Agrawal, P. Jones, and M. Hoven of the 

Technical Center for their support. 
138 

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 139

SELECTED PUBLICATIONS AND WEB SITES 

In addition to these publications and web sites, a list of wildlife field guides and 

reference books is provided at the end of Chapter 8. Also, a list of publications on 

wildlife control techniques by the U.S. Department of Agriculture, National Wildlife 

Research Center, is provided in Appendix L. 

Belant, J. L., S. K. Ickes, and T. W. Seamans. 1998. Importance of landfills to urbannesting herring and ring-billed gulls. Landscape and Urban Planning 43:11-19. 

Bellrose, F. C. 1980. Ducks, geese, and swans of North America, third edition. 

Stackpole Books, Harrisburg, Pennsylvania. 540 pages. 

Blokpoel, H. 1974. Bird hazards to aircraft. Canadian Wildlife Service. Ministry of 

Supply and Services, Ottawa, Ontario, Canada. 236 pages. 

Blokpoel, H., and, G. D. Tessier. 1984. Overhead wires and monofilament lines 

exclude ring-billed gulls from public places. Wildlife Society Bulletin 12:55-53 

Cleary, E. C., R. A. Dolbeer, and S. E. Wright. 2004. Wildlife strikes to civil aircraft in 

the United States, 1990-2003. U.S. Department of Transportation, Federal 

Aviation Administration, Serial Report No. 10, DOT/FAA/AS/00-6(AAS-310). 

Washington DC USA. 56 pages. (http://wildlife-mitigation.tc.faa.gov/). 

Code of Federal Regulations (CFR): available at 

http://www.gpoaccess.gov/cfr/index.html

CFR Title 40, Part 258, Criteria for Municipal Solid Waste Landfills, section 

258.10, Airport Safety, pages 395-396 (July 2003). 

CFR Title 50, Parts 1-100, Wildlife and Fisheries, 494 pages (October 2003). 

CFR Title 14, Part 139, Certification and Operations: Land Airports Serving 

Certain Air Carriers, section 139.337, Wildlife Hazard Management, 

pages 846-847 (June 2004). 

Dolbeer, R. A., J. L. Belant, and J. L. Sillings. 1993. Shooting gulls reduces strikes with 

aircraft at John F. Kennedy International Airport. Wildlife Society Bulletin 

21:442-450. 

Dolbeer, R. A., S. E. Wright, and E. C. Cleary. 2000. Ranking the hazard level of wildlife 

species to aviation. Wildlife Society Bulletin 28:372-378 (updated in special 

report to Federal Aviation Administration in 2003 that was incorporated into AC 

150/5200-7 [Appendix C]. 

Dolbeer, R. A., and P. Eschenfelder. 2002. Population increases of large birds, 

airworthiness standards, and high-speed flight: a precarious combination. 

Pages 273-281 in Proceedings of the 55th International Air Safety Seminar, 

Dublin, Ireland (Flight Safety Foundation, Alexandria, Virginia). 

Dunning, J. B. Jr., editor. 1993. CRC Handbook of Avian Body Masses. CRC Press. 

Boca Raton, Florida. 371 pages. (Body weights for birds throughout the world) 

Gill, F. B. 1990. Ornithology. W. H. Freeman and Company. New York, New York. 

660 pages. 
140 Selected Publications 

Hygnstrom, S. C., R. M. Timm, and G. E. Larson, editors. 1994. Prevention and control 

of wildlife damage. University of Nebraska Cooperative Extension Division, 

Lincoln, Nebraska. (This 2-volume manual is also available online at: 

ianrwww.unl.edu/wildlife/solutions/handbook/) 

Knittle, C. E., and R. D. Porter, 1993. Waterfowl damage and control methods in 

ripening grain: an overview, US Fish and Wildlife Service, Fish and Wildlife 

Technical Report 14, Washington, DC. 17 pages. 

Linnell, M. A., M. R. Conover, and T. J. Ohashi. 1999. Biases in bird strike statistics 

based on pilot reports. Journal of Wildlife Management 63:997-1003. 

MacKinnon, B., R. Sowden, and S. Dudley (Editors). 2001. Sharing the skies: an 

aviation guide to the management of wildlife hazards. Transport Canada, 

Aviation Publishing Division, Tower C, 330 Sparks Street, Ottawa, Ontario, K1A 

0N8 Canada. 316 pages. 

Seubert, J. L. 1994. Assessing the implementation of wildlife hazard management 

programs at civil airports. Proceedings Bird Strike Committee Europe 22:275-

284. 

Smith, A. E., S. R. Craven, and P. D. Curtis. 1999. Managing Canada geese in urban 

environments. Jack Berryman Institute Publication 16, and Cornell Cooperative 

Extension, Ithaca, New York. 

Transport Canada. 2002. Wildlife Control Procedures Manual. Safety and Security, 

Aerodrome Safety Branch. TP11500E. Ottawa, Ontario. 

(www.tc.gc.ca/civilaviation/aerodrome/wildlifecontrol/) 

Web Sites: 

Bird Strike Committee Canada. www.birdstrikecanada.com/ 

Bird Strike Committee USA. www.birdstrike.org/ 

Prevention and control of wildlife damage (2-volume manual). University of 

Nebraska Cooperative Extension Division, Lincoln, Nebraska. 

ianrwww.unl.edu/wildlife/solutions/handbook/ 

Transport Canada. www.tc.gc.ca/civilaviation/aerodrome/wildlifecontrol/ 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 

Wildlife Services. www.aphis.gov.usda.gov/ws 

U.S. Department of Defense, U.S. Air Force Bird Aircraft Strike Hazard (BASH) 

Team. http://afsafety.af.mil/afsc/bash/home.html. 

U.S. Department of Interior, Fish and Wildlife Service. www.fws.gov/ 

U.S. Department of Transportation, Federal Aviation Administration, Airports 

Division. www.faa.gov/arp/. 

U.S. Department of Transportation, Federal Aviation Administration, Wildlife 

Mitigation and Wildlife Strike Database. http://wildlife-mitigation.tc.faa.gov/. 
Selected Publications 141

Wright, S. E., R. A. Dolbeer, and A. J. Montoney. 1998. Deer on airports: an accident 

waiting to happen. Vertebrate Pest Conference 18:90-95. 
142 Selected Publications 

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GLOSSARY 

Air carrier. A person who holds or who is required to hold an air carrier operating 

certificate issued under this chapter [Title 14 Code of Federal Regulations, Part 

139, Certification and Operation: Land Airports Serving Certain Air Carriers] while 

operating aircraft having a seating capacity of more than 10 passengers (14 CFR 

139.5). 

Air carrier aircraft. An aircraft that is being operated by an air carrier and is 

categorized as either a large air carrier aircraft if designed for at least 31 

passenger seats or a small air carrier aircraft if designed for more than 9 

passenger seats but less than 31 passenger seats, as determined by the aircraft 

type certificate issued by a competent civil aviation authority (14 CFR 139.5). 

Air carrier operation. The takeoff or landing of an air carrier aircraft and includes the 

period of time from 15 minutes before until 15 minutes after the takeoff or landing 

(14 CFR 139.5). 

Air operations area (AOA). Any area of an airport used or intended to be used for 

landing, takeoff, or surface maneuvering of aircraft. An air operations area 

included such paved areas or unpaved areas that are used or intended to be 

used for the unobstructed movement of aircraft in addition to its associated 

runway, taxiways, or apron. 

Airport. An area of land or other hard surface, excluding water, that is used or intended 

to be used for the landing and takeoff of aircraft, including any buildings and 

facilities (14 CFR 139.5). 

Airport operator. The operator (private or public) or sponsor of a public use airport. 

Airport Operating Certificate. A certificate, issued under this part [Title 14 Code of 

Federal Regulations, Part 139, Certification and Operation: Land Airports Serving 

Certain Air Carriers], for operation of a Class I, II, III, or IV airport. 

Approach or departure airspace. The airspace, within 5 statute miles of an airport, 

through which aircraft move during landing or takeoff. 

Bird balls. High-density plastic floating balls that can be used to cover ponds and 

prevent birds from using the sites. 

Bird hazard. See Wildlife hazard. 

Bird strike. See Wildlife strike 

Carrying capacity. The maximum number of animals of a given species, which a 

habitat is capable of supporting on a sustained basis. The goal of wildlife 

management programs on airports is to eliminate or minimize the carrying 

capacity of habitat for species hazardous to aviation. 

Categorical exclusion (NEPA): A category of actions that do not individually or 

cumulatively have a significant effect on the human environment (40 CFR, 

1508.4). 
144 Glossary

Certificate holder. The holder of an Airport Operating Certificate issued under this part. 

[Title 14 Code of Federal Regulations, Part 139, Certification and Operation: 

Land Airports Serving Certain Air Carriers] (14 CFR 139.5). 

 Class I airport. An airport certificated to serve scheduled operations of large air carrier 

aircraft that can also serve unscheduled passenger operations of large air carrier 

aircraft and/or scheduled operations of small air carrier aircraft.

Class II airport. An airport certificated to serve scheduled operations of small air carrier 

aircraft and the unscheduled passenger operations of large air carrier aircraft. A 

Class II airport cannot serve scheduled large air carrier aircraft. 

Class III airport. An airport certificated to serve scheduled operations of small air carrier 

aircraft. A Class III airport cannot serve scheduled or unscheduled large air 

carrier aircraft. 

Class IV airport. An airport certificated to serve unscheduled passenger operations of 

large air carrier aircraft. A Class IV airport cannot serve scheduled large or small 

air carrier aircraft. 

Concurrent use. Aeronautical property used for compatible non-aviation purposes 

while at the same time serving the primary purpose for which it was acquired; 

and the use is clearly beneficial to the airport. The concurrent use should 

generate revenue to be used for airport purposes (see Order 5190.6A, Airport 

Compliance Requirements, sect. 5h). 

Construct a new MSWLF. To begin to excavate, grade land, or raise structures to 

prepare a municipal solid waste landfill as permitted by the appropriate regulatory 

or permitting agency. 

Cover. Vegetation covering a ground surface and serving as shelter for wildlife that are 

roosting, resting, nesting, or feeding. 

Cover types. A descriptive term characterizing vegetative composition and physical 

characteristics of a plant community. 

Detention ponds. Storm water management ponds that hold storm water for short 

periods of time, generally less than then 48 hours (compare with retentions 

ponds). 

Dump. The actively used and unvegetated part of an area where refuse (garbage) is 

placed and allowed to accumulate on the ground surface without periodic 

covering or compacting. This includes both authorized and unauthorized areas. 

Establish a new Municipal Solid Waste Landfill. When the first load of putrescible 

waste is received on-site for placement in a prepared municipal solid waste 

landfill. 

Extraordinary circumstances: Environmental conditions associated with an action that 

is normally categorically excluded and that: (1) involves one or more of the 

circumstances listed in FAA Order 1050.1E, paragraph 304a through 304k; and 

may cause a significant environmental effect. 

Fly ash. The fine, sand-like residue resulting from the complete incineration of an 
Glossary 145

organic fuel source. Fly ash typically results from the combustion of coal or 

organic waste used to operate a power generating plant. 

Hazardous wildlife. Species of wildlife (birds, mammals, reptiles, insects, earth worms), 

including feral animals and domesticated animals not under control, that are 

associated with aircraft strike problems, are capable of causing structural 

damage to airport facilities, or act as attractants to other wildlife that pose a strike 

hazard (Advisory Circular 150/5200-33A – Hazardous Wildlife Attractants on or 

Near Airports; 14 CFR 139.3) 

Heliport. An airport or an area of an airport used or intended to be used for the landing 

and takeoff of helicopters (14 CFR 139.3). 

Mammal strike. See Wildlife strike. 

Migratory Bird. “[A] migratory bird [is] ... any bird whatever its origin and whether or 

not raised in captivity, which belongs to a species listed in Section 10.13 [of 50 

CFR] or which is a mutation or a hybrid of any such species, including any part, 

nest, or egg of any such bird, or any product, whether or not manufactured, 

which consist, or is composed in whole or part, of any such bird, or any part, 

nest, or egg thereof." (50 CFR 10.12). This list includes almost all native bird 

species in the United States, with the exception of nonmigratory game birds such 

as pheasants, turkeys and grouse. Exotic and feral species such as graylag 

geese, muscovy ducks, European starlings, house (English) sparrows, and rock 

doves (pigeons) also are not listed in 50 CFR 10.13 and are therefore not 

protected by federal law. 

Migration. The periodic movement of a wildlife species from one geographic area to 

another, usually in correlation with seasonal changes in weather. 

Municipal Solid Waste Landfill (MSWLF). A publicly or privately owned discrete area 

of land or an excavation that receives household waste and that is not a land 

application unit, surface impoundment, injection well, or waste pile, as those 

terms are defined under 40 CFR § 257.2. An MSWLF may receive other types 

wastes, such as commercial solid waste, non-hazardous sludge, small-quantity 

generator waste, and industrial solid waste, as defined under 40 CFR § 258.2. 

An MSWLF can consist of either a stand alone unit or several cells that receive 

household waste. 

Movement area. The runways, taxiways, and other areas of an airport which are used 

for taxiing or hover taxiing, air taxiing, takeoff, and landing of aircraft, exclusive of 

loading ramps and aircraft parking areas (14 CFR 139.3). 

New MSWLF. A municipal solid waste landfill that was established or constructed after 

April 5, 2001 (AC 150/5200-34). 

Pesticide. (1) Any substance or mixture of substances intended for preventing, 

destroying, repelling, or mitigating any pest, (2) any substance or mixture of 

substances intended for use as a plant regulator, defoliant, or desiccant, and (3) 

any nitrogen stabilizer (7 U.S.C.A. 136[u]). 
146 Glossary

Piston-powered aircraft. Fixed-wing aircraft powered by piston engines. Such aircraft 

normally use LL-100 fuel. 

Piston-use airport. Any airport that does not sell Jet-A fuel for fixed-wing turbinepowered aircraft, and primarily serves fixed-wing, piston-powered aircraft. 

Incidental use of the airport by turbine-powered, fixed-wing aircraft would not 

affect this designation. However, such aircraft should not be based at the airport 

(AC 150/5200-33A). 

Public airport. An airport used or intended to be used for public purposes that is under 

the control of a public agency; and of which the area used or intended to be used 

for landing, taking off, or surface maneuvering of aircraft is publicly owned (49 

U.S.C. § 47102(16)). 

Putrescible waste. Solid waste that contains organic matter capable of being 

decomposed by micro-organisms and of such a character and proportion as to 

be capable of attracting or providing food for birds (40 CFR §257.3-8). 

Putrescible-waste disposal operation. Landfills, garbage dumps, underwater waste 

discharges, or similar facilities where activities include processing, burying, 

storing, or otherwise disposing of putrescible material, trash, and refuse. 

Propane cannon/exploder. A hollow cylinder that produces a loud explosion to frighten 

wildlife by the ignition of a metered amount of propane at timed or random 

intervals or by remote control. 

Pyrotechnics. Various combustible projectiles launched from a shotgun, pistol or other 

device that produce noise, light and smoke to frighten wildlife. 

Retention ponds. Storm water management ponds that hold water for long periods of 

time, generally more then 48 hours (compare with detentions ponds). 

Runway protection zone (RPZ). An area off the runway end to enhance the protection 

of people and property on the ground (see AC 150/5300-13). The dimensions of 

this zone vary with the airport design, aircraft, type of operation, and visibility 

minimum. 

Scheduled operation. Any common carriage passenger-carrying operation for 

compensation or hire conducted by an air carrier for which the air carrier or its 

representatives offers in advance the departure location, departure time, and 

arrival location. It does not include any operation that is conducted as a 

supplemental operation under 14 CFR part 121 or public charter operations 

under 14 CFR part 380. 

Sewage sludge. Any solid, semi-solid, or liquid residue generated during the treatment 

of domestic sewage in a treatment works. Sewage sludge includes, but is not 

limited to, domestic septage; scum or solids removed in primary, secondary, or 

advanced wastewater treatment process; and a material derived from sewage 

sludge. Sewage does not include ash generated during the firing of sewage 

sludge in a sewage sludge incinerator or grit and screenings generated during 

preliminary treatment of domestic sewage in a treatment works (40 CFR 257.2). 

Also, the de-watered effluent resulting from secondary or tertiary treatment of 
Glossary 147

municipal sewage and/or industrial wastes, including sewage sludge as 

referenced in USEPA’s Effluent Guidelines and Standards, 40 CFR Part 401. 

Sludge. Any solid, semi-solid, or liquid waste generated form a municipal, commercial 

or industrial wastewater treatment plant, water supply treatment plant, or air 

pollution control facility or any other such waste having similar characteristics and 

effect (40 CFR 257.2). 

Solid waste. Any garbage, refuse, sludge, from a waste treatment plant, water supply 

treatment plant or air pollution control facility and other discarded material, 

including, solid liquid, semisolid, or contained gaseous material resulting from 

industrial, commercial, mining, and agricultural operations, and from community 

activities, but does not include solid or dissolved materials in domestic sewage, 

or solid or dissolved material in irrigation return flows or industrial discharges 

which are point sources subject to permits under section 402 of the Federal 

Water Pollution Control Act, as amended (86 Stat. 880), or source, special 

nuclear, or by product material as defined by the Atomic Energy Act of 1954, as 

amended (68 Statute 923), (40 CFR 257.2). 

Take (of wildlife). To pursue, hunt, shoot, wound, kill, trap, capture, or collect or to 

attempt to pursue, hunt, shoot, wound, kill, trap, capture, or collect any wild 

animal (50 CFR 10.12). 

Turbine-powered aircraft. Aircraft powered by turbine engines including turbojets and 

turboprops but excluding turbo-shaft, rotary-wing aircraft. Such aircraft normally 

use Jet-A fuel (AC 150/5200-33A). 

Turbine-use airport. Any airport that sells Jet-A fuel for fixed-wing turbine-powered 

aircraft. 

Wastewater treatment facility. Any devices or systems used to store, treat, recycle, or 

reclaim municipal sewage or liquid industrial wastes, including Publicly Owned 

Treatment Works (POTW), as defined by Section 212 of the Federal Water 

Pollution Control Act (P.L. 92-500) as amended by the Clean Water Act of 1977 

(P.L. 95-576) and the Water Quality Act of 1937 (P.L. 100-4). This definition 

includes any pretreatment involving the reduction of the amount of pollutants, the 

elimination of pollutants, or the alteration of the nature of pollutant properties in 

wastewater prior to or in lieu of discharging or otherwise introducing such 

pollutants into a POTW (40 CFR 403.3 [o], [p], [q]). 

Wildlife. Any wild animal, including without limitation any wild mammal, bird, reptile, 

fish, amphibian, mollusk, crustacean, arthropod, coelenterate, or other 

invertebrate, including any part, product, egg, or offspring thereof (50 CFR 10.12, 

Taking, Possession, Transportation, Sale, Purchase, Barter, Exportation, and 

Importation of Wildlife and Plants). As used in this manual wildlife includes feral 

animals and domestic animals out of the control of their owners (14 CFR Part 

139, Certification of Airports). 

Wildlife attractants. Any human-made structure, land-use practice, or human-made or 

natural geographic feature, that can attract or sustain hazardous wildlife within 

the landing or departure airspace, AOA, loading ramps, or aircraft parking areas 
148 Glossary

of an airport. These attractants can include but are not limited to architectural 

features, landscaping, waste disposal sites, wastewater treatment facilities, 

agricultural or aquaculture activities, surface mining, or wetlands (AC 150/5200-

33). 

Wildlife hazard. A potential for a damaging aircraft collision with wildlife on or near an 

airport (14 CFR 139.3). 

Wildlife strike. A wildlife strike has occurred when: 

1. A pilot reports striking 1 or more birds or other wildlife; 

2. Aircraft maintenance personnel identify aircraft damage as having been 

caused by a wildlife strike; 

3. Personnel on the ground report seeing an aircraft strike 1 or more birds or 

other wildlife; 

4. Bird or other wildlife remains, whether in whole or in part are found within 

200 feet of a runway centerline, unless another reason for the animal's death is 

identified; 

5. The animal's presence on the airport had a significant negative effect on a 

flight (i.e., aborted takeoff, aborted landing, high-speed emergency stop, aircraft 

left pavement area to avoid collision with animal) (criteria 1-4 adopted from 

Transport Canada (MacKinnon et al. 2001). 
 149

ACRONYMS 

AAWV American Association of Wildlife Veterinarians 

AC Advisory Circular 

A-C Alpha-Chloralose 

ADC Animal Damage Control (former name of USDA/WS) 

AGL Above Ground Level 

AOA Air Operations Area 

APHIS Animal and Plant Health Inspection Service 

ATC Air Traffic Control 

BASH Bird Aircraft Strike Hazard (USAF) 

BSCC Bird Strike Committee Canada 

BSC-USA Bird Strike Committee USA 

C&D Landfills Construction and Demolition Landfills 

CFR Code of Federal Regulations 

EA Environmental Assessment 

EIS Environmental Impact Statement 

FAA Federal Aviation Administration 

FDA Food and Drug Administration 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FOD Foreign Object Debris, Foreign Object Damage 

MBTA Migratory Bird Treaty Act 

MOA Memorandum of Agreement 

MOU Memorandum of Understanding 
150 Acronyms 

MSWLF Municipal Solid Waste Landfill 

NEPA National Environmental Policy Act 

NIPAS National Integrated Plan of Airport System 

NWRC National Wildlife Research Center (USDA) 

OFA Object Free Area 

OFZ Obstacle Free Zone 

RPZ Runway Protection Zone 

TSS Threshold Siting Service 

USAF United States Air Force 

USCOE United States Army Corps of Engineers 

USDOD United States Department of Defense 

USDA/WS United States Department of Agriculture, Wildlife Services 

USDOT United States Department of Transportation 

USEPA United States Environmental Protection Agency 

USFWS United States Fish and Wildlife Service 

WCP Wildlife Control Personnel 

WHA Wildlife Hazard Assessment 

WHMP Wildlife Hazard Management Plan 

WHWG Wildlife Hazard Working Group 

WS Wildlife Services (USDA) 
 151

APPENDICES 
152 

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 153

APPENDIX A: 

Names, Addresses, and Phone Numbers: 

(Correct as of 11 July 2004.) 
154 Appendix A 

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Appendix A Points of Contact 

 

155

Federal Aviation Administration 

FAA National Headquarters 

Airports Division 

800 Independence Avenue, SW 

Washington, DC 20591 

Name Mail Stop Phone Number 

Ben Castellano, Div. Mgr. AAS-300 202-267-8728 

Bruce Landry, ANE, ASW AAS-300 202-267-8729 

Ed Cleary, Wildlife Hazard Management AAS-300 202-267-3389 

Ed Dorsett, AEA, ASO AAS-300 202-267-8792 

Ken Gilliam, Fire Safety Specialist AAS-300 @ 

ORL/ADO 

407-812-6331 

ext. 134 

Fax: 407-812-6978 

Elizabeth Matarese, AAL, AWP AAS-300 202-267-8723 

Darryel Adams, ACE, AGL, ANM AAS-300 202-267-8816 

Fax: 202-267-5383

FAA Alaska Region Headquarters 

Airports Division 

222 West 7th Avenue, #14 

Anchorage, AK 99513 

Name Mail Stop Phone Number 

Byron K. Huffman, Div. Mgr. AAL-600 907-271-5438 

Debbie Roth, Dep. Div. Mgr. AAL-601 907-271-5438 

Dave Wahto AAL-605 907-271-3815 

Maverick Douglas, Lead Inspector AAL-604 907-271-5444 

Stephen Powell AAL-624 907-271-5448 

Fax: 907-271-2851
156 Points of Contact Appendix A 

FAA Central Region Headquarters 

Airports Division 

601 East 12th Street 

Federal Building 

Kansas City, MO 64106 

Serving: KS, IA, MO, NE 

Name Mail Stop Phone Number 

George Hendon, Div. Mgr. ACE-600 816-329-2601 

Jim Johnson, Br. Mgr. ACE-620 816-329-2624 

Glenn Helm ACE-620B 816-329-2617 

Mike Mullen, Lead Inspector ACE-620C 816-329-2618 

Pat Haynes ACE-620D 816-329-2621 

Fax: 816-329-2610 

FAA Eastern Region Headquarters 

Airports Division 

One Aviation Plaza 

159-30 Rockaway Blvd 

Springfield Gardens, NY 11434 

Serving: DE, MD, NJ, NY, PA, VA, WV 

Name Mail Stop Phone Number 

Bill Flanagan, Div. Mgr. AEA-600 718-553-3330 

Harvey DeGraw, Br. Mgr. AEA-620 718-553-3350 

Vincent Cimino, Lead Inspector AEA-620 718-553-3348 

Dennis O'Donnell AEA-620 718-553-3343 

John Green AEA-620 718-553-3342 

Guillermo Felix AEA-620 718-553-3345 

Evelyn Martinez AEA-620 718-553-3347 
Appendix A Points of Contact 

 

157

Fax: 718-995-5615 

FAA Great Lakes Region Headquarters 

Airports Division 

O'Hare Lake Office Center 

2300 East Devon Avenue 

Des Plaines, IL 60018 

Serving: IL, IN, MI, MN, OH, ND, SD, WI 

Name Mail Stop Phone Number 

Jeri Alles, Div. Mgr. AGL-600 847-294-7272 

Christina Drouet, Br. Mgr. AGL-620 847-294-7387 

John Lott, Lead Inspector AGL-621.1 847-294-7533 

Tricia Halpin AGL-621.4 847-294-7160 

Jesse Carriger AGL-621.7 847-294-7626 

Ignacio Flores AGL-621.5 847-294-7531 

Birkely Rhodes, AGL-621.3 847-294-7509 

Kenneth Taira AGL-621.2 847-294-7519 

Fax: 847-294-8088 

FAA New England Regional Headquarters 

Airports Division 

12 New England Executive Park 

Burlington, MA 01803 

Serving: CT, MA, ME, NH, RI, VT 

Name Mail Stop Phone Number 

LaVerne Reid, Div. Mgr. ANE-600 781-238-7600 

Vacant, Br. Mgr. ANE-620 781-238-7620 

Laurie Suttmeier, Lead Inspector ANE-620 781-238-7630 

Laurie Hyman ANE-620 781-238-7632 

Fax: 781-238-7608 
158 Points of Contact Appendix A 

FAA Northwest Mountain Region Headquarters 

Airports Division 

1601 Lind Avenue, SW 

Renton, WA 98055 

Serving: CO, ID, MT, OR, UT, WA, WY 

Name Mail Stop Phone Number 

Lowell Johnson, Div. Mgr. ANM-600 425-227-2600 

Matt Cavanaugh, Br. Mgr. ANM-620 425-227-2606 

Mark Taylor, Lead Inspector ANM-625 425-227-2625 

Don Larson SEA-641 425-227-2652 

Lynn Deardorff ANM-621 425-227-1621 

Rich Van Allman ANM-627 425-227-2607 

Fax: 425-227-1600 

FAA Southern Region Headquarters 

Airports Division 

1701 Columbus Avenue 

College Park, GA 30337 

(Mail Address: P. O. Box 20636, Atlanta, GA 30320) 

Serving: AL, FL, GA, KY, MS, NC, PR, SC, TN, VI 

Name Mail Stop Phone Number 

Rusty Chapman, Div. Mgr. ASO-600 404-305-6700 

Linda Berkowitz, Lead Inspector ASO-620 404-305-6715 

Patrick Rogers ASO-620.K 404-305-6716 

Randy Moseng ASO-620.R 404-305-6714 

Jack McSwain AS0-620.J 404-305-6718 

Jim Price ASO-620.P 404-305-6721 

Fax: 404-305-6730 
Appendix A Points of Contact 

 

159

FAA Southwest Region Headquarters 

Airports Division 

2601 Meacham Blvd. 

Fort Worth, TX 76137-4298 

Serving: AR, LA, NM, OK, TX 

Name Mail Stop Phone Number 

Kelvin Solco, Div. Mgr. ASW-600 817-222-5600 

Joe Washington, Br. Mgr. ASW-620 817-222-5620 

Bruce Kirkendoll, Lead Inspector ASW-621 817-222-5621 

Bill Mitchell ASW-621B 817-222-5625 

Julie Netherton ASW-621A 817-222-5624 

Ron Hess ASW-622 817-222-5622 

John Dougherty ASW-623 817-222-5623 

Fax: 817-222-5984 

FAA Western Pacific Region Headquarters 

Airports Division 

15000 Aviation Boulevard 

Hawthorne, CA 90261 

Courier address: use above address 

Mail address: 

P. O. Box 92007, World Postal Center, Los Angeles, CA 90009 

Serving: AZ, CA, HI, NV 

Name Mail Stop Phone Number 

Mark McClardy, Div. Mgr. AWP-600 310-725-3600 

George Aikens, Br. Mgr. AWP-620 310-725-3620 

Bill Critchfield, Lead Inspector AWP-622 310-725-3622 

Elizabeth Louie AWP-622.1 310-725-3636 

William Long AWP-622.2 310-725-3635 
160 Points of Contact Appendix A 

Fax: 310-725-6849. 

San Francisco, CA Office 

Gretchen Catron, SFO-676 650-876-2778 ext 676 

Ray Cavole SFO-677 650-876-2778 ext 677 

Fax: 650-876-2733 

Honolulu, HI Office 

Ron Simpson HNL-600 808-541-1232 

Mack Humphery HNL-621A 808-541-1243 

Fax: 808-541-3462 
Appendix A Points of Contact 

 

161

USDA APHIS Wildlife Services 

Headquarters 

U.S. Department of Agriculture 

Animal and Plant Health Inspection Service 

Wildlife Services 

Room 1624 South Agriculture Building 

Washington, DC 20250-3402 

(mail address: USDA/APHIS/WS 

STOP 3402 

Washington, DC 20250-3402) 

William H. Clay, Deputy Administrator (202) 720-2054 

FAX:(202) 690-0053 

Operational Support Staff 

USDA/APHIS/WS 

Operational Support Staff 

4700 River Road, Unit 87, Room 2D26 

Riverdale, MD 20737-1234 

Joanne Garrett, Director (301) 734-7921 

FAX: (301) 734-5157 

Eastern Region 

USDA/APHIS/WS 

Eastern Regional Office 

920 Main Campus Drive, Suite 200 

Raleigh, NC 27606 

Charles S. Brown, Regional Director (919) 855-7200 

FAX: (919) 855-7215 

Alabama Frank Boyd 

State Director 

Room 118, Ext. Hall 

Auburn Univ. AL 36849 

(334) 844-5670 

FAX: (334) 844-5321 

Arkansas Thurman W. Booth 

State Director 

600 W. Capitol Ave. 

Room 55, 

Little Rock, AR 72201 

(501) 324-5382 

FAX: (501) 324-7135 

Connecticut See Massachusetts

Delaware See Maryland

District of 

Columbia See Maryland 

Florida Bernice Constantin 

State Director 

2820 E. University Ave. 

Gainesville, FL 32641 

(352) 377-5556 

FAX: (352)377-5559 
162 Points of Contact Appendix A 

Georgia Douglas Hall 

State Director 

School of Forest Res. 

Univ. of Georgia 

Athens, GA 30602 

(706) 546-5637 

FAX: (706) 316-9248 

Illinois Kirk Gustad 

State Director 

2869 Via Verde Dr. 

Springfield, IL 62703 

(217) 241-6700 

FAX: (217) 241-6702 

Indiana Judy Loven 

State Director 

Purdue University 

Smith Hall 

901 W. State Street 

W. Lafayette, IN 47907 

(765) 494-6229 

FAX: (765) 494-9475 

Iowa See Missouri 

Kentucky See Tennessee 

Louisiana Dwight LeBlanc 

State Director 

P.O. Box 589 

Port Allen, LA 70767 

(225) 389-0229 

FAX: (225) 389-0228 

Maine Edwin Butler 

State Director 

81 Leighton Rd, Suite 

12 Augusta, ME 04330 

(207) 622-8263 

FAX: (207) 622-5760 

Maryland Kevin Sullivan 

State Director 

1568 Whitehall Road 

Annapolis, MD 21401 

(410) 349-8055 

FAX: (410) 349-8258 

Massachusetts Monte Chandler 

State Director 

463 West Street 

Amherst, MA 01002 

(413) 253-2403 

FAX: (413) 253-7577 

Michigan Peter Butchko 

State Director 

2803 Jolly Rd, Ste.160 

Okemos, MI 48864 

(517) 336-1928 

FAX: (517) 336-1934 

Minnesota See Wisconsin 

Mississippi Kris C. Godwin 

State Director 

P.O. Drawer FW 

MS State, MS 39762 

(662) 325-3014 

FAX: (662) 325-3690 

Missouri Ed Hartin 

State Director 

1714 Commerce Court, 

Suite C 

Columbia, MO 65202 

(573) 449-3033 

FAX: (573) 449-4382 

New Hampshire John E. McConnell 

State Director 

59 Chenell Dr., Suite 7 

Concord, NH 03301 

(603) 223-6832 

FAX (603) 229-1951 

New Jersey Janet Bucknall 

State Director 

140-C Locust Grove 

Rd. 

Pittstown, NJ 08867 

(908) 735-5654 

(908) 735-4513 

FAX: (908) 735-0821 

New York Richard Chipman 

State Director 

1930 Route 9 

Castleton, NY 12033 

(518) 477-4837 

FAX: (518) 477-4899 

North Carolina Jon Heisterberg 

State Director 

6213-E. Angus Dr. 

Raleigh, NC 27617 

(919) 786-4480 

ext. 228 

FAX: (919) 782-4159 

Ohio Andy Montoney 

State Director 

6929 Americana Pkwy. 

Reynoldsburg, OH 

43068 

(614) 892-2514 

FAX: (614) 892-2519 
Appendix A Points of Contact 

 

163

Pennsylvania Jason Suckow 

State Director 

P.O. Box 60827 

Summerdale, PA 

 17106 

(717) 236-9451 

FAX: (717) 236-9454 

Rhode Island See Massachusetts

South Carolina Noel Myers 

State Director 

400 Northeast Dr. 

Suite L 

Columbia, SC 29203 

(803) 786-9455 

FAX: (803) 786-9472 

Tennessee Brett Dunlap 

State Director 

537 Myatt Dr. 

Madison, TN 37115 

(615) 736-5506 

FAX: (615) 736-2768 

Vermont See 

New Hampshire 

Virgin Islands See Alabama 

Virginia Martin Lowney 

State Director 

P.O. Box 130 

21425 Hull Street Rd. 

Moseley, VA 23120 

(804) 739-7739 

FAX: (804) 739-7738 

West Virginia William Bonwell 

State Director 

730 Yokum Street 

Elkins, WV 26241 

(304) 636-1785 

FAX: (304) 636-5397 

Wisconsin Vacant 750 Windsor Street 

Sun Prairie, WI 53590 

(608) 837-2727 

FAX: (608) 837-6754 

Western Region 

USDA/APHIS/WS 

Western Regional Office 

2150 Center Avenue, Bldg. B, Mail Stop 3W9 

Fort Collins, CO 80526-8117 

Jeff Green, (Acting) Regional Director (970) 494-7443 

FAX: (970) 494-7455 

Arizona David Bergman 

State Director 

8836 North 23rd Ave. 

Suite B-2 

Phoenix, AZ 85021 

(602) 870-2081 

FAX: (602) 870-2951 

Alaska See Washington

California Craig Coolahan 

State Director 

3419-A Arden Way 

Sacramento, CA 95825 

(916) 979-2675 

FAX: (916) 979-2680 

Colorado Michael Yeary 

State Director 

12345 W. Alameda 

Pkwy. Suite 

204Lakewood, CO 

80228 

(303) 236-5810 

FAX: (303) 236-5821 

Hawaii 

Pacific Islands 

Mike Pitzler 

State Director 

3375 Koapaka Street 

Suite H-420 

Honolulu, HI 96819 

(808) 861-8576 

FAX: (808) 861-8570 

Idaho Mark Collinge 

State Director 

9134 W. Blackeagle Dr. 

Boise, ID 83709 

(208) 378-5077 

FAX: (208) 378-5349 

Kansas See Nebraska
164 Points of Contact Appendix A 

Montana Larry Handegard 

State Director 

P.O. Box 1938 

Billings, MT 59103 

(406) 657-6464 

FAX: (406) 657-6110 

Nebraska John Hobbs 

State Director 

5940 S. 58th St. 

P.O. Box 81866 

Lincoln, NE 68501 

(402) 434-2340 

FAX: (402) 434-2330 

Nevada Mark Jensen 

State Director 

4600 Kietzke Lane 

Bldg. O, Suite 260 

Reno, NV 89502 

(775) 784-5081 

FAX: (775) 784-5874 

New Mexico Alex Lara 

State Director 

8441 Washington NE 

Albuquerque, NM 

87113 

(505) 346-2640 

FAX: (505) 346-2627 

North Dakota Phil Mastrangelo 

State Director 

2110 Miriam Circle 

Suite A 

Bismarck, ND 58501 

(701) 250-4405 

FAX: (701) 250-4408 

Oklahoma John Steuber 

State Director 

2800 N. Lincoln Blvd. 

Oklahoma City, OK 

73105 

(405) 521-4039 

(405) 521-4040 

FAX: (405) 525-5951 

Oregon David Williams 

State Director 

6135 NE. 80th, Suite A8 

Portland, OR 97218 

(503) 326-2346 

FAX: (503) 326-2367 

South Dakota See North Dakota 

Texas Gary L. Nunley 

State Director 

P.O. Box 100410 

San Antonio, TX 78201 

(210) 472-5451 

FAX: (210) 472-5446 

Utah Mike Bodenchuck 

State Director 

P.O. Box 26976 

Salt Lake City, UT 

84126 

(801) 975-3315 

FAX: (801) 975-3320 

Washington Roger Woodruff 

State Director 

720 O'Leary Street NW 

Olympia, WA 98502 

(360) 753-9884 

FAX: (360) 753-9466 

Wyoming R.F. Krischke 

State Director 

P.O. Box 59 

Casper, WY 82602 

(307) 261-5336 

FAX: (307) 261-5996 
Appendix A Points of Contact 

 

165

National Wildlife Research Center 

USDA/APHIS/WS/NWRC 

4101 LaPorte Avenue 

Fort Collins, CO 80521-2154 

Richard Bruggers, Director (970) 266-6036 

FAX (970) 266-6040 

NWRC Field Stations 

Hawaii Will Pitt 

Project Leader 

USDA/NWRC 

P.O. Box 10880 

Hilo, HI 96721 

(808) 961-4482 

FAX (808) 961-4776 

Utah John Shivik 

Project Leader 

USDA/NWRC 

Room 163, BNR Bldg. 

Utah State University 

Logan, UT 84322 

(435) 797-2505 

FAX (435) 797-0288 

Washington Vacant

USDA/NWRC 

9730-B Lathrop 

Industrial Drive SW 

Olympia, WA 98512 

(360) 956-3793 

FAX (360) 956-3925 

Florida Michael Avery 

Project Leader 

USDA/NWRC 

2820 E. Univ. Ave. 

Gainesville, FL 32641 

(352) 375-2229 

FAX (325) 375-5559 

Mississippi Scott Barras 

Project Leader 

USDA/NWRC 

P.O. Drawer 6099 

MS State, MS 39762 

(662) 325-8215 

FAX (662) 325-8704 

North Dakota George Linz 

Project Leader 

USDA/NWRC 

211 Miriam Circle, B 

Bismarck, ND 58501 

(701) 250-4469 

FAX (701) 250-4408 

Ohio Bob Beason 

Project Leader 

USDA/NWRC 

6100 Columbus Ave. 

Sandusky, OH 44870 

(419) 625-0242 

FAX (419) 625-8465 

Pennsylvania Vacant

USDA/NWRC 

c/o Monell Chemical 

Senses Center 

3500 Market St. 

Phil., PA 19104 

(215) 898-5753 

FAX (215) 898-2084 
166 Points of Contact Appendix A 

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 167

APPENDIX B: 

Animal Damage Control Act, 

2 March 1931, as amended 
168 Appendix B 

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Appendix B 169

ANIMAL DAMAGE CONTROL ACT 

7 U.S.C. §§ 426-426c, 2 March 1931, as amended 1937 and 1991. 

Overview. This Act gives the Secretary of Agriculture broad authority to investigate and 

control certain predatory or wild animals and nuisance mammal and bird species. 

Animal Damage Control. The Secretary is authorized to conduct investigations, 

experiments, and tests to determine the best methods of eradication, suppression, or 

bringing under control mountain lions, wolves, coyotes, bobcats, prairie dogs, gophers, 

ground squirrels, jack rabbits, brown tree snakes, and other animals injurious to 

agriculture, horticulture, forestry, animal husbandry, wild game animals, fur-bearing 

animals and birds. Another purpose of these investigations is to protect stock and other 

domestic animals through the suppression of rabies and tularemia in predatory or other 

wild animals. The Secretary is also directed to conduct campaigns for the destruction or 

control of these animals. In carrying out the Act, the Secretary may cooperate with 

states, individuals, agencies and organizations. § 426. 

The Secretary is also authorized, except for urban rodent control, to control nuisance 

mammals and birds and those mammal and bird species that are reservoirs for zoonotic 

diseases. Agreements may be entered into with states, local jurisdictions, individuals, 

and organizations for this purpose. § 426c. 

Brown Tree Snakes. Section 1013 of Public Law 102-237, which amended the Act in 

1991, also requires the Secretary to initiate a program to prevent the inadvertent 

introduction of the brown tree snake into Hawaii from Guam. The Secretary also is 

required, to the extent practicable, to take action to prevent the inadvertent introduction 

of the brown tree snake into other areas of the U.S. from Guam. Public Law 102-190 

requires the Secretary of Defense to take action to prevent its introduction by 

Department of Defense aircraft or vessels. §426 note. 

Appropriations Authorized. Congress authorized the Secretary to make expenditures for 

equipment, supplies, and materials, including the employment of persons to carry out 

this Act. § 426b. 

Historical Note. Public Law 99-190, approved in 1935, transferred administration of the 

Act from the Secretary of Agriculture to the Secretary of the Interior. In 1986 

administration of the Act was transferred back to the Secretary of Agriculture. 

Ruth Musgraves, et al, Federal Wildlife & Related Laws Handbook, US Fish and Wildlife 

Service, Chapter 4 - Statute Summaries. Center for Wildlife Law. 
170 Animal Damage Control Act Appendix B 

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 171

APPENDIX C: 

FAA Advisory Circulars 
172 Appendix C 

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Appendix C 173

AC 150/5200-32A Reporting Wildlife Aircraft Strikes 

U.S. Department 

of Transportation 

Federal Aviation 

Administration

Advisory 

Circular

Subject: REPORTING WILDLIFE AIRCRAFT 

STRIKES

Date: 

12/22/04 

Initiated by:

 AAS-300 

AC No: 150/5200-32A 

Change: 

1. PURPOSE: 

This Advisory Circular (AC) explains the importance of reporting collisions between 

aircraft and wildlife, more commonly referred to as wildlife strikes. It also examines 

recent improvements in the Federal Aviation Administration’s (FAA) Bird/Other Wildlife 

Strike Reporting system; how to report a wildlife strike; what happens to the wildlife 

strike report data; how to access the FAA National Wildlife Aircraft Strike Database; and 

the FAA’s Feather Identification program. 

2. BACKGROUND: 

The FAA has long recognized the threat to aviation safety posed by wildlife strikes. 

Worldwide, wildlife strikes cost civil aviation an estimated $1.2 billion annually. Each 

year in the U.S., wildlife strikes to U.S. civil aircraft cause about $500 million in damage 

to aircraft and about 500,000 hours of civil aircraft down time. For the period 1990—

2004, over 63,000 wildlife strikes were reported to the FAA. About 97 percent of all 

wildlife strikes reported to the FAA involve birds, almost 3 percent involve mammals and 

less than 1 percent involved reptiles. Waterfowl (ducks and geese), gulls, and raptors 

(mainly hawks and vultures) are the bird species that cause the most damage to civil 

aircraft in the United States. Vultures and waterfowl cause the most losses to U.S. 

military aircraft. 

The FAA has initiated several programs to address this important safety issue, including 

the collection, analysis, and dissemination of wildlife strike data. The FAA actively 

encourages the voluntary reporting wildlife strikes. 

3. HOW TO REPORT A WILDLIFE AIRCRAFT STRIKE: 

A wildlife strike has occurred when: 

1. A pilot reports striking 1 or more birds or other wildlife 

Aircraft maintenance personnel identify aircraft damage as having been caused by a 

wildlife strike; 
174 AC 150/5200-32A Reporting Wildlife Strikes Appendix C 

2. Personnel on the ground report seeing an aircraft strike 1 or more birds or other 

wildlife; 

3. Bird or other wildlife remains, whether in whole or in part, are found within 200 feet 

of a runway centerline, unless another reason for the animal's death is identified; 

and 

4. An animal's presence on the airport had a significant negative effect on a flight (i.e., 

aborted takeoff, aborted landing, high-speed emergency stop, aircraft left pavement 

area to avoid collision with animal) (Transport Canada, Airports Group, Wildlife 

Control Procedures Manual, Technical Publication 11500E, 1994). 

Pilots, airport operations, aircraft maintenance personnel, or anyone else who has 

knowledge of a strike is encouraged to report it to the FAA. Wildlife strikes may be 

reported to the FAA using the paper FAA Form 5200-7 Bird/Other Wildlife Strike Report, 

or electronically at the Airport Wildlife Hazard Mitigation web site: http://wildlifemitgation.tc.faa.gov. The FAA’s Bird/Other Wildlife Strike Report Form can be 

downloaded or printed from the same web site. Paper copies of Form 5200-7 may also 

be obtained from the Airports District Offices (ADO’s), Flight Standards District Offices 

(FSDO’s), and Flight Service Stations (FSS). Copies of the Bird/Other Wildlife Strike 

Report form are also found in the Airman’s Information Manual (AIM). 

Paper forms are pre-addressed to the FAA. No postage is needed if the form is mailed 

in the United States. It is important to include as much information as possible on the 

strike report. 

The FAA National Wildlife Strike Database Manager edits all strike reports to insure 

consistent, error-free data before entering the report into the Database. This 

information is supplemented with non-duplicated strike reports from other sources. 

About every 6 weeks, an updated version of the Database is posted on the web site. 

Annually, a current version of the Database is forwarded to the International Civil 

Aviation Organization (ICAO) for incorporation into ICAO’s Bird Strike Information 

System Database. 

Analyses of data from the FAA National Wildlife Aircraft Strike Database has proved 

invaluable in determining the nature and severity of the wildlife strike problem. The 

Database provides a scientific basis for identifying risk factors; justifying, implementing 

and defending corrective actions at airports; and for judging the effectiveness of those 

corrective actions. The Database is invaluable to engine manufacturers and 

aeronautical engineers as they develop new technologies for the aviation industry. 

Each wildlife strike report contributes to the accuracy of and effectiveness of the 

Database. Moreover, each report contributes to the common goal of increasing aviation 

safety. 

4. ACCESS TO THE FAA NATIONAL WILDLIFE AIRCRAFT STRIKE DATABASE: 

In order to expedite the dissemination of this important information, the FAA has 

developed procedures for searching the Database on line at: 

http://wildlife-mitigation.tc.faa.gov. The public may access the Database without a 
Appendix C AC 150/5200-32A Reporting Wildlife Strikes 175

password and retrieve basic information on the number of strikes by year, by state, and 

by species of wildlife. 

Access for airport operators, airline operators, engine manufactures, air frame 

manufactures, and certain other governmental agencies requires a password to access 

the Database and allows retrieval of more detailed wildlife strike information for their 

specific area of concern. An airport operator’s access is limited to strike information for 

incidents occurring on its particular airport. Airlines may only access strike records 

involving aircraft owned or operated by them. Comparisons among individual airports 

and airlines are not made. 

Airline and airport operators, airframe and engine manufactures, or governmental 

agencies may gain access the FAA National Wildlife Aircraft Strike Database by writing 

the FAA Staff Wildlife Biologist. All written requests should follow the guidelines 

provided below: 

1. On Company Letterhead, request access to the FAA National Wildlife Aircraft 

Strike Database. Include: 

a. Your preferred password. (The FAA does not assign passwords. The 

password should be no more than 8 characters, alphanumeric, and case 

sensitive.) 

b. Your contact information. (Title, mailing address, phone number, and email address.) 

2. Submit the request to: 

FAA Staff Wildlife Biologist, AAS-300 

Federal Aviation Administration, 

800 Independence Ave. SW. 

 Washington, DC. 20591. 

3. When the FAA receives the request for access to the Database, the request and 

the password will be entered into the system. Upon completion of the process, 

the requestor will be notified by e-mail. 

The Database is accessible from the Airport Wildlife Hazard Mitigation web page 

(http://wildlife-mitigation.tc.faa.gov): 

5. BIRD IDENTIFICATION: 

Accurate species identification is critical for bird-aircraft strike reduction programs. 

Wildlife biologist must know what species of animal they are dealing with in order to 

make proper management decisions. The FAA, the U.S. Air Force, and the U.S. 

Department of Agriculture – Wildlife Services are working closely with the Feather 

Identification Lab at the Smithsonian Institution, Museum of Natural History, to improve 

the understanding and prevention of bird-aircraft strike hazards. Bird strike remains that 

cannot be identified by airport personnel or by a local biologist can be sent (with FAA 

Form 5200-7) to the Smithsonian Museum for identification. 

Feather identification of birds involved in bird-aircraft strikes will be provided free of 

charge to all U.S. airport operators, all U.S. aircraft owners/operators (regardless of 
176 AC 150/5200-32A Reporting Wildlife Strikes Appendix C 

where the strike happened), or to any foreign air carrier if the strike occurred at a U.S. 

airport. 

Please observe the following guidelines for collecting and submitting feather or other 

bird/wildlife remains for species identification. These guidelines help maintain species 

identification accuracy, reduce turn-around time, and maintain a comprehensive FAA 

National Wildlife Aircraft Strike Database. 

1. Collect and submit remains as soon as possible. 

2. Provide complete information regarding the incident 

a. Fill out FAA Form 5200-7 – Bird/Other Wildlife Strike Report. 

i. A copy of Form 5200-7 can be downloaded and or printed from: 

http://wildlife-mitigation.tc.faa.gov. 

b. Mail report with feather material (see address below). 

c. Provide your contact information if you wish to be informed of the species 

identification. 

3. Collect as much material as possible in a clean plastic/ziplock bag. (Please, do not 

send whole birds). 

a. Pluck/pick a variety of feathers from the wings, tail and body.

b. Do not cut off feathers. This removes the downy region we may need to aid 

in identification. 

c. Include any feathers with distinct colors or patterns. 

d. Include any downy “fluff”. 

e. Include beaks, feet, and talons if possible. 

f. Where only a small amount of material is available, such as scrapings from 

an engine or smears on wings or windshields, send all of it. 

g. Do not use any sticky substance such as tape or post-it notes to attach 

feathers. 

4. Mail the Bird/Other Wildlife Strike Report and collected material to the Smithsonian’s 

Feather Identification Lab. They will forward the report to the FAA Staff Wildlife 

Biologist at the FAA’s Office of Airport Safety and Standards. 
Appendix C AC 150/5200-32A Reporting Wildlife Strikes 177

For Material Sent via Express Mail 

Service: For Material Sent via US Postal Service: 

Feather Identification Lab Feather Identification Lab 

Smithsonian Institution Smithsonian Institution 

NHB, E610, MRC 116 PO Box 37012 

10th & Constitution Ave. NW NHB, E610, MRC 116 

Washington, D.C. 20560-0116 Washington, D.C. 20013-7012 

(This can be identified as “safety 

investigation material”) (Not recommended for priority cases.) 

The species identification turn around time is usually 24 hours from receipt. Once 

processed, the reports and species identification information are sent to the Database 

Manager for entry into the FAA National Wildlife Aircraft Strike Database. Persons 

wishing to be notified of the species identification must include contact information (email, phone, etc.) on the report. 

For more information contact The FAA Staff Wildlife Biologist [(202) 267-3389], or the 

Smithsonian’s Feather Identification Lab [(202) 633-0801]. 

J. R. White 

For David L. Bennett 

 Director of airports Safety and standards 
178 AC 150/5200-32A Reporting Wildlife Strikes Appendix C 

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Appendix C 179

AC 150/5200-33A Hazardous Wildlife Attractants On Or Near Airports 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Advisory 

Circular 

Subject: HAZARDOUS WILDLIFE 

ATTRACTANTS ON OR NEAR AIRPORTS 

Date: 

July 27, 2004 

Initiated by: 

AAS-300 

AC No: 

150/5200-33A 

Change: 

1. PURPOSE. This Advisory Circular (AC) provides guidance on certain land uses 

that have the potential to attract hazardous wildlife on or near public-use airports. It 

also discusses airport development projects (including airport construction, expansion, 

and renovation) affecting aircraft movement near hazardous wildlife attractants. 

Appendix 1 provides definitions of terms used in this AC. 

2. APPLICABILITY. The Federal Aviation Administration (FAA) recommends that 

public-use airport operators implement the standards and practices contained in this 

AC. The holders of Airport Operating Certificates issued under Title 14, Code of 

Federal Regulations (CFR), Part 139, Certification of Airports, Subpart D (Part 139), 

may use the standards, practices, and recommendations contained in this AC to comply 

with the wildlife hazard management requirements of Part 139. Airports that have 

received Federal grant-in-aid assistance must use these standards. The FAA also 

recommends the guidance in this AC for land-use planners, operators of noncertificated airports, and developers of projects, facilities, and activities on or near 

airports. 

3. CANCELLATION. This AC cancels AC 150/5200-33, Hazardous Wildlife 

Attractants on or near Airports, dated May 1, 1997. 

4. PRINCIPAL CHANGES. This AC contains the following major changes: 

a. Reorganized outline of the AC. 

b. Expanded Table 1 to include updated information from the Special Report for the 

FAA, “Ranking the Hazard Level of Wildlife Species to Civil Aviation in the USA: 

Update #1, July 2, 2003”. 

c. Removed Table 2, which outlined the distances between certain airport features 

and any on-airport agricultural crops, and relocated the discussion of on-airport 

agricultural activities to Paragraph 2-6. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

180 Appendix C 

d. Added text about the basis for separation distances between wildlife hazards and 

airport movement areas and added Figure 1 depicting the separation distances. 

e. Added options for wetland mitigation for impacts from airport projects, including 

mitigation banking. 

f. Further recognized the importance of the Wildlife Hazard Management Plan 

(WHMP). 

5. BACKGROUND. Information about the risks posed to aircraft by certain wildlife 

species has increased a great deal in recent years. Improved reporting, studies, 

documentation, and statistics clearly show that aircraft collisions with birds and other 

wildlife are a serious economic and public safety problem. While many species of 

wildlife can pose a threat to aircraft safety, they are not equally hazardous. Table 1 

ranks the wildlife groups commonly involved in damaging strikes in the United States 

according to their relative hazard to aircraft. The ranking is based on the 47,212 

records in the FAA National Wildlife Strike Database for the years 1990 through 2003. 

These hazard rankings, in conjunction with site-specific WHAs, will help airport 

operators determine the relative abundance and use patterns of wildlife species and 

help focus hazardous wildlife management efforts on those species most likely to cause 

problems at an airport. 

Most public-use airports have large tracts of open, undeveloped land that provide added 

margins of safety and noise mitigation. These areas can also present potential hazards 

to aviation if they encourage wildlife to enter an airport's approach or departure airspace 

or air operations area (AOA). Constructed or natural areas—such as poorly drained 

locations, detention/retention ponds, roosting habitats on buildings, landscaping, odorcausing rotting organic matter (putrescible waste) disposal operations, wastewater 

treatment plants, agricultural or aquaculture activities, surface mining, or wetlands—can 

provide wildlife with ideal locations for feeding, loafing, reproduction, and escape. Even 

small facilities, such as fast food restaurants, taxicab staging areas, rental car facilities, 

aircraft viewing areas, and public parks, can produce substantial attractions for 

hazardous wildlife. 

During the past century, wildlife-aircraft strikes have resulted in the loss of hundreds of 

lives worldwide, as well as billions of dollars in aircraft damage. Hazardous wildlife 

attractants on and near airports can jeopardize future airport expansion, making proper 

community land-use planning essential. This AC provides airport operators and those 

parties with whom they cooperate with the guidance they need to assess and address 

potentially hazardous wildlife attractants when locating new facilities and implementing 

certain land-use practices on or near public-use airports. 

6. MEMORANDUM OF AGREEMENT BETWEEN FEDERAL RESOURCE 

AGENCIES. The FAA, the U.S. Air Force, the U.S. Army Corps of Engineers, the U.S. 

Environmental Protection Agency, the U.S. Fish and Wildlife Service, and the U.S. 

Department of Agriculture - Wildlife Services signed a Memorandum of Agreement 

(MOA) (final signature July 2003) to acknowledge their respective missions in protecting 

aviation from wildlife hazards. Through the MOA, the agencies established procedures 

necessary to coordinate their missions to address more effectively existing and future 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

181

environmental conditions contributing to collisions between wildlife and aircraft (wildlife 

strikes) throughout the United States. These efforts are intended to minimize wildlife 

risks to aviation and human safety while protecting the Nation’s valuable environmental 

resources. 

DAVID L. BENNETT 

Director, Office of Airport Safety 

and Standards 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

182 Appendix C 

Table 1. Ranking of 25 species groups as to relative hazard to aircraft (1=most hazardous) 

based on three criteria (damage, major damage, and effect-on-flight), a composite ranking 

based on all three rankings, and a relative hazard score. Data were derived from the FAA 

National Wildlife Strike Database, January 1990–April 2003.1

Ranking by criteria 

Species group Damage4 Major damage5 Effect on flight6

Composite 

ranking2

Relative 

hazard score3

Deer 1 1 1 1 100 

Vultures 2 2 2 2 64 

Geese 3 3 6 3 55 

Cormorants/pelicans 4 5 3 4 54 

Cranes 7 6 4 5 47 

Eagles 6 9 7 6 41 

Ducks 5 8 10 7 39 

Osprey 8 4 8 8 39 

Turkey/pheasants 9 7 11 9 33 

Herons 11 14 9 10 27 

Hawks (buteos) 10 12 12 11 25 

Gulls 12 11 13 12 24 

Rock pigeon 13 10 14 13 23 

Owls 14 13 20 14 23 

H. lark/s. bunting 18 15 15 15 17 

Crows/ravens 15 16 16 16 16 

Coyote 16 19 5 17 14 

Mourning dove 17 17 17 18 14 

Shorebirds 19 21 18 19 10 

Blackbirds/starling 20 22 19 20 10 

American kestrel 21 18 21 21 9 

Meadowlarks 22 20 22 22 7 

Swallows 24 23 24 23 4 

Sparrows 25 24 23 24 4 

Nighthawks 23 25 25 25 1 

 

1

 Excerpted from the Special Report for the FAA, “Ranking the Hazard Level of Wildlife Species to Civil 

Aviation in the USA: Update #1, July 2, 2003”. Refer to this report for additional explanations of criteria 

and method of ranking. 

2

 Relative rank of each species group was compared with every other group for the three variables, 

placing the species group with the greatest hazard rank for > 2 of the 3 variables above the next highest 

ranked group, then proceeding down the list. 

3

 Percentage values, from Tables 3 and 4 in Footnote 1 of the Special Report, for the three criteria were 

summed and scaled down from 100, with 100 as the score for the species group with the maximum 

summed values and the greatest potential hazard to aircraft. 

4

 Aircraft incurred at least some damage (destroyed, substantial, minor, or unknown) from strike. 

5

 Aircraft incurred damage or structural failure, which adversely affected the structure strength, 

performance, or flight characteristics, and which would normally require major repair or replacement of 

the affected component, or the damage sustained makes it inadvisable to restore aircraft to airworthy 

condition. 

6

 Aborted takeoff, engine shutdown, precautionary landing, or other. 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

183

1-1. INTRODUCTION. When considering proposed land uses, airport operators, 

local planners, and developers must take into account whether the proposed land uses, 

including new development projects, will increase wildlife hazards. Land-use practices 

that attract or sustain hazardous wildlife populations on or near airports can significantly 

increase the potential for wildlife strikes. 

The FAA recommends the minimum separation criteria outlined below for land-use 

practices that attract hazardous wildlife to the vicinity of airports. Please note that FAA 

criteria include land uses that cause movement of hazardous wildlife onto, into, or 

across the airport’s approach or departure airspace or air operations area (AOA). (See 

the discussion of the synergistic effects of surrounding land uses in Section 2-8 of this 

AC.) 

1-2. AIRPORTS SERVING PISTON-POWERED AIRCRAFT. Airports that do not sell 

Jet-A fuel normally serve piston-powered aircraft. Notwithstanding more stringent 

requirements for specific land uses, the FAA recommends a separation distance of 

5,000 feet at these airports for any of the hazardous wildlife attractants mentioned in 

Section 2 or for new airport development projects meant to accommodate aircraft 

movement. This distance is to be maintained between an airport’s AOA and the 

hazardous wildlife attractant. Figure 1 depicts this separation distance measured from 

the nearest aircraft operations areas. 

1-3. AIRPORTS SERVING TURBINE-POWERED AIRCRAFT. Airports selling Jet-A 

fuel normally serve turbine-powered aircraft. Notwithstanding more stringent 

requirements for specific land uses, the FAA recommends a separation distance of 

10,000 feet at these airports for any of the hazardous wildlife attractants mentioned in 

Section 2 or for new airport development projects meant to accommodate aircraft 

movement. This distance is to be maintained between an airport’s AOA and the 

hazardous wildlife attractant. Figure 1 depicts this separation distance from the nearest 

aircraft movement areas. 

1-4. PROTECTION OF APPROACH, DEPARTURE, AND CIRCLING AIRSPACE. 

For all airports, the FAA recommends a distance of 5 statute miles between the farthest 

edge of the airport’s AOA and the hazardous wildlife attractant if the attractant could 

cause hazardous wildlife movement into or across the approach or departure airspace. 

SECTION 1. 

GENERAL SEPARATION CRITERIA FOR HAZARDOUS WILDLIFE ATTRACTANTS 

ON OR NEAR AIRPORTS. 

The basis for the separation criteria contained in this section can be found in existing 

FAA regulations. The separation distances are based on (1) flight patterns of pistonpowered aircraft and turbine-powered aircraft, (2) the altitude at which most strikes 

happen (78 percent occur under 1,000 feet and 90 percent occur under 3,000 feet 

above ground level), and (3) National Transportation Safety Board (NTSB) 

recommendations. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

184 Appendix C 

Figure 1. Separation distances within which hazardous wildlife attractants should be avoided, 

eliminated, or mitigated. 

PERIMETER A: For airports serving piston-powered aircraft, hazardous wildlife attractants must be 5,000 

feet from the nearest air operations area. 

PERIMETER B: For airports serving turbine-powered aircraft, hazardous wildlife attractants must be 

10,000 feet from the nearest air operations area. 

PERIMETER C: 5-mile range to protect approach, departure and circling airspace. 

PERIMETER A

PERIMETER B

Apron Parking 

Area

Runway

Taxiway Runway

Taxiway

PERIMETER C
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

185

SECTION 2. 

LAND-USE PRACTICES ON OR NEAR AIRPORTS THAT POTENTIALLY ATTRACT 

HAZARDOUS WILDLIFE.

2-1. GENERAL. The wildlife species and the size of the populations attracted to the 

airport environment vary considerably, depending on several factors, including land-use 

practices on or near the airport. This section discusses land-use practices having the 

potential to attract hazardous wildlife and threaten aviation safety. In addition to the 

specific considerations outlined below, airport operators should refer to Wildlife Hazard 

Management at Airports, prepared by FAA and U.S. Department of Agriculture (USDA) 

staff. (This manual is available in English, Spanish, and French. It can be viewed and 

downloaded free of charge from the FAA’s wildlife hazard mitigation web site: 

http://wildlife-mitigation.tc.FAA.gov.). And, Prevention and Control of Wildlife Damage,

compiled by the University of Nebraska Cooperative Extension Division. (This manual 

is available online in a periodically updated version at: 

ianrwww.unl.edu/wildlife/solutions/handbook/.)

2-2. WASTE DISPOSAL OPERATIONS. Municipal solid waste landfills (MSWLF) 

are known to attract large numbers of hazardous wildlife, particularly birds. Because of 

this, these operations, when located within the separations identified in the siting criteria 

in Sections 1-2 through 1-4, are considered incompatible with safe airport operations. 

a. Siting for new municipal solid waste landfills subject to AIR 21. Section 503 of 

the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century 

(Public Law 106-181) (AIR 21) prohibits the construction or establishment of a new 

MSWLF within 6 statute miles of certain public-use airports. Before these 

prohibitions apply, both the airport and the landfill must meet the very specific 

conditions described below. These restrictions do not apply to airports or landfills 

located within the state of Alaska.

The airport must (1) have received a Federal grant(s) under 49 U.S.C. § 47101, et. 

seq.; (2) be under control of a public agency; (3) serve some scheduled air carrier 

operations conducted in aircraft with less than 60 seats; and (4) have total annual 

enplanements consisting of at least 51 percent of scheduled air carrier 

enplanements conducted in aircraft with less than 60 passenger seats. 

The proposed MSWLF must (1) be within 6 miles of the airport, as measured from 

airport property line to MSWLF property line, and (2) have started construction or 

establishment on or after April 5, 2001. Public Law 106-181 only limits the 

construction or establishment of some new MSWLF. It does not limit the expansion, 

either vertical or horizontal, of existing landfills. 

NOTE: Consult the most recent version of AC 150/5200-34, Construction or 

Establishment of Landfills Near Public Airports, for a more detailed discussion of 

these restrictions. 

b. Siting for new MSWLF not subject to AIR 21. If an airport and MSWLF do not 

meet the restrictions of Public Law 106-181, the FAA recommends against locating 

MSWLF within the separation distances identified in Sections 1-2 through 1-4. The 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

186 Appendix C 

e. Composting operations on or near airport property. Composting operations that 

accept only yard waste (e.g., leaves, lawn clippings, or branches) generally do not 

attract hazardous wildlife. Sewage sludge, woodchips, and similar material are not 

municipal solid wastes and may be used as compost bulking agents. The compost, 

however, must never include food or other municipal solid waste. Composting 

operations should not be located on airport property. Off-airport property 

composting operations should be located no closer than the greater of the following 

distances: 1,200 feet from any AOA or the distance called for by airport design 

requirements (see AC 150/5300-13, Airport Design). This spacing should prevent 

material, personnel, or equipment from penetrating any Object Free Area (OFA), 

Obstacle Free Zone (OFZ), Threshold Siting Surface (TSS), or Clearway. Airport 

operators should monitor composting operations located in proximity to the airport to 

ensure that steam or thermal rise does not adversely affect air traffic. On-airport 

disposal of compost by-products should not be conducted for the reasons stated in 

2-3f. 

separation distances should be measured from the closest point of the airport’s AOA 

to the closest planned MSWLF cell. 

c. Considerations for existing waste disposal facilities within the limits of 

separation criteria. The FAA recommends against airport development projects 

that would increase the number of aircraft operations or accommodate larger or 

faster aircraft near MSWLF operations located within the separations identified in 

Sections 1-2 through 1-4. In addition, in accordance with 40 CFR 258.10, owners or 

operators of existing MSWLF units that are located within the separations listed in 

Sections 1-2 through 1-4 must demonstrate that the unit is designed and operated 

so it does not pose a bird hazard to aircraft. (See Sections 4-3(b) and 4-3(c) of this 

AC for a discussion of this demonstration requirement.) 

d. Enclosed trash transfer stations. Enclosed waste-handling facilities that receive 

garbage behind closed doors; process it via compaction, incineration, or similar 

manner; and remove all residue by enclosed vehicles generally are compatible with 

safe airport operations, provided they are not located on airport property or within 

the Runway Protection Zone (RPZ). These facilities should not handle or store 

putrescible waste outside or in a partially enclosed structure accessible to hazardous 

wildlife. Trash transfer facilities that are open on one or more sides; that store 

uncovered quantities of municipal solid waste outside, even if only for a short time; 

that use semi-trailers that leak or have trash clinging to the outside; or that do not 

control odors by ventilation and filtration systems (odor masking is not acceptable) 

do not meet the FAA’s definition of fully enclosed trash transfer stations. The FAA 

considers these facilities incompatible with safe airport operations if they are located 

closer than the separation distances specified in Sections 1-2 through 1-4. 

f. Underwater waste discharges. The FAA recommends against the underwater 

discharge of any food waste (e.g., fish processing offal) within the separations 

identified in Sections 1-2 through 1-4 because it could attract scavenging hazardous 

wildlife. 

g. Recycling centers. Recycling centers that accept previously sorted non-food items, 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

187

2-3. WATER MANAGEMENT FACILITIES. Drinking water intake and treatment 

facilities, storm water and wastewater treatment facilities, associated retention and 

settling ponds, ponds built for recreational use, and ponds that result from mining 

activities often attract large numbers of potentially hazardous wildlife. To prevent 

wildlife hazards, land-use developers and airport operators may need to develop 

management plans, in compliance with local and state regulations, to support the 

operation of storm water management facilities on or near all public-use airports to 

ensure a safe airport environment. 

such as glass, newspaper, cardboard, or aluminum, are, in most cases, not 

attractive to hazardous wildlife and are acceptable. 

h. Construction and demolition (C&D) debris facilities. C&D landfills do not 

generally attract hazardous wildlife and are acceptable if maintained in an orderly 

manner, admit no putrescible waste, and are not co-located with other waste 

disposal operations. However, C&D landfills have similar visual and operational 

characteristics to putrescible waste disposal sites. When co-located with putrescible 

waste disposal operations, C&D landfills are more likely to attract hazardous wildlife 

because of the similarities between these disposal facilities. Therefore, a C&D 

landfill co-located with another waste disposal operation should be located outside of 

the separations identified in Sections 1-2 through 1-4. 

i. Fly ash disposal. The incinerated residue from resource recovery power/heatgenerating facilities that are fired by municipal solid waste, coal, or wood is generally 

not a wildlife attractant because it no longer contains putrescible matter. Landfills 

accepting only fly ash are generally not considered to be wildlife attractants and are 

acceptable as long as they are maintained in an orderly manner, admit no 

putrescible waste of any kind, and are not co-located with other disposal operations 

that attract hazardous wildlife. 

Since varying degrees of waste consumption are associated with general 

incineration (not resource recovery power/heat-generating facilities), the FAA 

considers the ash from general incinerators a regular waste disposal by-product and, 

therefore, a hazardous wildlife attractant if disposed of within the separation criteria 

outlined in Sections 1-2 through 1-4. 

a. Existing storm water management facilities. On-airport storm water 

management facilities allow the quick removal of surface water, including discharges 

related to aircraft deicing, from impervious surfaces, such as pavement and 

terminal/hangar building roofs. Existing on-airport detention ponds collect storm 

water, protect water quality, and control runoff. Because they slowly release water 

after storms, they create standing bodies of water that can attract hazardous wildlife. 

Where the airport has developed a WHMP in accordance with Part 139, the FAA 

requires immediate correction of any wildlife hazards arising from existing storm 

water facilities located on or near airports, using appropriate wildlife hazard 

mitigation techniques. Airport operators should develop measures to minimize 

hazardous wildlife attraction in consultation with a wildlife damage management 

biologist. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

188 Appendix C 

c. Existing wastewater treatment facilities. The FAA strongly recommends that 

airport operators immediately correct any wildlife hazards arising from existing 

wastewater treatment facilities located on or near the airport. Where required, a 

WHMP developed in accordance with Part 139 will outline appropriate wildlife 

hazard mitigation techniques. Accordingly, airport operators should encourage 

wastewater treatment facility operators to incorporate measures, developed in 

Where possible, airport operators should modify storm water detention ponds to 

allow a maximum 48-hour detention period for the design storm. The FAA 

recommends that airport operators avoid or remove retention ponds and detention 

ponds featuring dead storage to eliminate standing water. Detention basins should 

remain totally dry between rainfalls. Where constant flow of water is anticipated 

through the basin, or where any portion of the basin bottom may remain wet, the 

detention facility should include a concrete or paved pad and/or ditch/swale in the 

bottom to prevent vegetation that may provide nesting habitat. 

When it is not possible to drain a large detention pond completely, airport operators 

may use physical barriers, such as bird balls, wires grids, pillows, or netting, to deter 

birds and other hazardous wildlife. When physical barriers are used, airport 

operators must evaluate their use and ensure they will not adversely affect water 

rescue. Before installing any physical barriers over detention ponds on Part 139 

airports, airport operators must get approval from the appropriate FAA Regional 

Airports Division Office. 

The FAA recommends that airport operators encourage off-airport storm water 

treatment facility operators to incorporate appropriate wildlife hazard mitigation 

techniques into storm water treatment facility operating practices when their facility is 

located within the separation criteria specified in Sections 1-2 through 1-4. 

b. New storm water management facilities. The FAA strongly recommends that offairport storm water management systems located within the separations identified in 

Sections 1-2 through 1-4 be designed and operated so as not to create aboveground standing water. On-airport storm water detention ponds should be designed, 

engineered, constructed, and maintained for a maximum 48–hour detention period 

for the design storm and remain completely dry between storms. To facilitate the 

control of hazardous wildlife, the FAA recommends the use of steep-sided, narrow, 

linearly shaped water detention basins. When it is not possible to place these ponds 

away from an airport’s AOA, airport operators should use physical barriers, such as 

bird balls, wires grids, pillows, or netting, to prevent access of hazardous wildlife to 

open water and minimize aircraft-wildlife interactions. When physical barriers are 

used, airport operators must evaluate their use and ensure they will not adversely 

affect water rescue. Before installing any physical barriers over detention ponds on 

Part 139 airports, airport operators must get approval from the appropriate FAA 

Regional Airports Division Office. All vegetation in or around detention basins that 

provide food or cover for hazardous wildlife should be eliminated. If soil conditions 

and other requirements allow, the FAA encourages the use of underground storm 

water infiltration systems, such as French drains or buried rock fields, because they 

are less attractive to wildlife. 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

189

consultation with a wildlife damage management biologist, to minimize hazardous 

wildlife attractants. Airport operators should also encourage those wastewater 

treatment facility operators to incorporate these mitigation techniques into their 

standard operating practices. In addition, airport operators should consider the 

existence of wastewater treatment facilities when evaluating proposed sites for new 

airport development projects and avoid such sites when practicable. 

a. Existing wetlands on or near airport property. If wetlands are located on or near 

airport property, airport operators should be alert to any wildlife use or habitat 

d. New wastewater treatment facilities. The FAA strongly recommends against the 

construction of new wastewater treatment facilities or associated settling ponds 

within the separations identified in Sections 1-2 through 1-4. Appendix 1 defines 

wastewater treatment facility as “any devices and/or systems used to store, treat, 

recycle, or reclaim municipal sewage or liquid industrial wastes.” The definition 

includes any pretreatment involving the reduction of the amount of pollutants or the 

elimination of pollutants prior to introducing such pollutants into a publicly owned 

treatment works (wastewater treatment facility). During the site-location analysis for 

wastewater treatment facilities, developers should consider the potential to attract 

hazardous wildlife if an airport is in the vicinity of the proposed site, and airport 

operators should voice their opposition to such facilities if they are in proximity to the 

airport. 

e. Artificial marshes. In warmer climates, wastewater treatment facilities sometimes 

employ artificial marshes and use submergent and emergent aquatic vegetation as 

natural filters. These artificial marshes may be used by some species of flocking 

birds, such as blackbirds and waterfowl, for breeding or roosting activities. The FAA 

strongly recommends against establishing artificial marshes within the separations 

identified in Sections 1-2 through 1-4. 

f. Wastewater discharge and sludge disposal. The FAA recommends against the 

discharge of wastewater or sludge on airport property because it may improve soil 

moisture and quality on unpaved areas and lead to improved turf growth that can be 

an attractive food source for many species of animals. Also, the turf requires more 

frequent mowing, which in turn may mutilate or flush insects or small animals and 

produce straw, both of which can attract hazardous wildlife. In addition, the 

improved turf may attract grazing wildlife, such as deer and geese. Problems may 

also occur when discharges saturate unpaved airport areas. The resultant soft, 

muddy conditions can severely restrict or prevent emergency vehicles from reaching 

accident sites in a timely manner. 

2-4. WETLANDS. Wetlands provide a variety of functions and can be regulated by 

local, state, and Federal laws. Normally, wetlands are attractive to many types of 

wildlife, including many which rank high on the list of hazardous wildlife species (Table 

1). 

NOTE: If questions exist as to whether an area qualifies as a wetland, contact the local 

division of the U.S. Army Corps of Engineers, the Natural Resources Conservation 

Service, or a wetland consultant qualified to delineate wetlands. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

190 Appendix C 

changes in these areas that could affect safe aircraft operations. At public-use 

airports, the FAA recommends immediately correcting, in cooperation with local, 

state, and Federal regulatory agencies, any wildlife hazards arising from existing 

wetlands located on or near airports. Where required, a WHMP will outline 

appropriate wildlife hazard mitigation techniques. Accordingly, airport operators 

should develop measures to minimize hazardous wildlife attraction in consultation 

with a wildlife damage management biologist. 

b. New airport development. Whenever possible, the FAA recommends locating new 

airports using the separations from wetlands identified in Sections 1-2 through 1-4. 

Where alternative sites are not practicable, or when airport operators are expanding 

an existing airport into or near wetlands, a wildlife damage management biologist, in 

consultation with the U.S. Fish and Wildlife Service, the U.S. Army Corps of 

Engineers, and the state wildlife management agency should evaluate the wildlife 

hazards and prepare a WHMP that indicates methods of minimizing the hazards. 

c. Mitigation for wetland impacts from airport projects. Wetland mitigation may be 

necessary when unavoidable wetland disturbances result from new airport 

development projects or projects required to correct wildlife hazards from wetlands. 

Wetland mitigation must be designed so it does not create a wildlife hazard. The 

FAA recommends that wetland mitigation projects that may attract hazardous wildlife 

be sited outside of the separations identified in Sections 1-2 through 1-4. 

(1) Onsite mitigation of wetland functions. The FAA may consider exceptions to 

locating mitigation activities outside the separations identified in Sections 1-2 

through 1-4 if the affected wetlands provide unique ecological functions, such as 

critical habitat for threatened or endangered species or ground water recharge, 

which cannot be replicated when moved to a different location. Using existing 

airport property is sometimes the only feasible way to achieve the mitigation ratios 

mandated in regulatory orders and/or settlement agreements with the resource 

agencies. Conservation easements are an additional means of providing mitigation 

for project impacts. Typically the airport operator continues to own the property, and 

an easement is created stipulating that the property will be maintained as habitat for 

state or Federally listed species. 

Mitigation must not inhibit the airport operator’s ability to effectively control 

hazardous wildlife on or near the mitigation site or effectively maintain other aspects 

of safe airport operations. Enhancing such mitigation areas to attract hazardous 

wildlife must be avoided. The FAA will review any onsite mitigation proposals to 

determine compatibility with safe airport operations. A wildlife damage management 

biologist should evaluate any wetland mitigation projects that are needed to protect 

unique wetland functions and that must be located in the separation criteria in 

Sections 1-2 through 1-4 before the mitigation is implemented. A WHMP should be 

developed to reduce the wildlife hazards. 

(2) Offsite mitigation of wetland functions. The FAA recommends that wetland 

mitigation projects that may attract hazardous wildlife be sited outside of the 

separations identified in Sections 1-2 through 1-4 unless they provide unique 

functions that must remain onsite (see 2-4c(1)). Agencies that regulate impacts to or 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

191

(3) Mitigation banking. Wetland mitigation banking is the creation or restoration of 

wetlands in order to provide mitigation credits that can be used to offset permitted 

wetland losses. Mitigation banking benefits wetland resources by providing advance 

replacement for permitted wetland losses; consolidating small projects into larger, 

better-designed and managed units; and encouraging integration of wetland 

mitigation projects with watershed planning. This last benefit is most helpful for 

airport projects, as wetland impacts mitigated outside of the separations identified in 

Sections 1-2 through 1-4 can still be located within the same watershed. Wetland 

mitigation banks meeting the separation criteria offer an ecologically sound 

approach to mitigation in these situations. Airport operators should work with local 

watershed management agencies or organizations to develop mitigation banking for 

wetland impacts on airport property. 

around wetlands recognize that it may be necessary to split wetland functions in 

mitigation schemes. Therefore, regulatory agencies may, under certain 

circumstances, allow portions of mitigation to take place in different locations. 

2-5. DREDGE SPOIL CONTAINMENT AREAS. The FAA recommends against 

locating dredge spoil containment areas (also known as Confined Disposal Facilities) 

within the separations identified in Sections 1-2 through 1-4 if the containment area or 

the spoils contain material that would attract hazardous wildlife. 

2-6. AGRICULTURAL ACTIVITIES. Because most, if not all, agricultural crops can 

attract hazardous wildlife during some phase of production, the FAA recommends 

against the used of airport property for agricultural production, including hay crops, 

within the separations identified in Sections 1-2 through 1-4. . If the airport has no 

financial alternative to agricultural crops to produce income necessary to maintain the 

viability of the airport, then the airport shall follow the crop distance guidelines listed in 

the table titled "Minimum Distances between Certain Airport Features and Any OnAirport Agricultural Crops" found in AC 150/5300-13, Airport Design, Appendix 19. The 

cost of wildlife control and potential accidents should be weighed against the income 

produced by the on-airport crops when deciding whether to allow crops on the airport. 

a. Livestock production. Confined livestock operations (i.e., feedlots, dairy 

operations, hog or chicken production facilities, or egg laying operations) often 

attract flocking birds, such as starlings, that pose a hazard to aviation. Therefore, 

The FAA recommends against such facilities within the separations identified in 

Sections 1-2 through 1-4. Any livestock operation within these separations should 

have a program developed to reduce the attractiveness of the site to species that 

are hazardous to aviation safety. Free-ranging livestock must not be grazed on 

airport property because the animals may wander onto the AOA. Furthermore, 

livestock feed, water, and manure may attract birds. 

b. Aquaculture. Aquaculture activities (i.e. catfish or trout production) conducted 

outside of fully enclosed buildings are inherently attractive to a wide variety of birds. 

Existing aquaculture facilities/activities within the separations listed in Sections 1-2 

through 1-4 must have a program developed to reduce the attractiveness of the sites 

to species that are hazardous to aviation safety. Airport operators should also 

oppose the establishment of new aquaculture facilities/activities within the 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

192 Appendix C 

2-7. GOLF COURSES, LANDSCAPING AND OTHER LAND-USE 

CONSIDERATIONS. 

separations listed in Sections 1-2 through 1-4. 

c. Alternative uses of agricultural land. Some airports are surrounded by vast areas 

of farmed land within the distances specified in Sections 1-2 through 1-4. Seasonal 

uses of agricultural land for activities such as hunting can create a hazardous wildlife 

situation. In some areas, farmers will rent their land for hunting purposes. Rice 

farmers, for example, flood their land during waterfowl hunting season and obtain 

additional revenue by renting out duck blinds. The duck hunters then use decoys 

and call in hundreds, if not thousands, of birds, creating a tremendous threat to 

aircraft safety. A wildlife damage management biologist should review, in 

coordination with local farmers and producers, these types of seasonal land uses 

and incorporate them into the WHMP. 

a. Golf courses. The large grassy areas and open water found on most golf courses 

are attractive to hazardous wildlife, particularly Canada geese and some species of 

gulls. These species can pose a threat to aviation safety. The FAA recommends 

against construction of new golf courses within the separations identified in Sections 

1-2 through 1-4. Existing golf courses located within these separations must 

develop a program to reduce the attractiveness of the sites to species that are 

hazardous to aviation safety. Airport operators should ensure these golf courses are 

monitored on a continuing basis for the presence of hazardous wildlife. If hazardous 

wildlife is detected, corrective actions should be immediately implemented. 

b. Landscaping and landscape maintenance. Depending on its geographic location, 

landscaping can attract hazardous wildlife. The FAA recommends that airport 

operators approach landscaping with caution and confine it to airport areas not 

associated with aircraft movements. A wildlife damage management biologist 

should review all landscaping plans. Airport operators should also monitor all 

landscaped areas on a continuing basis for the presence of hazardous wildlife. If 

hazardous wildlife is detected, corrective actions should be immediately 

implemented. 

Turf grass areas can be highly attractive to a variety of hazardous wildlife species. 

Research conducted by the USDA Wildlife Services’ National Wildlife Research 

Center has shown that no one grass management regime will deter all species of 

hazardous wildlife in all situations. In cooperation with wildlife damage management 

biologist, airport operators should develop airport turf grass management plans on a 

prescription basis, depending on the airport’s geographic locations and the type of 

hazardous wildlife likely to frequent the airport 

Airport operators should ensure that plant varieties attractive to hazardous wildlife 

are not used on the airport. Disturbed areas or areas in need of re-vegetating 

should not be planted with seed mixtures containing millet or any other large-seed 

producing grass. For airport property already planted with seed mixtures containing 

millet, rye grass, or other large-seed producing grasses, the FAA recommends 

disking, plowing, or another suitable agricultural practice to prevent plant maturation 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

193

and seed head production. Plantings should follow the specific recommendations 

for grass management and seed and plant selection made by the State University 

Cooperative Extension Service, the local office of Wildlife Services, or a qualified 

wildlife damage management biologist. Airport operators should also consider 

developing and implementing a preferred/prohibited plant species list, reviewed by a 

wildlife damage management biologist, which has been designed for the geographic 

location to reduce the attractiveness to hazardous wildlife for landscaping airport 

property. 

c. Airports surrounded by wildlife habitat. The FAA recommends that operators of 

airports surrounded by woodlands, water, or wetlands refer to Section 2.4 of this AC. 

Operators of such airports should provide for a WHA conducted by a wildlife damage 

management biologist. This WHA is the first step in preparing a WHMP, where 

required. 

d. Other hazardous wildlife attractants. Other specific land uses or activities (e.g., 

sport or commercial fishing, shellfish harvesting, etc.), perhaps unique to certain 

regions of the country, have the potential to attract hazardous wildlife. Regardless of 

the source of the attraction, when hazardous wildlife is noted on a public-use airport, 

airport operators must take prompt remedial action(s) to protect aviation safety. 

2-8. SYNERGISTIC EFFECTS OF SURROUNDING LAND USES. There may be 

circumstances where two (or more) different land uses that would not, by themselves, 

be considered hazardous wildlife attractants or that are located outside of the 

separations identified in Sections 1-2 through 1-4 that are in such an alignment with the 

airport as to create a wildlife corridor directly through the airport and/or surrounding 

airspace. An example of this situation may involve a lake located outside of the 

separation criteria on the east side of an airport and a large hayfield on the west side of 

an airport, land uses that together could create a flyway for Canada geese directly 

across the airspace of the airport. There are numerous examples of such situations; 

therefore, airport operators and the wildlife damage management biologist must 

consider the entire surrounding landscape and community when developing the WHMP. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

194 Appendix C 

SECTION 3. 

 PROCEDURES FOR WILDLIFE HAZARD MANAGEMENT BY OPERATORS OF 

PUBLIC-USE AIRPORTS. 

3.1. INTRODUCTION. In recognition of the increased risk of serious aircraft damage 

or the loss of human life that can result from a wildlife strike, the FAA may require the 

development of a Wildlife Hazard Management Plan (WHMP) when specific triggering 

events occur on or near the airport. Part 139.337 discusses the specific events that 

trigger a Wildlife Hazard Assessment (WHA) and the specific issues that a WHMP must 

address for FAA approval and inclusion in an Airport Certification Manual. 

3.2. COORDINATION WITH USDA WILDLIFE SERVICES OR OTHER QUALIFIED 

WILDLIFE DAMAGE MANAGEMENT BIOLOGISTS. The FAA will use the WHA 

conducted in accordance with Part 139 to determine if the airport needs a WHMP. 

Therefore, persons having the education, training, and expertise necessary to assess 

wildlife hazards must conduct the WHA. The airport operator may look to Wildlife 

Services or to qualified private consultants to conduct the WHA. When the services of a 

wildlife damage management biologist are required, the FAA recommends that land-use 

developers or airport operators contact a consultant specializing in wildlife damage 

management or the appropriate state director of Wildlife Services. 

NOTE: Telephone numbers for the respective USDA Wildlife Services state offices can 

be obtained by contacting USDA Wildlife Services Operational Support Staff, 4700 

River Road, Unit 87, Riverdale, MD, 20737-1234, Telephone (301) 734-7921, Fax (301) 

734-5157 (http://www.aphis.usda.gov/ws/). 

3-3. WILDLIFE HAZARD MANAGEMENT AT AIRPORTS: A MANUAL FOR 

AIRPORT PERSONNEL. This manual, prepared by FAA and USDA Wildlife Services 

staff, contains a compilation of information to assist airport personnel in the 

development, implementation, and evaluation of WHMPs at airports. The manual 

includes specific information on the nature of wildlife strikes, legal authority, regulations, 

wildlife management techniques, WHAs, WHMPs, and sources of help and information. 

The manual is available in three languages: English, Spanish, and French. It can be 

viewed and downloaded free of charge from the FAA’s wildlife hazard mitigation web 

site: http://wildlife-mitigation.tc.FAA.gov/. This manual only provides a starting point for 

addressing wildlife hazard issues at airports. Hazardous wildlife management is a 

complex discipline and conditions vary widely across the United States. Therefore, 

qualified wildlife damage management biologists must direct the development of a 

WHMP and the implementation of management actions by airport personnel. 

There are many other resources complementary to this manual for use in developing 

and implementing WHMPs. Several are listed in the manual's bibliography. 

3-4. WILDLIFE HAZARD ASSESSMENTS, TITLE 14, CODE OF FEDERAL 

REGULATIONS, PART 139. Part 139.337(b) requires airport operators to conduct a 

Wildlife Hazard Assessment (WHA) when certain events occur on or near the airport. 

Part 139.337 (c) provides specific guidance as to what facts must be addressed in a 

WHA. 

3-5. WILDLIFE HAZARD MANAGEMENT PLAN (WHMP). The FAA will consider 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

195

The WHMP must identify hazardous wildlife attractants on or near the airport and the 

appropriate wildlife damage management techniques to minimize the wildlife hazard. It 

must also prioritize the management measures. 

the results of the WHA, along with the aeronautical activity at the airport and the views 

of the airport operator and airport users, in determining whether a formal WHMP is 

needed, in accordance with Part 139.337. If the FAA determines that a WHMP is 

needed, the airport operator must formulate and implement a WHMP, using the WHA as 

the basis for the plan. 

The goal of an airport’s Wildlife Hazard Management Plan is to minimize the risk to 

aviation safety, airport structures or equipment, or human health posed by populations 

of hazardous wildlife on and around the airport. 

3-6. LOCAL COORDINATION. The establishment of a Wildlife Hazards Working 

Group (WHWG) will facilitate the communication, cooperation, and coordination of the 

airport and its surrounding community necessary to ensure the effectiveness of the 

WHMP. The cooperation of the airport community is also necessary when new projects 

are considered. Whether on or off the airport, the input from all involved parties must be 

considered when a potentially hazardous wildlife attractant is being proposed. Airport 

operators should also incorporate public education activities with the local coordination 

efforts because some activities in the vicinity of your airport, while harmless under 

normal leisure conditions, can attract wildlife and present a danger to aircraft. For 

example, if public trails are planned near wetlands or in parks adjoining airport property, 

the public should know that feeding birds and other wildlife in the area may pose a risk 

to aircraft. 

Airport operators should work with local and regional planning and zoning boards so as 

to be aware of proposed land-use changes, or modification of existing land uses, that 

could create hazardous wildlife attractants within the separations identified in Sections 

1-2 through 1-4. Pay particular attention to proposed land uses involving creation or 

expansion of waste water treatment facilities, development of wetland mitigation sites, 

or development or expansion of dredge spoil containment areas. At the very least, 

airport operators must ensure they are on the notification list of the local planning board 

or equivalent review entity for all communities located within 5 miles of the airport, so 

they will receive notification of any proposed project and have the opportunity to review 

it for attractiveness to hazardous wildlife. 

3-7 COORDINATION/NOTIFICATION OF AIRMEN OF WILDLIFE HAZARDS. If an 

existing land-use practice creates a wildlife hazard and the land-use practice or wildlife 

hazard cannot be immediately eliminated, airport operators must issue a Notice to 

Airmen (NOTAM) and encourage the land–owner or manager to take steps to control 

the wildlife hazard and minimize further attraction. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

196 Appendix C 

4-1. FAA REVIEW OF PROPOSED LAND-USE PRACTICE CHANGES IN THE 

VICINITY OF PUBLIC USE AIRPORTS. 

The Environmental Protection Agency (EPA) requires any MSWLF operator 

proposing a new or expanded waste disposal operation within 5 statute miles of a 

runway end to notify the appropriate FAA Regional Airports Division Office and the 

airport operator of the proposal (40 CFR 258, Criteria for Municipal Solid Waste 

Landfills, Section 258.10, Airport Safety). The EPA also requires owners or 

operators of new MSWLF units, or lateral expansions of existing MSWLF units, that 

are located within 10,000 feet of any airport runway end used by turbojet aircraft, or 

within 5,000 feet of any airport runway end used only by piston-type aircraft, to 

demonstrate successfully that such units are not hazards to aircraft. (See 4-2.b 

below.) 

SECTION 4. 

FAA NOTIFICATION AND REVIEW OF PROPOSED LAND-USE PRACTICE 

CHANGES IN THE VICINITY OF PUBLIC USE AIRPORTS 

a. The FAA discourages the development of waste disposal and other facilities, 

discussed in Section 2, located within the 5,000/10,000-foot criteria specified in 

Sections 1-2 through 1-4. 

b. For projects that are located outside the 5,000/10,000-foot criteria but within 5 

statute miles of the airport’s AOA, the FAA may review development plans, 

proposed land-use changes, operational changes, or wetland mitigation plans to 

determine if such changes present potential wildlife hazards to aircraft operations. 

The FAA considers sensitive airport areas as those that lie under or next to 

approach or departure airspace. This brief examination should indicate if further 

investigation is warranted. 

c. Where a wildlife damage management biologist has conducted a further study to 

evaluate a site's compatibility with airport operations, the FAA may use the study 

results to make a determination. 

4-2. WASTE MANAGEMENT FACILITIES. 

a. Notification of new/expanded project proposal. Section 503 of the Wendell H. 

Ford Aviation Investment and Reform Act for the 21st Century (Public Law 106-181) 

limits the construction or establishment of new MSWLF within 6 statute miles of 

certain public use airports, when both the airport and the landfill meet very specific 

conditions. See Section 2-2 of this AC and AC 150/5200-34 for a more detailed 

discussion of these restrictions. 

When new or expanded MSWLF are being proposed near airports, MSWLF 

operators must notify the airport operator and the FAA of the proposal as early as 

possible pursuant to 40 CFR 258. 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

197

Waste handling facilities within separations identified in Sections 1-2 through 1-4. 

To claim successfully that a waste-handling facility sited within the separations identified 

in Sections 1-2 through 1-4 does not attract hazardous wildlife and does not threaten 

aviation, the developer must establish convincingly that the facility will not handle 

putrescible material other than that as outlined in 2-2b. The FAA strongly recommends 

against any facility other than that as outlined in 2-2b (enclosed transfer stations). The 

FAA will use this information to determine if the facility will be a hazard to aviation. 

b. Putrescible-Waste Facilities. In their effort to satisfy the EPA requirement, some 

putrescible-waste facility proponents may offer to undertake experimental measures 

to demonstrate that their proposed facility will not be a hazard to aircraft. To date, no 

such facility has been able to demonstrate an ability to reduce and sustain 

hazardous wildlife to levels that existed before the putrescible-waste landfill began 

operating. For this reason, demonstrations of experimental wildlife control measures 

may not be conducted in an airport’s AOA. 

4-3. OTHER LAND-USE PRACTICE CHANGES. As a matter of policy, the FAA 

encourages operators of public use airports who become aware of proposed land use 

practice changes that may attract hazardous wildlife within 5 statute miles of their 

airports to promptly notify the FAA. The FAA also encourages proponents of such land 

use changes to notify the FAA as early in the planning process as possible. Advanced 

notice affords the FAA an opportunity (1) to evaluate the effect of a particular land-use 

change on aviation safety and (2) to support efforts by the airport sponsor to restrict the 

use of land next to or near the airport to uses that are compatible with the airport. 

The airport operator, project proponent, or land-use operator may use FAA Form 7460-

1, Notice of Proposed Construction or Alteration, or other suitable documents similar to 

FAA Form 7460-1 to notify the appropriate FAA Regional Airports Division Office. 

Project proponents can contact the appropriate FAA Regional Airports Division Office 

for assistance with the notification process. 

It is helpful if the notification includes a 15-minute quadrangle map of the area 

identifying the location of the proposed activity. The land-use operator or project 

proponent should also forward specific details of the proposed land-use change or 

operational change or expansion. In the case of solid waste landfills, the information 

should include the type of waste to be handled, how the waste will be processed, and 

final disposal methods. 

a. Airports that have received Federal grant-in-aid assistance. Airports that have 

received Federal grant-in-aid assistance are required by their grant assurances to 

take appropriate actions to restrict the use of land next to or near the airport to uses 

that are compatible with normal airport operations. The FAA recommends that 

airport operators to the extent practicable oppose off-airport land-use changes or 

practices within the separations identified in Sections 1-2 through 1-4 that may 

attract hazardous wildlife. Failure to do so may lead to noncompliance with 

applicable grant assurances. The FAA will not approve the placement of airport 

development projects pertaining to aircraft movement in the vicinity of hazardous 

wildlife attractants without appropriate mitigating measures. Increasing the intensity 

of wildlife control efforts is not a substitute for eliminating or reducing a proposed 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

198 Appendix C 

wildlife hazard. Airport operators should identify hazardous wildlife attractants and 

any associated wildlife hazards during any planning process for new airport 

development projects. 

b. Additional coordination. If, after initial review by the FAA, questions remain about 

the existence of a wildlife hazard near an airport, airport operators should consult a 

wildlife damage management biologist. Such questions may be triggered by a 

history of wildlife strikes at the airport or the proximity of the airport to a wildlife 

refuge, body of water, or similar feature known to attract wildlife. Once identified, 

such questions require resolution prior to the project’s implementation. 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

199

8. Establish a new MSWLF. When the first load of putrescible waste is received onsite for placement in a prepared municipal solid waste landfill. 

APPENDIX 1. DEFINITIONS OF TERMS USED IN THIS ADVISORY CIRCULAR. 

1. GENERAL. This appendix provides definitions of terms used throughout this AC. 

1. Air operations area. Any area of an airport used or intended to be used for landing, 

takeoff, or surface maneuvering of aircraft. An air operations area includes such 

paved areas or unpaved areas that are used or intended to be used for the 

unobstructed movement of aircraft in addition to its associated runway, taxiways, or 

apron. 

2. Airport operator. The operator (private or public) or sponsor of a public-use airport. 

3. Approach or departure airspace. The airspace, within 5 statute miles of an 

airport, through which aircraft move during landing or takeoff. 

4. Bird balls. High-density plastic floating balls that can be used to cover ponds and 

prevent birds from using the sites. 

5. Certificate holder. The holder of an Airport Operating Certificate issued under Title 

14, Code of Federal Regulations, Part 139. 

6. Construct a new MSWLF. To begin to excavate, grade land, or raise structures to 

prepare a municipal solid waste landfill as permitted by the appropriate regulatory or 

permitting agency. 

7. Detention ponds. Storm water management ponds that hold storm water for short 

periods of time, a few hours to a few days. 

9. Fly ash. The fine, sand-like residue resulting from the complete incineration of an 

organic fuel source. Fly ash typically results from the combustion of coal or waste 

used to operate a power generating plant. 

10. General aviation aircraft. Any civil aviation aircraft not operating under 14 CFR 

Part 119, Certification: Air Carriers and Commercial Operators. 

11. Hazardous wildlife. Species of wildlife (birds, mammals, reptiles), including feral 

animals and domesticated animals not under control, that are associated with 

aircraft strike problems, are capable of causing structural damage to airport facilities, 

or act as attractants to other wildlife that pose a strike hazard 

12. Municipal Solid Waste Landfill (MSWLF). A publicly or privately owned discrete 

area of land or an excavation that receives household waste and that is not a land 

application unit, surface impoundment, injection well, or waste pile, as those terms 

are defined under 40 CFR § 257.2. An MSWLF may receive other types wastes, 

such as commercial solid waste, non-hazardous sludge, small-quantity generator 

waste, and industrial solid waste, as defined under 40 CFR § 258.2. An MSWLF 

can consist of either a stand alone unit or several cells that receive household 

waste. 

13. New MSWLF. A municipal solid waste landfill that was established or constructed 

after April 5, 2001. 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

200 Appendix C 

14. Piston-powered aircraft. Fixed-wing aircraft powered by piston engines. 

20. Retention ponds. Storm water management ponds that hold water for several 

months. 

15. Piston-use airport. Any airport that does not sell Jet-A fuel for fixed-wing turbinepowered aircraft, and primarily serves fixed-wing, piston-powered aircraft. Incidental 

use of the airport by turbine-powered, fixed-wing aircraft would not affect this 

designation. However, such aircraft should not be based at the airport. 

16. Public agency. A State or political subdivision of a State, a tax-supported 

organization, or an Indian tribe or pueblo (49 U.S.C. § 47102(15)). 

17. Public airport. An airport used or intended to be used for public purposes that is 

under the control of a public agency; and of which the area used or intended to be 

used for landing, taking off, or surface maneuvering of aircraft is publicly owned (49 

U.S.C. § 47102(16)). 

18. Putrescible waste. Solid waste that contains organic matter capable of being 

decomposed by micro-organisms and of such a character and proportion as to be 

capable of attracting or providing food for birds (40 CFR §257.3-8). 

19. Putrescible-waste disposal operation. Landfills, garbage dumps, underwater 

waste discharges, or similar facilities where activities include processing, burying, 

storing, or otherwise disposing of putrescible material, trash, and refuse. 

21. Runway protection zone (RPZ). An area off the runway end to enhance the 

protection of people and property on the ground (see AC 150/5300-13). The 

dimensions of this zone vary with the airport design, aircraft, type of operation, and 

visibility minimum. 

22. Scheduled air carrier operation. Any common carriage passenger-carrying 

operation for compensation or hire conducted by an air carrier or commercial 

operator for which the air carrier, commercial operator, or their representative offers 

in advance the departure location, departure time, and arrival location. It does not 

include any operation that is conducted as a supplemental operation under 14 CFR 

Part 119 or as a public charter operation under 14 CFR Part 380 (14 CFR § 119.3). 

23. Sewage sludge. Any solid, semi-solid, or liquid residue generated during the 

treatment of domestic sewage in a treatment works. Sewage sludge includes, but is 

not limited to, domestic septage; scum or solids removed in primary, secondary, or 

advanced wastewater treatment process; and a material derived from sewage 

sludge. Sewage does not include ash generated during the firing of sewage sludge 

in a sewage sludge incinerator or grit and screenings generated during preliminary 

treatment of domestic sewage in a treatment works. (40 CFR 257.2) 

24. Sludge. Any solid, semi-solid, or liquid waste generated form a municipal, 

commercial or industrial wastewater treatment plant, water supply treatment plant, or 

air pollution control facility or any other such waste having similar characteristics and 

effect. (40 CFR 257.2) 

25. Solid waste. Any garbage, refuse, sludge, from a waste treatment plant, water 
Appendix C AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

201

26. Turbine-powered aircraft. Aircraft powered by turbine engines including turbojets 

and turboprops but excluding turbo-shaft rotary-wing aircraft. 

32. Wildlife strike. A wildlife strike is deemed to have occurred when: 

supply treatment plant or air pollution control facility and other discarded material, 

including, solid liquid, semisolid, or contained gaseous material resulting from 

industrial, commercial, mining, and agricultural operations, and from community 

activities, but does not include solid or dissolved materials in domestic sewage, or 

solid or dissolved material in irrigation return flows or industrial discharges which are 

point sources subject to permits under section 402 of the Federal Water Pollution 

Control Act, as amended (86 Stat. 880), or source, special nuclear, or by product 

material as defined by the Atomic Energy Act of 1954, as amended, (68 Stat. 923). 

(40 CFR 257.2) 

27. Turbine-use airport. Any airport that sells Jet-A fuel for fixed-wing turbine-powered 

aircraft. 

28. Wastewater treatment facility. Any devices and/or systems used to store, treat, 

recycle, or reclaim municipal sewage or liquid industrial wastes, including Publicly 

Owned Treatment Works (POTW), as defined by Section 212 of the Federal Water 

Pollution Control Act (P.L. 92-500) as amended by the Clean Water Act of 1977 

(P.L. 95-576) and the Water Quality Act of 1987 (P.L. 100-4). This definition 

includes any pretreatment involving the reduction of the amount of pollutants, the 

elimination of pollutants, or the alteration of the nature of pollutant properties in 

wastewater prior to or in lieu of discharging or otherwise introducing such pollutants 

into a POTW. (See 40 CFR Section 403.3 (o), (p), & (q)). 

29. Wildlife. Any wild animal, including without limitation any wild mammal, bird, reptile, 

fish, amphibian, mollusk, crustacean, arthropod, coelenterate, or other invertebrate, 

including any part, product, egg, or offspring thereof (50 CFR 10.12, Taking, 

Possession, Transportation, Sale, Purchase, Barter, Exportation, and Importation of 

Wildlife and Plants). As used in this AC, wildlife includes feral animals and domestic 

animals out of the control of their owners (14 CFR Part 139, Certification of Airports). 

30. Wildlife attractants. Any human-made structure, land-use practice, or humanmade or natural geographic feature that can attract or sustain hazardous wildlife 

within the landing or departure airspace or the airport’s AOA. These attractants can 

include architectural features, landscaping, waste disposal sites, wastewater 

treatment facilities, agricultural or aquaculture activities, surface mining, or wetlands. 

31. Wildlife hazard. A potential for a damaging aircraft collision with wildlife on or near 

an airport. 

a. A pilot reports striking 1 or more birds or other wildlife; 

b. Aircraft maintenance personnel identify aircraft damage as having been caused 

by a wildlife strike; 

c. Personnel on the ground report seeing an aircraft strike 1 or more birds or other 

wildlife; 
AC 150/5200-33A 

Hazardous Wildlife Attractants on or Near Airports 

202 Appendix C 

2. RESERVED 

d. Bird or other wildlife remains, whether in whole or in part, are found within 200 

feet of a runway centerline, unless another reason for the animal's death is 

identified; 

e. The animal's presence on the airport had a significant negative effect on a flight 

(i.e., aborted takeoff, aborted landing, high-speed emergency stop, aircraft left 

pavement area to avoid collision with animal) (Transport Canada, Airports Group, 

Wildlife Control Procedures Manual, Technical Publication 11500E, 1994). 
Appendix C 203

AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Advisory 

Circular 

SUBJECT: 

CONSTRUCTION OR ESTABLISHMENT OF 

LANDFILLS NEAR PUBLIC AIRPORTS

Date: 8/26/2000 

Initiated by: 

AAS-300 

AC No: 

150/5200-34 

Change: 

1. Purpose. This advisory circular (AC) contains guidance on complying with new 

Federal statutory requirements regarding the construction or establishment of landfills 

near public airports.

2. Application. The guidance contained in the AC is provided by the Federal Aviation 

Administration (FAA) for use by persons considering the construction or establishment 

of a municipal solid waste landfill (MSWLF) near a public airport. Guidance contained 

herein should be used to comply with recently enacted MSWLF site limitations 

contained in 49 U.S.C. § 44718(d), as amended by section 503 of the Wendell H. Ford 

Aviation Investment and Reform Act for the 21st Century, Pub. L. No. 106-181 (April 5, 

2000), "Structures interfering with air commerce." In accordance with § 44718(d), as 

amended, these site limitations are not applicable in the State of Alaska.

In addition, this AC provides guidance for a state aviation agency desiring to petition the 

FAA for an exemption from the requirements of § 44718(d), as amended. 

3. Related Reading Materials. 

a. AC - 150/5200-33, Hazardous Wildlife Attractions On or Near Airports, May 1, 

1997. 

b. Wildlife Strikes to Civil Aircraft in the United States 1990-1998, FAA Wildlife 

Aircraft Strike Database Serial Report Number 5, November 1998. 

c. Report to Congress: Potential Hazards to Aircraft by Locating Waste Disposal 

Sites in the Vicinity of Airports, April 1996, DOT/FAA/AS/96-1. 

d. Title 14, Code of Federal Regulation, Part 139, Certification and Operations: 

Land Airports Serving Certain Air Carriers. 

e. Title 40, Code of Federal Regulation, Part 258, Municipal Solid Waste Landfill 

Criteria. 
AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports

204 Appendix C 

Some of these documents and additional information on wildlife management, including 

guidance on landfills, are available on the FAA’s Airports web site at 

www.faa.gov/arp/arphome.htm.

From 1990 to 1999, waterfowl, gulls and raptors were involved in 77% of the 2,119 

reported damaging aircraft-wildlife strikes where the bird was identified. Populations of 

Canada geese and many species of gulls and raptors have increased markedly over the 

last several years. Further, gulls and Canada geese have adapted to urban and 

suburban environments and, along with raptors and turkey vultures, are commonly 

found feeding or loafing on or near landfills. 

4. Definitions. Definitions for the specific purpose of this AC are found in Appendix 1. 

5. Background. The FAA has the broad authority to regulate and develop civil aviation 

under the Federal Aviation Act of 1958, 49 U.S.C. § 40101, et. seq., and other Federal 

law. In section 1220 of the Federal Aviation Reauthorization Act of 1996, Pub. L. No. 

104-264 (October 9, 1996), the Congress added a new provision, section (d), to 49 

U.S.C. § 44718 to be enforced by the FAA and placing limitations on the construction or 

establishment of landfills near public airports for the purposes of enhancing aviation 

safety. Section 503 of the Wendell H. Ford Aviation Investment and Reform Act for the 

21st Century (AIR-21), Pub. L. No. 106-181 (April 5, 2000) has replaced section 1220 of 

the 1996 Reauthorization Act, 49 U.S.C. § 44718 (d), with new language. Specifically, 

the new provision, § 44718(d), as amended, was enacted to further limit the 

construction or establishment of a MSWLF near certain smaller public airports. 

In enacting this legislation, Congress expressed concern that a MSWLF sited near an 

airport poses a potential hazard to aircraft operations because such a waste facility 

attracts birds. Statistics support the fact that bird strikes pose a real danger to aircraft. 

An estimated 87 percent of the collisions between wildlife and civil aircraft occurred on 

or near airports when aircraft are below 2,000 feet above ground level (AGL). Collisions 

with wildlife at these altitudes are especially dangerous as aircraft pilots have minimal 

time to recover from such emergencies. 

Databases managed by FAA and the United States Air Force show that more than 

54,000 civil and military aircraft sustained reported strikes with wildlife from 1990 to 

1999 (28,150 civil strikes and 25,853 military strikes). Between 1990-1999, aircraftwildlife strikes involving U. S. civil aircraft result in over $350 million/year worth of 

aircraft damage and associated losses and over 460,000 hours/year of aircraft down 

time. 

In light of increasing bird populations and aircraft operations, the FAA believes locating 

landfills in proximity to airports increases the risk of collisions between birds and aircraft. 

To address this concern, the FAA issued AC 150/5200-33, Hazardous Wildlife 

Attractions On or Near Airports, to provide airport operators and aviation planners with 

guidance on minimizing wildlife attractant. AC 150/5200-33 recommends against 

locating municipal solid waste landfills within five statute miles of an airport if the landfill 

may cause hazardous wildlife to move into or through the airport's approach or 

departure airspace. 

6. General. Using guidance provided in the following sections, persons considering 
Appendix C AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports 

205

While the FAA does not classify airports precisely in this manner, the FAA does 

categorize airports by the type of aircraft operations served and number of annual 

passenger enplanements. In particular, the FAA categorizes public airports that serve 

air carrier operations. These airports are known as commercial service airports, and 

receive scheduled passenger service and have 2,500 or more enplaned passengers per 

year. 

construction or establishment of a landfill should first determine if the proposed facility 

meets the definition of a new MSWLF (see Appendix 1). Section 44718(d), as amended, 

applies only to a new MSWLF. It does not apply to the expansion or modification of an 

existing MSWLF, and does not apply in the State of Alaska. If the proposed landfill 

meets the definition of a new MSWLF, its proximity to certain public airports (meeting 

the criteria specified in Paragraph 8 below) should be determined. If it is determined that 

a new MSWLF would be located within six miles of such a public airport, then either the 

MSWLF should be planned for an alternate location more than 6 miles from the airport, 

or the MSWLF proponent should request the appropriate State aviation agency to file a 

petition for an exemption from the statutory restriction. 

In addition to the requirements of § 44718(d), existing landfill restrictions contained in 

AC 150/5200-33, Hazardous Wildlife Attractions On or Near Airports (see Paragraph 5, 

Background) also may be applicable. Airport operators that have accepted Federal 

funds have obligations under Federal grant assurances to operate their facilities in safe 

manner and must comply with standards prescribed in advisory circulars, including 

landfill site limitations contained in AC 150/5200-33. 

7. Landfills Covered by the Statute. The limitations of § 44718(d), as amended, only 

apply to a new MSWLF (constructed or established after April 5, 2000). The statutory 

limitations are not applicable where construction or establishment of a MSWLF began 

on or before April 5, 2000, or to an existing MSWLF (received putrescible waste on or 

before April 5, 2000). Further, an existing MSWLF that is expanded or modified after 

April 5, 2000, would not be held to the limitations of § 44718(d), as amended. 

8. Airports Covered by the Statute. The statutory limitations restricting the location of 

a new MSWLF near an airport apply to only those airports that are recipients of Federal 

grants (under the Airport and Airway Improvement Act of 1982, as amended, 49 U.S.C. 

§ 47101, et seq.) and to those that primarily serve general aviation aircraft and 

scheduled air carrier operations using aircraft with less than 60 passenger seats. 

One sub-category of commercial service airports, nonhub primary airports, closely 

matches the statute requirement. Nonhub primary airports are defined as commercial 

service airports that enplane less than 0.05 percent of all commercial passenger 

enplanements (0.05 percent equated to 328,344 enplanements in 1998) but more than 

10,000 annual enplanements. While these enplanements consist of both large and 

small air carrier operations, most are conducted in aircraft with less than 60 seats. 

These airports also are heavily used by general aviation aircraft, with an average of 81 

based aircraft per nonhub primary airport. 

In addition, the FAA categorizes airports that enplane 2,500 to 10,000 passengers 

annually as non-primary commercial service airports, and those airports that enplane 
AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports

206 Appendix C 

3. Serve some scheduled air carrier operations conducted in aircraft with less 

than 60 seats; and 

2,500 or less passengers annually as general aviation airports. Both types of airports 

are mainly used by general aviation but in some instances, they have annual 

enplanements that consist of scheduled air carrier operations conducted in aircraft with 

less than 60 seats. Of the non-primary commercial service airports and general aviation 

airports, only those that have scheduled air carrier operations conducted in aircraft with 

less than 60 seats would be covered by the statute. The statute does not apply to those 

airports that serve only general aviation aircraft operations. 

To comply with the intent of the statute, the FAA has identified those airports classified 

as nonhub primary, non-primary commercial service and general aviation airports that: 

1. Are recipients of Federal grant under 49 U.S.C. § 47101, et. seq.; 

2. Are under control of a public agency; 

4. Have total annual enplanements consisting of at least 51% of scheduled air 

carrier enplanements conducted in aircraft with less than 60 passenger seats. 

Persons considering construction or establishment of a new MSWLF should contact the 

FAA to determine if an airport within six statute miles of the new MSWLF meets these 

criteria (see paragraph 11 below for information on contacting the FAA). If the FAA 

determines the airport does meet these criteria, then § 44718(d), as amended, is 

applicable. 

An in-depth explanation of how the FAA collects and categorizes airport data is 

available in the FAA’s National Plan of Integrated Airport Systems (NPIAS). This report 

and a list of airports classified as nonhub primary, non-primary commercial service and 

general aviation airports (and associated enplanement data) are available on the FAA’s 

Airports web site at http://www.faa.gov/arp/410home.htm. 

9. Separation distance measurements. Section 44718(d), as amended, requires a 

minimum separation distance of six statute miles between a new MSWLF and a public 

airport. In determining this distance separation, measurements should be made from 

the closest point of the airport property boundary to the closest point of the MSWLF 

property boundary. Measurements can be made from a perimeter fence if the fence is 

co-located, or within close proximity to, property boundaries. It is the responsibility of the 

new MSWLF proponent to determine the separation distance. 

10. Exemption Process. Under § 44718(d), as amended, the FAA Administrator may 

approve an exemption from the statute’s landfill location limitations. Section 44718(d), 

as amended, permits the aviation agency of the state in which the airport is located to 

request such an exemption from the FAA Administrator. Any person desiring such an 

exemption should contact the aviation agency in the state in which the affected airport is 

located. A list of state aviation agencies and contact information is available at the 

National Association of State Aviation Officials (NASAO) web site at www.nasao.org or 

by calling NASAO at (301) 588-1286. 

A state aviation agency that desires to petition the FAA for an exemption should notify 

the Regional Airports Division Manager, in writing, at least 60 days prior to the 
Appendix C AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports 

207

establishment or construction of a MSWLF. The petition should explain the nature and 

extent of relief sought, and contain information, documentation, views, or arguments 

that demonstrate that an exemption from the statute would not have an adverse impact 

on aviation safety. Information on contacting FAA Regional Airports Division Managers 

can be found on the FAA’s web site at www.faa.gov. 

After considering all relevant material presented, the Regional Airports Division 

Manager will notify the state agency within 30 days whether the request for exemption 

has been approved or denied. The FAA may approve a request for an exemption if it is 

determined that such an exemption would have no adverse impact on aviation safety. 

11. Information. For further information, please contact the FAA’s Office of Airport 

Safety and Standards, Airport Safety and Certification Branch, at (800) 842-8736, Ext. 

73085 or via email at WebmasterARP@faa.gov. Any information, documents and 

reports that are available on the FAA web site also can be obtained by calling the tollfree telephone number listed above. 

DAVID L. BENNETT 

Director, Office of Airport Safety and Standards 
AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports

208 Appendix C 

APPENDIX 1. DEFINITIONS. 

e. Municipal solid waste landfill (MSWLF) means publicly or privately owned discrete 

area of land or an excavation that receives household waste, and that is not a land 

application unit, surface impoundment, injection well, or waste pile, as those terms 

are defined under 40 CFR § 257.2. A MSWLF may receive other types of RCRA 

subtitle D wastes, such as commercial solid waste, nonhazardous sludge, small 

quantity generator waste and industrial solid waste, as defined under 40 CFR § 

258.2. A MSWLF may consist of either a standalone unit or several cells that receive 

household waste. 

k. Scheduled air carrier operation means any common carriage passenger-carrying 

operation for compensation or hire conducted by an air carrier or commercial 

operator for 8/26/00 AC 150/5200-34 Appendix 17 which the air carrier, commercial 

operator, or their representatives offers in advance the departure location, departure 

time, and arrival location. It does not include any operation that is conducted as a 

supplemental operation under 14 CFR Part 119, or is conducted as a public charter 

operation under 14 CFR Part 380 (14 CFR § 119.3). 

The following are definitions for the specific purpose of this advisory circular. 

a. Construct a municipal solid waste landfill (MSWLF) means excavate or grade land, 

or raise structures, to prepare a municipal solid waste landfill as permitted by the 

appropriate regulatory or permitting authority. 

b. Establish a municipal solid waste landfill (MSWLF) means receive the first load of 

putrescible waste on site for placement in a prepared municipal solid waste landfill. 

c. Existing municipal solid waste landfill (MSWLF) means a municipal solid waste 

landfill that received putrescible waste on or before April 5, 2000. 

d. General aviation aircraft means any civil aviation aircraft not operating under 14 CFR 

Part 119, Certification: Air carriers and commercial operators. 

f. New municipal solid waste landfill (MSWLF) means a municipal solid waste landfill 

that was established or constructed after April 5, 2000. 

g. Person(s) means an individual, firm, partnership, corporation, company, association, 

joint-stock association, or governmental entity. It includes a trustee, receiver, 

assignee, or similar representative of any of them (14 CFR Part 1). 

h. Public agency means a State or political subdivision of a State; a tax-supported 

organization; or an Indian tribe or pueblo (49 U.S.C. § 47102(15)). 

i. Public airport means an airport used or intended to be used for public purposes that 

is under the control of a public agency; and of which the area used or intended to be 

used for landing, taking off, or surface maneuvering of aircraft is publicly owned (49 

U.S.C. § 47102(16)). 

j. Putrescible waste means solid waste which contains organic matter capable of being 

decomposed by micro-organisms and of such a character and proportion as to be 

capable of attracting or providing food for birds (40 CFR § 257.3-8). 
Appendix C AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports 

209

l. Solid waste means any garbage, or refuse, sludge from a wastewater treatment 

plant, water supply treatment plant, or air pollution control facility and other 

discarded material, including solid, liquid, semi-solid, or contained gaseous material 

resulting from industrial, commercial, mining, and agricultural operations, and from 

community activities, but does not include solid or dissolved materials in domestic 

sewage, or solid or dissolved materials in irrigation return flows or industrial 

discharges that are point sources subject to permit under 33 U.S.C. § 1342, or 

source, special nuclear, or by-product material as defined by the Atomic Energy Act 

of 1954, as amended (68 Stat. 923) (40 CFR § 258.2). 
AC 150/5200-34 

Construction or Establishment of Landfills Near Public Airports

210 Appendix C 

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Appendix C 211

AC 150/5300-13 Airport Design. Appendix 19. 

 Minimum Distances Between Certain Airport Features And Any OnAirport Agriculture Crops.

Distance In Feet From 

Runway Centerline To 

Crop 

Distance In Feet 

From Runway End 

To Crop Aircraft Approach 

Category And Design 

Group 1

Visual &>

3⁄4 mile < 3⁄4 mile

Visual &>

3⁄4 mile < 3⁄4 mile

Distance In 

Feet from 

Centerline 

Of Taxiway 

To Crop 

Distance In 

Feet from 

Edge Of 

Apron To Crop

Category A & B Aircraft 

Group I 200 2 400 3003 600 45 40

Group II 250 400 400 53 3 600 66

Group III 400 400 600 300 93 31 

Group IV 400 400 1,000 1,000 130 113 

Category C, D & E Aircraft 

Group I 5303 5753 1,000 1,000 45 40 

Group II 5303 5753 1,000 1,000 66 53 

Group III 5303 5753 1,000 1,000 93 31 

Group IV 5303 5753 1,000 1,000 130 113

Group V 5303 5753 1,000 1,000 160 133

Group VI 5303 5753 1,000 1,000 193 167

1

 Design Groups are based on wing span, and Category depends on approach speed of the aircraft.

Group I: Wing span up to 49 ft. Category A: Speed less than 91 knots 

Group II Wing span 49ft. up to 73 ft. Category B: Speed 91 knots up to 120 knots 

Group III: Wing span 79 ft. up to 117 ft. Category C: Speed 121 knots up to 140 

knots 

Group IV: Wing span 113 ft. up to 170 ft. Category D: Speed 141 knots up to 165 

knots 

Group V: Wing span 171 ft. up to 213 ft. Category E: Speed 166 knots or more 

Group VI: Wing span 214 ft. up to 261 ft. 

3 These dimensions reflect the TSS as defined in AC 150/5300-13, Appendix 2. The TSS cannot be penetrated by

any object. Under these conditions, the TSS is more restrictive than the OFA, and the dimensions shown here are to 

prevent penetration of the TSS by crops and farm machinery.

2

 If the runway will only serve small airplanes (12,500 lb. And under) in Design Group I, this dimension may be 

reduced to 125 feet; however, this dimension should be increased where necessary to accommodate visual 

navigational aids that may be installed. For example farming operations should not be allowed within 25 feet of a 

Precision Approach Path Indicator (PAPI) light box.
212 AC 150/5300-13 Airport Design, Appendix 19 Appendix C 

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 213

APPENDIX D: 

FAA, Office Of Airport Safety And Standards, 

Program Policies And Guidance — 

Airport Certification Program – 14 CFR 139 
214 Appendix D 

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Appendix D 215

Airport Certification Program – 14 CFR 139 

Program Policy And Guidance 

Policy No. 77: Initiation of Wildlife Hazard Assessments at Airports 

14 CFR 139.337 June 21, 2004

SUBJECT :

Initiation of Wildlife Hazard Assessments at Airports. 

CANCELLATION: 

Program Policy and Guidance Policy Number 53, Initiation of Wildlife Hazard 

Assessments at Airports, Issued April 25, 1997 is cancelled. 

PURPOSE: 

This policy establishes the procedures Federal Aviation Administration (FAA) Airport 

Certification Safety Inspectors (ACSI) should follow when it is determined that an airport 

needs to conduct a wildlife hazard assessment to address an airport wildlife hazard. 

BACKGROUND: 

Populations of wildlife species commonly associated with wildlife/aircraft strikes are 

increasing at a marked rate in the United States. For example, the resident Canada 

goose population quadrupled between 1986 and 2002; white-tailed deer populations 

increased from 350,000 in 1900 to over 26 million in 2000; and ring-billed gull 

populations increased 4-fold between 1966 and 1999. The presence of wildlife on and 

near airports creates a hazard to operating aircraft. 

Wildlife/aircraft strikes cause severe damage to operating aircraft, human injuries and 

loss of life. It is estimated that between 1990 and 2002, wildlife strikes cost U. S. civil 

aviation over $500 million annually. 

Title 14, Code of Federal Regulations, part 139.337 requires the certificate holder to 

conduct a wildlife hazard assessment, acceptable to the FAA, when a wildlife hazard 

exist on the airport. This study is used by the FAA to determine if a wildlife hazard 

management plan is needed for the airport. A Memorandum of Understanding (MOU) 

between the FAA and USDA Wildlife Services (No. 12-34-71-0003-MOU) establishes a 

cooperative relationship between these agencies for resolving wildlife hazards to 

aviation. The FAA relies heavily on the assistance of Wildlife Services to conduct, 

review, or contribute to, airport wildlife hazard assessments and airport wildlife hazard 

management plans. 
Policy No. 77 

Initiation of Wildlife Hazard Assessments at Airports 

216 Appendix D 

Contact the appropriate airport official and inform them of the need for the study. 

Review the airport’s certification manual (ACM) to determine what procedures are 

already in place to meet section 139.337 requirements and the degree of compliance on 

the part of the airport. Failure of the certificate holder to fully comply with all part 139 

requirements is a violation of the regulation. 

Take follow-up actions as needed to insure timely initiation and completion of the study, 

as well as submission of the study results and recommendations. 

June 21, 2004 

Date 

PROCEDURES: 

When the FAA determines that a wildlife hazard assessment is needed for a particular 

airport, the ACSI should: 

The certificate holder may look to ADC or to a private party to conduct the required 

wildlife hazard assessment. The certificate holder is responsible for consultant 

selection and initial contact. Because the wildlife hazard assessment is used by the 

FAA to determine if a wildlife hazard management plan is needed for the airport, it 

should be conducted by persons having the education, training, and experience 

necessary to adequately assess any wildlife hazards. 

Give the airport sufficient time (normally no more than 30 days) to make the initial 

contact and set a date when the study will begin. 

Review the study and recommendations to determine if an airport wildlife hazard 

management plan is needed. Upon completion of the review process, convey the 

determination to the certificate holder. 

OSB 

Ben Castellano, Manager 

Airport Safety & Operations Division 
 217

Airport Certification Program – 14 CFR 139 

Program Policy And Guidance 

Policy No. 78: 

Section 7 Consultation on Endangered or Threatened Species 

14 CFR 139.337 June 21, 2004

SUBJECT: 

Section 7 Consultation on Endangered or Threatened Species. 

CANCELLATION: 

Program Policy and Guidance Policy Number 57, Section 7 Consultation on 

Endangered or Threatened Species. Issued March 19, 1998 is cancelled. 

This policy establishes the procedures for coordinating and documenting Federal 

Aviation Administration (FAA) compliance with the Endangered Species Act when 

requiring an airport operator to develop, submit for approval, and implement a Wildlife 

Hazard Management Plan. 

BACKGROUND: 

Section 7(a)(2) of the Endangered Species Act of 1973, as amended, (16 U.S.C. 1531 

et seq.) states, in part, that each Federal agency shall, in consultation with and with the 

assistance of the Secretary of Interior, insure that any action authorized, funded, or 

carried out by such agency is not likely to jeopardize the continued existence of any 

Federally-listed or proposed endangered or threatened species, or result in the 

destruction or adverse modification of designated or proposed critical habitat. 

The FAA’s action in requiring an airport operator to develop, submit for approval, and 

implement a Wildlife Hazard Management Plan is considered a Federal action, as 

defined in the Endangered Species Act, and therefore, subject to section 7 consultation 

with the U.S. Fish and Wildlife Service (USFWS). 

PROCEDURES: 

PURPOSE: 

Under Title 14, Code of Federal Regulations, part 139.337(e), the FAA may direct an 

airport operator to develop a Wildlife Hazard Management Plan or to update an existing 

plan. In these instances, the FAA Regional Coordinator (usually the Airport Certification 

Safety Inspector responsible for wildlife hazards) shall contact and request information 

from the local USFWS Ecological Services Field Office regarding the presence of 

Federally-listed or proposed species or designated or proposed critical habitat occurring 

on or near the airport. Form letter #1 (attached) shall be used to make this request.
Policy No. 78 

Section 7 Consultation on Endangered or Threatened Species 

218 Appendix D 

FURTHER COORDINATION IS REQUIRED. 

a) The airport operator must prepare a Biological Assessment (50 CFR 402.13) 

assessing the affects of the Wildlife Hazard Management Plan on the Federally-listed or 

proposed species or designated or proposed critical habitat. The Biological 

Assessment must be submitted to FAA along with the draft plan. 

3) The section-7 consultation must be completed before the Wildlife Hazard 

Management Plan is given final FAA approval and returned to the airport operator for 

inclusion in its Airport Certification Manual and implementation. 

OSB 

Ben Castellano, Manager 

Airport Safety & Operations Division 

NO FURTHER COORDINATION IS REQUIRED. 

If the USFWS indicates there are no Federally-listed or proposed species or designated 

or proposed critical habitat occurring on or near the airport, no further action is required 

regarding the section 7 consultation. 

If the USFWS indicates that Federally-listed or proposed species or designated or 

proposed critical habitat occur on or near the airport, the following additional actions 

must be taken. 

1) The FAA Regional Coordinator shall forward the information regarding the 

presence of Federally-listed or proposed species or designated or proposed critical 

habitat to the airport so it can take this information into consideration when developing 

its Wildlife Hazard Management Plan. 

b) The airport operator may request early consultation if it has reasons to believe 

some of the actions proposed under the Wildlife Hazard Management Plan may affect 

Federally-listed or proposed species or designated or proposed critical habitat. 

2) When the plan is submitted to the FAA for review and approval, the FAA 

Regional Coordinator must contact the local USFWS Ecological Services Field Office 

responsible for section 7 consultations and request consultation on the plan. Form 

letter #2 (attached) shall be used to submit the Wildlife Hazard Management Plan to 

USFWS ES for section-7 consultation. 

4) The signature level for both letters is at the discretion of the FAA Regional Office. 

June 21, 2004 

Date 
Appendix D Policy No. 78 

Section 7 Consultation on Endangered or Threatened Species 

219

FORM LETTER #1 

As part of the Wildlife Hazard Management Plan developmental process, potential 

impact on federally-listed or proposed species or designated or proposed critical habitat 

will be considered. Therefore, would you provide information concerning the presence 

of federally-listed or proposed species or designated or proposed critical habitat 

occurring on or near the airport? 

Request for information regarding the presence of Federally-listed or proposed species 

or designated or proposed critical habitat. 

Because of recent wildlife aircraft strikes at __________ Airport in ______County, 

____(State), the Federal Aviation Administration (FAA) is requiring the airport develop a 

Wildlife Hazard Management Plan to reduce the wildlife aircraft strike hazard at the 

airport. 

Please reply to the attention of _________, [and reference file no. ________ ]. 

Thank you for your cooperation in this matter. 
Policy No. 78 

Section 7 Consultation on Endangered or Threatened Species 

220 Appendix D 

FORM LETTER #2

Request for Section 7 Consultation. 

At the direction of the Federal Aviation Administration (FAA), __________ Airport in 

______County, ____(State), has developed the attached Wildlife Hazard Management 

Plan, which is intended to mitigate wildlife aircraft strike hazards at the airport. 

The actions proposed in the plan may include: 

Habitat modifications - reduction/elimination of food, cover, and water attractive to 

certain wildlife species. 

Resource protection - repelling of certain wildlife species using physical barriers and/or 

chemical, audio, and/or visual repellents. 

Population management - removal of certain wildlife species from the vicinity of the 

airport using non-lethal and lethal means. 

In accordance with Section 7 of the Endangered Species Act of 1973, as amended, the 

FAA has reviewed the draft plan and has determined that the plan is/is not (select one; 

consult the FAA Staff Wildlife Biologist if assistance is needed in making the 

determination of effect.) likely to adversely affect the following federally-listed or 

proposed species or designated or proposed critical habitat: (list federally-listed or 

proposed species or designated or proposed critical habitat from information provided 

by USFWS ES, in response to form letter #1). 

Please reply to the attention of _________, [and reference file no. ________ ]. 

Thank you for your cooperation in this matter. 
Appendix D 221

Airport Certification Program - 14 CFR 139 

Program Policy And Guidance 

Policy No. 79: Review of Airport Wildlife Hazard Management Plans 

14 CFR 139.337 June 21, 2004

SUBJECT: 

Review of Airport Wildlife Hazard Management Plans. 

CANCELLATION: 

Program Policy and Guidance Policy Number 64, Review of Airport Wildlife Hazard 

Management Plans, Issued October 4, 1999 is cancelled. 

PURPOSE: 

This policy establishes procedures Airport Certification Safety Inspectors must follow 

when an incident occurs that requires an operator of a certificated airport to initiate a 

Wildlife Hazard Assessment, as mandated under Title 14, Code of Federal Regulations, 

§139.337(b)(1-4). 

BACKGROUND: 

Part 139.337 prescribes action that a certificate holder must take in response to certain 

wildlife events. As a reminder, the requirements states: 

(b) In a manner authorized by the Administrator, each certificate holder shall ensure that 

a Wildlife Hazard Assessment is conducted when any of the following events occurs on 

or near the airport: 

(1) An air carrier aircraft experiences multiple wildlife strikes; 

(2) An air carrier aircraft experiences substantial damage from striking wildlife. As used 

in this paragraph, substantial damage means damage or structural failure incurred by 

an aircraft that adversely affects the structural strength, performance, or flight 

characteristics of the aircraft and that would normally require major repair or 

replacement of the affected component; 

(3) An air carrier aircraft experiences an engine ingestion of wildlife; or 

(4) Wildlife of a size, or in numbers, capable of causing an event described in 

paragraphs (b)(1), (b)(2), or (b)(3) of this section is observed to have access to any 

airport flight pattern or aircraft movement area. 

Recent strike reports received by the Airport Safety and Certification Branch (AAS-310) 

have raised questions regarding compliance with the standards of §139.337. To
222 Policy No. 79 Review of Airport Wildlife Management Plans Appendix D 

 resolve this matter, Airport Certification Safety Inspectors shall implement the following 

procedures when notified of any of the events listed in §139.337 (b)(1-4). These 

procedures are intended to ensure that certificate holders take appropriate action in 

response to wildlife strikes/incidents and that the FAA consistently maintains records of 

actions taken. 

PROCEDURES: 

AAS-310 will review all reports of aircraft wildlife strikes. When a strike is reported that 

would initiate a Wildlife Hazard Assessment under §139.337(b)(1-4), a copy of the 

report, together with the strike history of the airport in question, will be forwarded to the 

Regional Coordinator, usually the Airport Certification Safety Inspector responsible for 

that region's wildlife hazard management issues. 

When notification is received from AAS-310, the Regional Coordinator will review the 

specific airport’s Airport Certification Manual to determine if a Wildlife Hazard 

Assessment has ever been conducted at the airport, and if the results of that study led 

to the development and implementation of an FAA approved Wildlife Hazard 

Management Plan. 

If a Wildlife Hazard Assessment has never been conducted, the Regional Coordinator 

will instruct the certificate holder to undertake the required Wildlife Hazard Assessment. 

Procedures found in Program Policy and Guidance Policy # 53, Initiation of Wildlife 

Hazard Assessments at Airports should be followed. The results of this study, together 

with other pertinent factors, will be used to determine if a Wildlife Hazard Management 

Plan is needed. 

If a Wildlife Hazard Assessment was conducted within the last 12 months, but 

development and implementation of a Wildlife Hazard Management Plan was not 

required, Regional Coordinator will review the Wildlife Hazard Assessment and the 

decision not to require development and implementation of a Wildlife Hazard 

Management Plan. In most cases, the certificate holder should be instructed to develop 

and submit for FAA approval, a Wildlife Hazard Management Plan, based on the results 

of the Wildlife Hazard Assessment. 

If the Wildlife Hazard Assessment is more than 12 months old, and no Wildlife Hazard 

Management Plan was developed, the Regional Coordinator will instruct the certificate 

holder to begin a new Wildlife Hazard Assessment. The results of this study, together 

with other pertinent factors, will be used to determine if a Wildlife Hazard Management 

Plan is needed. 

If a FAA approved Wildlife Hazard Management Plan is in place; the Plan should be 

reviewed to insure that it meets all requirements of §139.337(f). Certalert 97-09, 

Wildlife Hazard Management Plan Outline provides guidance on what should be in an 

airport’s Wildlife Hazard Management Plan. 

If the Wildlife Hazard Management Plan does not meet all requirements of §139.337(f), 

the Regional Coordinator will instruct the certificate holder to bring the Plan into 

compliance with §139.337(f). In some cases, it may be necessary for the certificate 

holder to under take a new Wildlife Hazard Assessment. 

If the Wildlife Hazard Management Plan does meet all requirements of §139.337(f), the 
Appendix D Policy No. 79 Review of Airport Wildlife Management Plans 223

Regional Coordinator will instruct the certificate holder to review the Plan and determine 

if it needs revision. This review is best conducted with the assistance of a Wildlife 

Damage Management Biologist. 

Following the review, the certificate holder must notify the FAA of the results of their 

review and any proposed corrective actions or changes to their Wildlife Hazard 

Management Plan. When approved, amendments shall be incorporated in the Airport 

Certification Manual. 

As a reminder, Airport Certification Safety Inspectors will, as part of the initial or periodic 

inspection, review an airport's Wildlife Hazard Management Plan to ensure that is meets 

all requirements of §139.337(f) 

Further, Airport Certification Safety Inspectors will also review remarks on wildlife 

hazards in the Airport Facility Directory (AFD), Notice to Airmen (NOTAM) system, or 

the Automatic Terminal Information Service (ATIS). If these remarks warn of wildlife 

hazards at or around the airport, the Airport Certification Safety Inspector will consider 

such remarks to have met the criteria of §139.337(b)(4), and therefore will require the 

certificate holder to conduct a Wildlife Hazard Assessment, if such a study has not been 

previously conducted. The results of the Wildlife Hazard Assessment will be used to 

determine if a Wildlife Hazard Management Plan is needed. 

OSB June 21, 2004 

Ben Castellano, Manager 

Airport Safety & Operations Division Date 
224 Policy No. 79 Review of Airport Wildlife Management Plans Appendix D 

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Appendix D 225

Airport Certification Program – 14 CFR Part 139 

Program Policy And Guidance 

Policy No. 82 Waste Disposal Facility Coordination 

14 CFR 139.337 September 9, 2004 

SUBJECT:

Waste Disposal Facility Coordination. 

PROCEDURES: 

CANCELLATION: 

Program Policy and Guidance Policy Number 65, Waste Disposal Facility Coordination, 

Issued October 4, 1999 is cancelled. 

PURPOSE: 

This policy establishes the procedures for coordinating and documenting Federal 

Aviation Administration (FAA) determinations on developing new or expanding existing 

waste disposal sites within 5 miles of a public-use airport. Guidance on siting various 

types of landfills is provided in FAA Advisory Circular 150/5200-33A — Hazardous 

Wildlife Attractants on or Near Airports, and FAA Advisory Circular 150/5200-34 — 

Construction Or Establishment Of Landfills Near Public Airports. 

BACKGROUND: 

The increasing pressure to develop new or expand existing waste disposal sites 

necessitates coordinating responses to ensure that the agency has a consistent 

response to these proposals. This practice has been in effect in the Great Lakes and 

Southwest Regions for several years and has worked well. 

When a landfill proponent notifies FAA under Title 40, Code of Federal Regulations, part 

258.10, of a proposal to establish a new or expand an existing landfill, the Regional 

Coordinator, usually the Airport Certification Safety Inspector (ACSI), responsible for 

waste disposal and wildlife hazards in that region will: 

Evaluate the proposal and determine whether on not it is compatible with the provisions 

of AC 150/5200 – 33A, AC 150/5200 – 34, and safe airport operations; 

Complete a copy of the attached Waste Disposal Facility Coordination Form, based on 

that determination, including any recommended permitting conditions; 

Forward the completed form, together with any supporting material to the FAA Staff 

Wildlife Biologist (AAS-300) for evaluation and coordination. 

If the potentially affected airport is a joint use facility with military aviation, a courtesy
226 Policy No. 82 Waste Disposal Facility Coordination Appendix D 

copy of the completed form, together with any supporting material should be forwarded 

to the FAA regional military liaison. 

Any disagreement between the recommendations of the Regional Coordinator and the 

Staff Wildlife Biologist will be resolved by consultation between the Region and 

Headquarters. When agreement is reached, the Staff Wildlife Biologist will sign the 

Coordination Form and return a copy to the Regional Coordinator. 

All applicable recommended permitting conditions (Section 4 of the Waste Disposal 

Facility Coordination Form) should be included in the Letter of Determination sent to the 

proponent or state agency. The completed form will be made a part of the region’s 

permanent file. 

OSB September 9, 2004 

Ben Castellano, Manager 

Airport Safety & Operations Division Date 
Appendix D Policy No. 82 Waste Disposal Facility Coordination 227

EXAMPLE WASTE DISPOSAL/PROCESSING FACILITY (WD/WP) COORDINATION FORM 

SECTION 1 – WASTE DISPOSAL/PROCESSING FACILITY (WD/WP) INFORMATION 

Site / Facility Name: File No 

Associated City / State: 

Check as appropriate 

New Site: Expand/Modify Existing Site: Re-Permit Existing Site: Other: 

Sanitary Landfill: Waste transfer Station: Demolition/Construction Debris: Recycling Center: 

Compost: Water Treatment/Oxidation: Water Detention/Retention: Other: 

Circle as appropriate 

Facility will process or store putrescible waste material outdoors:: Y - N 

Facility is within 5,000 feet of a public-use airport utilized by piston engine aircraft: Y - N 

Facility is within 10.000 feet of a public-use airport utilized by turbine engine aircraft: Y - N 

Facility is within a 5 mile radius of a public-use airport: Y - N Distance to nearest runway end (FT): 

Reported hazardous wildlife activity at airport: Y - N Reported hazardous wildlife activity at facility: Y - N 

State EPA licensing requirements: Y - N State EPA enforcement/mitigation procedures: Y - N 

USDA/WS evaluation conducted: Y - N Non-hazard: _____ Hazard: _____ (check one) 

SECTION 2 - AIRPORT INFORMATION 

Associated Public Use Airports: 

LOC ID: ATCT: Y - N Military Aviation On-Site: Y - N (If yes, notify FAA regional military liaison) 

Type Airport: GA - Com Serv Longest Runway (Ft): Instrument Runway: Y - N Jet fuel Available: Y - N 

Total Annual Operations: Piston Operations: Turbine Operations: 

SECTIONS 3 – COMPATIBILITY

Proposed wildlife attraction is considered compatible with provisions of FAA AC 150/5200-33 

Concur: Non-concur: Signature: Date: 

Supporting documentation, correspondence, site maps, etc., attached 

AAS-300 agree: Disagree: Signature: Date: 

SECTIONS 4 – CONDITIONS FOR CONCURRENCE

1 The WD/PF must be properly supervised to assure that bird populations are not increasing and that appropriate control procedures 

are being followed. 

2 Any increases in bird activity that might be hazardous to safe aircraft operations will result in prompt mitigation actions and/or closure 

of the WD/PF. 

3 Garbage shall not be handled or stored outside the WD/PF at any time, for any reason, or in a partially enclosed vehicle/structure that 

is accessible to birds or other wildlife. 

4 The WD/PF shall be totally enclosed and shall be operated without any outward indications that waste disposal operations are 

underway indoors. 

5 Only non-putrescible demolition/construction waste material will be accepted in the WD/PF. 

6 Only composting materials shall be accepted in the referenced WD/PF. No other putrescible materials shall be accepted. 

7 The above checked conditions must be clearly defined via state/local licensing procedures associated with establishment of the 

WD/PF. 

SECTIONS 5 – COMMENTS
228 Policy No. 82 Waste Disposal Facility Coordination Appendix D 

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 229

APPENDIX E: 

FAA, Office Of Airport Safety And Standards, 

Certalerts
230 Appendix E 

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Appendix E 231

C E R T A L E R T 

No. 98-05: Grasses Attractive To Hazardous Wildlife 

ADVISORY CAUTIONARY NON-DIRECTIVE 

FOR INFORMATION, CONTACT AIRPORT WILDLIFE SPECIALIST, 

 AAS-317 (202) 267.3389 

DATE: September, 18, 1998 No. 98-05

TO: Airport Operators, 

FAA Airport Certification Safety Inspectors 

TOPIC: Grasses Attractive to Hazardous Wildlife 

Recently, several reports have been received of airport owners or airport contractors 

planting disturbed areas (construction sites, re-grading projects, etc) with seed mixtures 

containing brown-top millet. All millets are a major attractant to doves and other seed 

eating birds. 

Doves can be a major threat to aircraft safety. In the United States, between 1991 and 

1997, doves were involved in 11% of all reported bird/aircraft strikes, 8% of the reported 

strikes that resulted in aircraft down time, and 8% of the reported strikes causing aircraft 

damage or other associated monetary losses. 

September 18, 1998

Airport operators should ensure that grass species and other varieties of plants 

attractive to hazardous wildlife are not used on the airport. Disturbed areas or areas in 

need of re-vegetating should not be planted with seed mixtures containing millet or any 

other large-seed producing grass. 

For airport property already planted with seed mixtures containing millet or other largeseed producing grasses, it is recommended that disking, plowing, or other suitable 

agricultural practice be employed to prevent plant maturation and seed head production. 

For specific recommendations on grass management and seed selection, contact the 

State University Cooperative Extension Service, or the local office of the USDA, Wildlife 

Services. 

OSB

Ben Castellano, Manager 

Airport Safety & Operations Division Date
232 No. 98-05 Grasses Attractive to Hazardous Wildlife Appendix E 

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Appendix E 233

C E R T A L E R T 

No. 04-09: Relationship Between FAA And WS 

ADVISORY CAUTIONARY NON-DIRECTIVE 

FOR INFORMATION, CONTACT AIRPORT WILDLIFE SPECIALIST, 

 AAS-317 (202) 267.3389 

DATE: August 30, 2004 No. 04-09

TO: Airport Certification Program Inspectors 

TOPIC: Relationship Between FAA And WS 

CANCELLATION:

Certalert 97-02, Relationship Between FAA And WS, Dated April 25, 1997, is cancelled. 

PURPOSE: 

This Certalert clarifies the roles of, and relationship between the Federal Aviation 

Administration (FAA) and the United States Department of Agriculture/Animal and Plant 

Health Inspection Service/Wildlife Services (WS) with regards to wildlife hazards on or 

near airports. 

FEDERAL AVIATION ADMINISTRATION

The FAA issues airport operating certificates for airports serving certain air carrier 

aircraft under Title 14, Code of Federal Regulations, Part 139. Section 139.337 

requires certificated airports having a wildlife hazard problem to develop and implement 

a Wildlife Hazard Management Plan to manage and control wildlife, which present a risk 

to public safety, caused by aircraft collisions with wildlife. The FAA relies heavily on the 

assistance of WS to review and contribute to such plans. 

ANIMAL DAMAGE CONTROL

The Animal Damage Control Act of March 2, 1931, (7 USC 426-426c, as amended), 

charges the Secretary of Agriculture with management of wildlife injurious to agricultural 

interests, other wildlife, or human health and safety. Further, the Secretary is 

authorized to cooperate with States, individuals, public and private agencies, 

organizations, and institutions in the control of nuisance mammals and birds, including 

wildlife hazards to aviation. Because of the experience, training, and background of its 

personnel, WS is recognized throughout the world as an expert in dealing with wildlife 

damage management issues. WS has an active presence in all U.S. states and 

territories. 

MEMORANDUM OF UNDERSTANDING 

A Memorandum of Understanding (MOU) between the FAA and WS (No. 12-4-71-0003-

MOU) establishes a cooperative relationship between these agencies for resolving 

wildlife hazards to aviation. 
234 No. 04-09 Relationship Between FAA and WS Appendix E 

AGENCY FUNDING

Both agencies are funded by congressional appropriations. The majority of funding for 

the FAA comes from the Aviation Trust Fund with the remainder coming from the 

general funds of the U.S. Treasury. Any revenues generated by the FAA are returned 

to the U.S. Treasury. WS receives a limited amount of funds from the general fund of 

the U.S. Treasury that allows it to perform some services for the public good. However, 

WS’s funding is also based upon its ability to enter into contracts to provide services 

and receive reimbursement for the cost of the services. Legislation allows WS to collect 

this money and return it to the program rather than the general funds of the U.S. 

Treasury. Consequently, WS may enter into a cooperative service agreement with an 

airport operator for reimbursement of services to perform a wildlife hazard assessment 

on an airport. 

WILDLIFE HAZARD MANAGEMENT

14 CFR 139.337(b) requires the certificate holder conduct a wildlife hazard assessment, 

acceptable to the FAA Administrator, when any of the following events occur on or near 

the airport: 

(b) (1) An air carrier aircraft experiences multiple wildlife strikes: 

(b) (2) An air carrier aircraft experiences substantial damage from striking wildlife. As 

used in this paragraph, substantial damage means damage or structural failure incurred 

by an aircraft that adversely affects the structural strength, performance, or flight 

characteristics of the aircraft and that would normally require major repair or 

replacement of the affected component; 

(b) (3) An air carrier aircraft experiences an engine ingestion of wildlife; or 

(b) (4) Wildlife of a size, or in numbers, capable of causing an event described in 

paragraph (b)(1), (2), or (3) of this section is observed to have access to any airport 

flight pattern or aircraft movement area. 

The wildlife hazard assessment shall contain at least the following (14CFR 139.337(c)): 

(c) (l) An analysis of the events or circumstances that prompted the assessment. 

(c) (2) Identification of the wildlife species observed and their numbers, locations, local 

movements, and daily and seasonal occurrences. 

(c) (3) Identification and location of features on and near the airport that attract wildlife. 

(c) (4) A description of wildlife hazards to air carrier operations. 

(c) (5) Recommended actions for reducing identified wildlife hazards to air carrier 

operations. 

The certificate holder may look to WS or to private consultants to conduct the required 

wildlife hazard assessment. The FAA uses the wildlife hazard assessment in 

determining if a wildlife hazard management plan is needed for the airport. Therefore, 

persons having the education, training, and experience necessary to adequately assess 

any wildlife hazards should conduct the assessment. 

Depending on the availability of resources, WS may conduct a preliminary hazard 
Appendix E No. 04-09 Relationship Between FAA and WS 235

assessment at no charge to the certificate holder. The certificate holder should 

determine in advance if WS will charge to conduct the preliminary hazard assessment. 

More detailed assessments may require the certificate holder to enter into a cooperative 

service agreement with WS. 

OSB August 30, 2004 

Ben Castellano, Manager 

Airport Safety & Operations Division Date 
236 No. 04-09 Relationship Between FAA and WS Appendix E 

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Appendix E 237

C E R T A L E R T 

No. 04-16: Deer Hazard to Aircraft and Deer Fencing 

ADVISORY CAUTIONARY NON-DIRECTIVE 

FOR INFORMATION, CONTACT AIRPORT WILDLIFE SPECIALIST, 

 AAS-317 (202) 267.3389 

DATE: December 13, 2004 No. 04-16

TO: Airport Operators, FAA Airport Certification Program Inspectors 

TOPIC: Deer Hazard to Aircraft and Deer Fencing 

CANCELLATION: 

Certalert 01-01. Deer Aircraft Hazard, dated February 1, 2001; and Certalert 02-09. 

Alternative Deer Fencing, dated December 12, 2002, are cancelled. 

BACKGROUND

Elevated deer populations in the United States represent an increasingly serious threat 

to both Commercial and General Aviation Aircraft. It is currently estimated that there 

over 26 million deer in the United States. Because of increasing urbanization and 

rapidly expanding deer populations, deer are adapting to human environments, 

especially around airports, where they often find food and shelter. From 1990 to 2004, 

over 650 deer-aircraft collisions were reported to the Federal Aviation Administration 

(FAA). Of these reports, over 500 indicated the aircraft was damaged as a result of the 

collision. 

In light of recent incidents where a Learjet landing at an airport in Alabama and a 

Learjet departing an airport in Oregon were destroyed after colliding with deer or elk, 

airport operators are reminded of the importance of controlling deer and other wild 

ungulates on and around airfields. 

PURPOSE

Proper fencing is the best way of keeping deer off aircraft movement areas. The FAA 

recommends a 10-12 foot chain link fence with 3-strand barbed wire outriggers. In 

some cases an airport may be able to use an 8-foot chain link fence with 3-strand 

barbed outriggers, depending upon the amount of deer activity in a local area.

All fencing must be properly installed and maintained. A 4-foot skirt of chain-link fence 

material, attached to the bottom of the fence and buried at a 45o

 angle on the outside of 

the fence will prevent animals from digging under the fence and reduce the chance of 

washouts. This type of fencing also greatly increases airport security and safety. The 

fence line right-of-way must be kept free of excess vegetation. The fence line should be 

patrolled at least daily, and any washouts, breaks or other holes in the fence repaired as 

soon as they are discovered.
238 No. 04-16 Deer Hazard to Aircraft and Deer Fencing Appendix E 

Gates should close with less than 6-inch gaps to prevent entry by deer. 

When installation of chain link fencing is not feasible due to cost or environmental 

impacts, other types of fencing may be installed. (Cost alone is not an acceptable 

reason for rejecting the use of chain link fencing.) In some cases, electric fencing may 

offer a suitable alternative. Recent improvements in fencing components and design 

have greatly increased the effectiveness and ease of installation of electric fences. 

Tests by the USDA, National Wildlife Research Center have shown that some 4 to 6-

foot, 5 to 9-strand electric fences designs can be 99% effective at stopping deer. 

Installation of some of the newer electric fences requires neither specialized equipment 

nor training and can be accomplished by airport personnel. 

In limited situations, the use of non-conductive, composite, frangible electric fence posts 

and fence conductors may allow the installation of electric fence closer to the aircraft 

movement area than would normally be allowed with standard chain link fencing 

material. 

If deer are observed on or near the aircraft movement area, immediate action must be 

taken to remove them. 

Airport operators can contact the nearest USDA, Wildlife Services Office or the State 

Wildlife Management Agency for assistance with deer problems. 

OSB December 13, 2004 

Ben Castellano 

Manager Airport Safety & Operations 

Division 

Date 

 
 239

APPENDIX F: 

USDA, Wildlife Services Directive 2.305 

Wildlife Hazards To Aviation 
 240 Appendix F 

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Appendix F 241

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Wildlife Services 

Directive 2.305 4/15/98 

Wildlife Hazards To Aviation 

1. PURPOSE

To provide general guidelines for Wildlife Services (WS) technical and/or direct control 

assistance to airport managers, State aviation agencies, aviation industry, Federal 

Aviation Administration (FAA), and Department of Defense regarding hazards caused 

by wildlife to airport safety. 

2. REPLACEMENT HIGHLIGHTS

This directive replaces ADC Directive 2.305 dated 04/05/95. 

3. POLICY

WS will assist responsible Federal and State agencies, airport managers, and the 

aviation industry in reducing wildlife hazards to airports and air bases according to the 

APHIS/ADC [WS] Memorandum of Understanding with the FAA and the guidelines set 

forth in the WS Managing Wildlife Hazards at Airports Manual. 

WS may enter into cooperative agreements to conduct wildlife hazard assessments 

and/or management plans for an airport or air base or to conduct direct control and/or 

technical assistance activities to minimize hazards caused by wildlife. These activities 

will be conducted under cooperative agreements fully funded by cooperating entities. 

WS personnel may also provide specific training for airport and air base personnel in 

wildlife identification and the safe and proper use of wildlife damage management 

equipment and techniques. WS personnel will provide recommendations and assistance 

to airport managers and air base commanders in obtaining necessary Federal and State 

permits required to take protected wildlife species at airports and air bases. 

Whenever WS personnel observe existing or potential wildlife hazards at airports or air 

bases, appropriate aviation authorities will be notified immediately. 

4. REFERENCES

ADC Directive 2.620, ADC Aviation Safety and Operations 

WS Managing Wildlife Hazards at Airports Manual 

Memorandum of Understanding between APHIS and FAA (3/21/89) 

14 CFR Part 139.337 Wildlife Hazard Management 

 

Deputy Administrator 
242 WS Directive 2.305 Appendix F 

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 243

APPENDIX G: 

Memorandum Of Understanding 

Between 

United States Department Of Transportation, 

Federal Aviation Administration 

And 

United States Department Of Agriculture, 

Animal And Plant Health Inspection Service, 

Wildlife Services. 

(No. 12-34-71-0003-MOU) 
 244 Appendix G 

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Appendix G MOU Between FAA and WS 245

No. 12-34-71-0003-MOU 

Memorandum of Understanding 

between the 

United States Department of Transportation 

ARTICLE 1 

The WS has the authority to enter agreements with States, local jurisdictions, 

individuals, public and private agencies, organizations, and institutions for the control of 

nuisance wildlife2

. The WS also has the authority to charge for services provided under 

such agreements and to deposit the funds collected into the accounts that incur the 

costs3

. 

 

Federal Aviation Administration 

and the 

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Wildlife Services 

This Memorandum of Understanding (MOU) continues the cooperation between the 

Federal Aviation Administration and Wildlife Services (WS) for mitigating wildlife 

hazards to aviation. 

ARTICLE 2

The FAA has the broad authority to regulate and develop civil aviation in the 

United States1

. The FAA may issue Airport Operating Certificates to airports serving 

certain air carrier aircraft. Issuance of an Airport Operating Certificate indicates that the 

airport meets the requirements of Title 14, Code of Federal Regulations, part 139 (14 

CFR 139) for conducting certain air carrier operations.

14 CFR 139.337 requires the holder of an Airport Operating Certificate (certificate 

holder) to conduct a wildlife hazard assessment (WHA) when specific events occur on 

or near the airport. A wildlife management biologist who has professional training 

1

 Federal Aviation Act of 1958, 49 U.S.C. § 40101, et. seq. 

2

 The Animal Damage Control Act of March 2, 1931, as amended, 46 Stat. 1468; 7 

U.S.C. 426 – 426b. 

3

 The Rural Development, Agriculture, and Related Agencies Appropriations Act of 

1988, as amended, 426c to U.S.C. 426 – 426b. 
246 MOU Between FAA and WS Appendix G 

and/or experience in wildlife hazard management at airports, or someone working 

under the direct supervision of such an individual, must conduct the WHA required by 

14 CFR 139.337. The FAA reviews all WHAs to determine if the certificate holder must 

develop and implement a wildlife hazard management plan (WHMP) designed to 

mitigate wildlife hazards to aviation on or near the airport. These regulations also 

require airport personnel implementing an FAA-approved WHMP to receive training 

conducted by a qualified wildlife damage management biologist. 

ARTICLE 3 

The FAA and the WS agree to the following. 

d. The FAA or the certificate holder may seek technical support from WS to 

lessen wildlife hazards. This help may include, but is not limited to, 

conducting site visits and WHAs to identify hazardous wildlife, their daily and 

seasonal movement patterns and habitat requirements. WS personnel may 

also provide: 

a. The WS has the professional expertise, airport experience, and training to 

provide support to assess and reduce wildlife hazards to aviation on and near 

airports. The WS can also provide the necessary training to airport personnel. 

b. Most airports lack the technical expertise to identify underlying causes of 

wildlife hazard problems. They can control many of their wildlife problems 

following proper instruction in control techniques and wildlife species 

identification from qualified wildlife management biologists. 

c. Situations arise where control of hazardous wildlife is necessary on and off 

airport property (i.e., roost relocations, reductions in nesting populations, and 

removal of wildlife). This often requires the specialized technical support of 

WS personnel. 

i. support with developing WHMPs including recommendations on control 

and habitat management methods designed to minimize the presence 

of hazardous wildlife on or near the airport; 

ii. training in wildlife species identification and the use of control devices; 

iii. support with managing hazardous wildlife and associated habitats; and 

iv. recommendations on the scope of further studies necessary to identify 

and minimize wildlife hazards. 

e. Unless specifically requested by the certificate holder, WS is not liable or 

responsible for development, approval, or implementation of a WHMP 

required by 14 CFR 139.337. Development of a WHMP is the responsibility 

of the certificate holder. The certificate holder will use the information 

developed by WS from site visits and/or conducting WHA in the preparation 

of a WHMP. 

f. The FAA and WS agree to meet at least yearly to review this agreement, 

identify problems, exchange information on new control methods, identify 

research needs, and prioritize program needs. 
Appendix G MOU Between FAA and WS 247

ARTICLE 4 

The WS personnel will advise the certificate holder of their responsibilities to secure 

necessary permits and/or licenses for control of wildlife. This will ensure all wildlife 

damage control activities are conducted under applicable Federal, State, and local 

laws and regulations. 

ARTICLE 5 

This MOU defines in general terms, the basis on which the parties will cooperate and 

does not constitute a financial obligation to serve as a basis for expenditures. Request 

for technical, operational, or research assistance that requires cooperative or 

reimbursable funding will be completed under a separate agreement. 

ARTICLE 6 

This MOU will supersede all existing MOUs, supplements, and amendments about the 

conduct of wildlife hazard control programs between WS and the FAA. 

ARTICLE 7 

Under Section 22, Title 41, U.S.C., no member of or delegate to Congress will be 

admitted to any share or part of this MOU or to any benefit to arise from it. 

ARTICLE 8 

This MOU will become effective on the date of final signature and will continue 

indefinitely. This MOU may be amended by agreement of the parties in writing. Either 

party, on 60 days advance written notice to the other party, may end the agreement. 

___ OSB Woodie Woodward ___ 

Associate Administrator for Airports 

Federal Aviation Administration 

Date _____ June 20, 2005 ______ 

___ OSB William H Clay ___ 

Deputy Administrator for Wildlife Services 

Animal and Plant Health Inspection Service 

Date _____ June 27, 2005 _____ 
248 MOU Between FAA and WS Appendix G 

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Appendix H 249

APPENDIX H: 

Memorandum of Agreement Between 

the Federal Aviation Administration, 

the U.S. Air Force, 

the U.S. Army, 

the U.S. Environmental Protection Agency, 

the U.S. Fish and Wildlife Service, and 

the U.S. Department of Agriculture 

to Address Aircraft-Wildlife Strikes 
 250 Appendix H 

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Appendix H 251

Memorandum of Agreement Between 

the Federal Aviation Administration, 

the U.S. Air Force, 

the U.S. Army, 

the U.S. Environmental Protection Agency, 

the U.S. Fish and Wildlife Service, and 

the U.S. Department of Agriculture 

to Address Aircraft-Wildlife Strikes 

PURPOSE

The signatory agencies know the risks that aircraft-wildlife strikes pose to safe aviation. 

This Memorandum of Agreement (MOA) acknowledges each signatory agency’s 

respective missions. Through this MOA, the agencies establish procedures necessary 

to coordinate their missions to more effectively address existing and future 

environmental conditions contributing to aircraft-wildlife strikes throughout the United 

States. These efforts are intended to minimize wildlife risks to aviation and human 

safety, while protecting the Nation’s valuable environmental resources. 

BACKGROUND

 

Aircraft-wildlife strikes are the second leading causes of aviation-related fatalities. 

Globally, these strikes have killed over 400 people and destroyed more than 420 

aircraft. While these extreme events are rare when compared to the millions of annual 

aircraft operations, the potential for catastrophic loss of human life resulting from one 

incident is substantial. The most recent accident demonstrating the grievous nature of 

these strikes occurred in September 1995, when a U.S. Air Force reconnaissance jet 

struck a flock of Canada geese during takeoff, killing all 24 people aboard.

The Federal Aviation Administration (FAA) and the United States Air Force (USAF) 

databases contain information on more than 54,000 United States civilian and military 

aircraft-wildlife strikes reported to them between 1990 and 19991

. During that decade, 

the FAA received reports indicating that aircraft-wildlife strikes, damaged 4,500 civilian 

U.S. aircraft (1,500 substantially), destroyed 19 aircraft, injured 91 people, and killed 6 

people. Additionally, there were 216 incidents where birds struck two or more engines 

on civilian aircraft, with damage occurring to 26 percent of the 449 engines involved in 

these incidents. The FAA estimates that during the same decade, civilian U.S. aircraft 

sustained $4 billion worth of damages and associated losses and 4.7 million hours of 

aircraft downtime due to aircraft-wildlife strikes. For the same period, USAF planes 

colliding with wildlife resulted in 10 Class A Mishaps2

, 26 airmen deaths, and over $217 

million in damages.

1

 FAA estimates that the 28,150 aircraft-wildlife strike reports it received represent less than 20% of the 

actual number of strikes that occurred during the decade. 

2

 See glossary for the definition of a Class A Mishap and similar terms. 
252 Multi Agency MOA Appendix H 

Approximately 97 percent of the reported civilian aircraft-wildlife strikes involved 

common, large-bodied birds or large flocks of small birds. Almost 70 percent of these 

events involved gulls, waterfowl, and raptors (Table 1). 

About 90 percent of aircraft-wildlife strikes occur on or near airports, when aircraft are 

below altitudes of 2,000 feet. Aircraft-wildlife strikes at these elevations are especially 

dangerous because aircraft are moving at high speeds and are close to or on the 

ground. Aircrews are intently focused on complex take-off or landing procedures and 

monitoring the movements of other aircraft in the airport vicinity. Aircrew attention to 

these activities while at low altitudes often compromises their ability to successfully 

recover from unexpected collisions with wildlife and to deal with rapidly changing flight 

procedures. As a result, crews have minimal time and space to recover from aircraftwildlife strikes. 

Increasing bird and wildlife populations in urban and suburban areas near airports 

contribute to escalating aircraft-wildlife strike rates. FAA, USAF, and Wildlife Services 

(WS) experts expect the risks, frequencies, and potential severities of aircraft-wildlife 

strikes to increase during the next decade as the numbers of civilian and military aircraft 

operations grow to meet expanding transportation and military demands. 

SECTION I. 

SCOPE OF COOPERATION AND COORDINATION

Based on the preceding information and to achieve this MOA’s purpose, the signatory 

agencies: 

Agree to strongly encourage their respective regional and local offices, as appropriate, 

to develop interagency coordination procedures necessary to effectively and efficiently 

implement this MOA. Local procedures should clarify time frames and other general 

coordination guidelines. 

Agree that the term “airport” applies only to those facilities as defined in the attached 

glossary. 

Agree that the three major activities of most concern include, but are not limited to: 

1. airport siting and expansion; 

2. development of conservation/mitigation habitats or other land uses that could attract 

hazardous wildlife to airports or nearby areas; and 

3. responses to known wildlife hazards or aircraft-wildlife strikes. 

Agree that “hazardous wildlife” are those animals, identified to species and listed in FAA 

and USAF databases, that are most often involved in aircraft-wildlife strikes. Many of 

the species frequently inhabit areas on or near airports, cause structural damage to 

airport facilities, or attract other wildlife that pose an aircraft-wildlife strike hazard. Table 

1 lists many of these species. It is included solely to provide information on identified 

wildlife species that have been involved in aircraft-wildlife strikes. It is not intended to 

represent the universe of species concerning the signatory agencies, since more than 

50 percent of the aircraft-wildlife strikes reported to FAA or the USAF did not identify the 

species involved. 

Agree to focus on habitats attractive to the species noted in Table 1, but the signatory 

agencies realize that it is imperative to recognize that wildlife hazard determinations 
Appendix H Multi Agency MOA 253

discussed in Paragraph L of this section may involve other animals. 

Agree that not all habitat types attract hazardous wildlife. The signatory agencies, 

during their consultative or decision making activities, will inform regional and local land 

use authorities of this MOA’s purpose. The signatory agencies will consider regional, 

local, and site-specific factors (e.g., geographic setting and/or ecological concerns) 

when conducting these activities and will work cooperatively with the authorities as they 

develop and implement local land use programs under their respective jurisdictions. 

The signatory agencies will encourage these stakeholders to develop land uses within 

the siting criteria noted in Section 1-3 of FAA Advisory Circular (AC) 150.5200-33 

(Attachment A) that do not attract hazardous wildlife. Conversely, the agencies will 

promote the establishment of land uses attractive to hazardous wildlife outside those 

siting criteria. Exceptions to the above siting criteria, as described in Section 2.4.b of 

the AC, will be considered because they typically involve habitats that provide unique 

ecological functions or values (e.g., critical habitat for federally-listed endangered or 

threatened species, ground water recharge). 

Agree that wetlands provide many important ecological functions and values, including 

fish and wildlife habitats; flood protection; shoreline erosion control; water quality 

improvement; and recreational, educational, and research opportunities. To protect 

jurisdictional wetlands, Section 404 of the Clean Water Act (CWA) establishes a 

program to regulate dredge and/or fill activities in these wetlands and navigable waters. 

In recognizing Section 404 requirements and the Clean Water Action Plan’s goal to 

annually increase the Nation’s net wetland acreage by 100,000 acres through 2005, the 

signatory agencies agree to resolve aircraft-wildlife conflicts. They will do so by 

avoiding and minimizing wetland impacts to the maximum extent practicable, and will 

work to compensate for all associated unavoidable wetland impacts. The agencies 

agree to work with landowners and communities to encourage and support wetland 

restoration or enhancement efforts that do not increase aircraft-wildlife strike potentials. 

Agree that the: U.S. Army Corps of Engineers (ACOE) has expertise in protecting and 

managing jurisdictional wetlands and their associated wildlife; U.S. Environmental 

Protection Agency (EPA) has expertise in protecting environmental resources; and the 

U.S. Fish and Wildlife Service (USFWS) has expertise in protecting and managing 

wildlife and their habitats, including migratory birds and wetlands. Appropriate signatory 

agencies will cooperatively review proposals to develop or expand wetland mitigation 

sites, or wildlife refuges that may attract hazardous wildlife. When planning these sites 

or refuges, the signatory agencies will diligently consider the siting criteria and land use 

practice recommendations stated in FAA AC 150/5200-33. The agencies will make 

every effort to undertake actions that are consistent with those criteria and 

recommendations, but recognize that exceptions to the siting criteria may be 

appropriate (see Paragraph F of this section). 

Agree to consult with airport proponents during initial airport planning efforts. As 

appropriate, the FAA or USAF will initiate signatory agency participation in these efforts. 

When evaluating proposals to build new civilian or military aviation facilities or to expand 

existing ones, the FAA or the USAF, will work with appropriate signatory agencies to 

diligently evaluate alternatives that may avoid adverse effects on wetlands, other 

aquatic resources, and Federal wildlife refuges. If these or other habitats support 
254 Multi Agency MOA Appendix H 

hazardous wildlife, and there is no practicable alternative location for the proposed 

aviation project, the appropriate signatory agencies, consistent with applicable laws, 

regulations, and policies, will develop mutually acceptable measures, to protect aviation 

safety and mitigate any unavoidable wildlife impacts. 

Agree that a variety of other land uses (e.g., storm water management facilities, 

wastewater treatment systems, landfills, golf courses, parks, agricultural or aquacultural 

facilities, and landscapes) attract hazardous wildlife and are, therefore, normally 

incompatible with airports. Accordingly, new, federally-funded airport construction or 

airport expansion projects near habitats or other land uses that may attract hazardous 

wildlife must conform to the siting criteria established in the FAA Advisory Circular (AC) 

150/5200-33, Section 1-3. 

Agree to encourage and advise owners and/or operators of non-airport facilities that are 

known hazardous wildlife attractants (See Paragraph J) to follow the siting criteria in 

Section 1-3 of AC 150/5200-33. As appropriate, each signatory agency will inform 

proponents of these or other land uses about the land use’s potential to attract 

hazardous species to airport areas. The signatory agencies will urge facility owners 

and/or operators about the critical need to consider the land uses’ effects on aviation 

safety. 

Agree that FAA, USAF, and WS personnel have the expertise necessary to determine 

the aircraft-wildlife strike potentials of various land uses. When there is disagreement 

among signatory agencies about a particular land use and its potential to attract 

hazardous wildlife, the FAA, USAF, or WS will prepare a wildlife hazard assessment. 

Then, the appropriate signatory agencies will meet at the local level to review the 

assessment. At a minimum, that assessment will: 

identify each species causing the aviation hazard, its seasonal and daily populations, 

and the population’s local movements; 

discuss locations and features on and near the airport or land use attractive to 

hazardous wildlife; and 

evaluate the extent of the wildlife hazard to aviation. 

Agree to cooperate with the airport operator to develop a specific, wildlife hazard 

management plan for a given location, when a potential wildlife hazard is identified. The 

plan will meet applicable FAA, USAF, and other relevant requirements. In developing 

the plan, the appropriate agencies will use their expertise and attempt to integrate their 

respective programmatic responsibilities, while complying with existing laws, 

regulations, and policies. The plan should avoid adverse impacts to wildlife populations, 

wetlands, or other sensitive habitats to the maximum extent practical. Unavoidable 

impacts resulting from implementing the plan will be fully compensated pursuant to all 

applicable Federal laws, regulations, and policies. 

Agree that whenever a significant aircraft-wildlife strike occurs or a potential for one is 

identified, any signatory agency may initiate actions with other appropriate signatory 

agencies to evaluate the situation and develop mutually acceptable solutions to reduce 

the identified strike probability. The agencies will work cooperatively, preferably at the 

local level, to determine the causes of the strike and what can and should be done at 

the airport or in its vicinity to reduce potential strikes involving that species. 
Appendix H Multi Agency MOA 255

Agree that information and analyses relating to mitigation that could cause or contribute 

to aircraft-wildlife strikes should, whenever possible, be included in documents prepared 

to satisfy the National Environmental Policy Act (NEPA). This should be done in 

coordination with appropriate signatory agencies to inform the public and Federal 

decision makers about important ecological factors that may affect aviation. This 

concurrent review of environmental issues will promote the streamlining of the NEPA 

review process. 

Agree to cooperatively develop mutually acceptable and consistent guidance, manuals, 

or procedures addressing the management of habitats attractive to hazardous wildlife, 

when those habitats are or will be within the siting criteria noted in Section 1-3 of FAA 

AC 5200-33. As appropriate, the signatory agencies will also consult each other when 

they propose revisions to any regulations or guidance relevant to the purpose of this 

MOA, and agree to modify this MOA accordingly. 

SECTION II. 

GENERAL RULES AND INFORMATION

Development of this MOA fulfills the National Transportation Safety Board’s 

recommendation of November 19, 1999, to form an inter-departmental task force to 

address aircraft-wildlife strike issues. 

This MOA does not nullify any obligations of the signatory agencies to enter into 

separate MOAs with the USFWS addressing the conservation of migratory birds, as 

outlined in Executive Order 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds, dated January 10, 2001 (66 Federal Register, No. 11, pg. 3853). 

This MOA in no way restricts a signatory agency’s participation in similar activities or 

arrangements with other public or private agencies, organizations, or individuals. 

This MOA does not alter or modify compliance with any Federal law, regulation or 

guidance (e.g., Clean Water Act; Endangered Species Act; Migratory Bird Treaty Act; 

National Environmental Policy Act; North American Wetlands Conservation Act; Safe 

Drinking Water Act; or the “no-net loss” policy for wetland protection). The signatory 

agencies will employ this MOA in concert with the Federal guidance addressing wetland 

mitigation banking dated March 6, 1995 (60 Federal Register, No. 43, pg. 12286). 

The statutory provisions and regulations mentioned above contain legally binding 

requirements. However, this MOA does not substitute for those provisions or 

regulations, nor is it a regulation itself. This MOA does not impose legally binding 

requirements on the signatory agencies or any other party, and may not apply to a 

particular situation in certain circumstances. The signatory agencies retain the 

discretion to adopt approaches on a case-by-case basis that differ from this MOA when 

they determine it is appropriate to do so. Such decisions will be based on the facts of a 

particular case and applicable legal requirements. Therefore, interested parties are free 

to raise questions and objections about the substance of this MOA and the 

appropriateness of its application to a particular situation. 

This MOA is based on evolving information and may be revised periodically without 

public notice. The signatory agencies welcome public comments on this MOA at any 

time and will consider those comments in any future revision of this MOA. 

This MOA is intended to improve the internal management of the Executive Branch to 
256 Multi Agency MOA Appendix H 

address conflicts between aviation safety and wildlife. This MOA does not create any 

right, benefit, or trust responsibility, either substantively or procedurally. No party, by 

law or equity, may enforce this MOA against the United States, its agencies, its officers, 

or any person. 

This MOA does not obligate any signatory agency to allocate or spend appropriations or 

enter into any contract or other obligations. 

This MOA does not reduce or affect the authority of Federal, State, or local agencies 

regarding land uses under their respective purviews. When requested, the signatory 

agencies will provide technical expertise to agencies making decisions regarding land 

uses within the siting criteria in Section 1-3 of FAA AC 150/5200-33 to minimize or 

prevent attracting hazardous wildlife to airport areas. 

Any signatory agency may request changes to this MOA by submitting a written request 

to any other signatory agency and subsequently obtaining the written concurrence of all 

signatory agencies. 

Any signatory agency may terminate its participation in this MOA within 60 days of 

providing written notice to the other agencies. This MOA will remain in effect until all 

signatory agencies terminate their participation in it. 
Appendix H Multi Agency MOA 257

SECTION III. PRINCIPAL SIGNATORY AGENCY CONTACTS

The following list identifies contact offices for each signatory agency. 

Federal Aviation Administration U.S. Air Force 

Office Airport Safety and Standards HQ AFSC/SEFW 

Airport Safety and Compliance Branch 

(AAS-310) 

9700 Ave., G. SE, Bldg. 24499 

800 Independence Ave., S.W. Kirtland AFB, NM 87117 

Washington, D.C. 20591 V: 505-846-5679 

V: 202-267-1799 F: 505-846-0684 

F: 202-267-7546 

U.S. Army U.S. Environmental Protection Agency. 

Directorate of Civil Works Office of Water 

Regulatory Branch (CECW-OR) Wetlands Division 

441 G St., N.W. Ariel Rios Building, MC 4502F 

Washington, D.C. 20314 1200 Pennsylvania Ave., SW 

V: 202-761-4750 Washington, D.C. 20460 

F: 202-761-4150 V: 202-260-1799 

F: 202-260-7546

U.S. Fish and Wildlife Service U.S. Department of Agriculture 

Division of Migratory Bird Management Animal and Plant Inspection Service 

4401 North Fairfax Drive, Room 634 Wildlife Services 

Arlington, VA 22203 Operational Support Staff 

V: 703-358-1714 4700 River Road, Unit 87 

F: 703-358-2272 Riverdale, MD 20737 

V: 301-734-7921 

F: 301-734-5157 
258 Multi Agency MOA Appendix H 

Signature Page 

Associate Administrator for Airports 

Federal Aviation Administration Date 

Chief of Safety, 

U. S. Air Force Date 

Assistant Secretary of the Army (Civil Works), 

U.S. Army Date 

Assistant Administrator, Office of Water, 

U.S. Environmental Protection Agency Date 

Assistant Director, Migratory Birds and State 

Programs, 

U.S. Fish and Wildlife Service 

Date 

Deputy Administrator, Wildlife Services 

U.S. Department of Agriculture Date 
Appendix H Multi Agency MOA 259

GLOSSARY

Aircraft-wildlife strike. An aircraft-wildlife strike is deemed to have occurred when: 

3. personnel on the ground report seeing an aircraft strike 1 or more birds or other 

wildlife; 

This glossary defines terms used in this MOA. 

Airport. All USAF airfields or all public use airports in the FAA’s National Plan of 

Integrated Airport Systems (NPIAS). Note: There are over 18,000 civil-use airports in 

the U.S., but only 3,344 of them are in the NPIAS and, therefore, under FAA’s 

jurisdiction. 

1. a pilot reports that an aircraft struck 1 or more birds or other wildlife; 

2. aircraft maintenance personnel identify aircraft damage as having been caused by 

an aircraft-wildlife strike; 

4. bird or other wildlife remains, whether in whole or in part, are found within 200 feet of 

a runway centerline, unless another reason for the animal's death is identified; or 

5. the animal's presence on the airport had a significant, negative effect on a flight (i.e., 

aborted takeoff, aborted landing, high-speed emergency stop, aircraft left pavement 

area to avoid collision with animal) 

(Source: Wildlife Control Procedures Manual, Technical Publication 11500E, 1994). 

Aircraft-wildlife strike hazard. A potential for a damaging aircraft collision with wildlife 

on or near an airport (14 CFR 139.3). 

Bird Sizes. Title 40, Code of Federal Regulations, Part 33.76 classifies birds according 

to weight: 

1. small birds weigh less than 3 ounces (oz). 

2. medium birds weigh more than 3 oz and less than 2.5 lbs. 

3. large birds weigh greater than 2.5 lbs. 

Civil aircraft damage classifications. The following damage descriptions are based 

on the Manual on the International Civil Aviation Organization Bird Strike Information 

System: 

1. Minor: The aircraft is deemed airworthy upon completing simple repairs or replacing 

minor parts and an extensive inspection is not necessary. 

2. Substantial: Damage or structural failure adversely affects an aircraft’s structural 

integrity, performance, or flight characteristics. The damage normally requires major 

repairs or the replacement of the entire affected component. Bent fairings or 

cowlings; small dents; skin punctures; damage to wing tips, antenna, tires or brakes, 

or engine blade damage not requiring blade replacement are specifically excluded. 

3. Destroyed: The damage sustained makes it inadvisable to restore the aircraft to an 

airworthy condition. 

Significant Aircraft-Wildlife Strikes. A significant aircraft-wildlife strike is deemed to 
260 Multi Agency MOA Appendix H 

have occurred when any of the following applies: 

1. a civilian, U.S. air carrier aircraft experiences a multiple aircraft-bird strike or engine 

ingestion; 

2. a civilian, U.S. air carrier aircraft experiences a damaging collision with wildlife other 

than birds; or 

3. a USAF aircraft experiences a Class A, B, or C mishap as described below: 

a. Class A Mishap: Occurs when at least one of the following applies: 

i. total mishap cost is $1,000,000 or more; 

ii. a fatality or permanent total disability occurs; and/or 

iii. an Air Force aircraft is destroyed. 

b. Class B Mishap: Occurs when at least one of the following applies: 

i. total mishap cost is $200,000 or more and less than $1,000,000; 

and/or 

ii. a permanent partial disability occurs and/or 3 or more people are 

hospitalized; 

c. Class C Mishap: Occurs when at least one of the following applies: 

i. cost of reported damage is between $20,000 and $200,000; 

ii. an injury causes a lost workday (i.e., duration of absence is at least 8 

hours beyond the day or shift during which mishap occurred); and/or 

iii. an occupational illness causing absence from work at any time. 

Wetlands. An ecosystem requiring constant or recurrent, shallow inundation or 

saturation at or near the surface of the substrate. The minimum essential 

characteristics of a wetland are recurrent, sustained inundation or saturation at or near 

the surface and the presence of physical, chemical, and biological features indicating 

recurrent, sustained inundation, or saturation. Common diagnostic wetland features are 

hydric soils and hydrophytic vegetation. These features will be present, except where 

specific physiochemical, biotic, or anthropogenic factors have removed them or 

prevented their development. (Source the 1987 Delineation Manual; 40 CFR 230.3(t)). 

Wildlife. Any wild animal, including without limitation any wild mammal, bird, reptile, 

fish, amphibian, mollusk, crustacean, arthropod, coelenterate, or other invertebrate, 

including any part, product, egg, or offspring there of (50 CFR 10.12, Taking, 

Possession, Transportation, Sale, Purchase, Barter, Exportation, and Importation of 

Wildlife and Plants). As used in this MOA, “wildlife” includes feral animals and domestic 

animals while out of their owner’s control (14 CFR 139.3, Certification and Operations: 

Land Airports Serving CAB-Certificated Scheduled Air Carriers Operating Large Aircraft 

(Other Than Helicopters))
Appendix H Multi Agency MOA 261

Birds 

Table 1. Identified wildlife species, or groups, that were involved in two or 

more aircraft-wildlife strikes, that caused damage to one or more aircraft 

components, or that had an adverse effect on an aircraft’s flight. Data are 

for 1990-1999 and involve only civilian, U.S. aircraft. 

No. reported strikes 

Gulls (all spp.) 874 

Geese (primarily, Canada geese) 

182 

Sandhill cranes 

15 

14

14 

Meadowlarks 8 

7 

Turkeys 4 

458 

Hawks (primarily, Red-tailed hawks) 

Ducks (primarily Mallards.) 166 

Vultures (primarily, Turkey vulture) 142 

Rock doves 122 

Doves (primarily, mourning doves) 109 

Blackbirds 81

European starlings 55 

Sparrows 52

Egrets 41

Shore birds (primarily, Killdeer & Sandpipers) 40 

Crows 31

Owls 24

22 

American kestrels 

Great blue herons 15 

Pelicans 14

Swallows

Eagles (Bald and Golden) 

Ospreys 13

Ring-necked pheasants 11 

Herons 11

Barn-owls 9

American robins 8 

Buntings (snow) 

Cormorants 6

Snow buntings 6 

Brants 5

Terns (all spp.) 5 

Great horned owls 5 

Horned larks 4 
262 Multi Agency MOA Appendix H 

Swans 3 

Mockingbirds 3 

Quails 3 

Homing pigeons 3 

Snowy owls 3 

Peregrine falcons 

2 

Anhingas 2 

Ravens 2 

Kites 2 

Falcons 2 

2 

Merlins 2 

Grouse 2 

Hungarian partridges 

Spotted doves 2 

Thrushes 2 

Mynas 2 

Finches 2 

Total known birds 2,612 

Mammals No. reported strikes 

Deer (primarily, White-tailed deer) 285 

Coyotes 16 

Dogs 10 

Elk 6 

5 

3 

2 

Moose 2 

Cattle 

Bats 4 

Horses 

Pronghorn antelopes 3 

Foxes 

Raccoons 2 

Rabbits 2 

Total known mammals 340 

Ring-billed gulls were the most commonly struck gulls. The U.S. ring-billed gull 

population increased steadily at about 6% annually from 1966-1988. Canada geese 

were involved in about 90% of the aircraft-goose strikes involving civilian, U.S. aircraft 

from 1990-1998. Resident (non-migratory) Canada goose populations increased 

annually at 13% from 1966-1998. Red-tailed hawks accounted for 90% of the identified 

aircraft-hawk strikes for the 10-year period. Red-tailed hawk populations increased 
Appendix H Multi Agency MOA 263

annually at 3% from 1966 to 1998. Turkey vultures were involved in 93% of he 

identified aircraft-vulture strikes. The U.S. Turkey vulture populations increased at 

annually at 1% between 1966 and 1998. Deer, primarily white-tailed deer, have also 

adapted to urban and airport areas and their populations have increased dramatically. 

In the early 1900’s, there were about 100,000 white-tailed deer in the U.S. Current 

estimates are that the U.S. population is about 24 million. 
264 Multi Agency MOA Appendix H 

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 265

APPENDIX I: 

FAA Form 5200-7 

Bird/Other Wildlife Strike Report 
 266 Appendix I 

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Appendix I Appendix I FAA Form 5200-7 FAA Form 5200-7 267
268 FAA Form 5200-7 Appendix I 
Appendix I FAA Form 5200-7 269

Directions for FAA Form 5200-7 Bird/Other Wildlife Strike Report 

13. Part(s) of Aircraft Struck or Damaged - Check which parts were struck and damaged. If a part was 

damaged but not struck, indicate this with a check on the damaged column only and indicate in 

comments (#21) why this happened (e.g., the landing gear might be damaged by deer strike, causing 

the aircraft to flip over and damage parts not struck by deer). 

22. Estimated cost of repairs or replacement - This may not be known immediately, but the data can be 

sent at a later date or put down a contact name and number for this data. 

Date - Date the form was filled out. 

1. Name of Operator - This can be an airline (abbreviations okay - UAL, AAL, etc.), business (Coca 

Cola), government agency (Police Dept., FAA) or if a private pilot, his or her name. 

2. Aircraft Make/Model - Abbreviations are okay, but try to include the model (e.g., B737-200). 

3. Engine Make/Model - Abbreviations are allowed (e.g., PW 4060, GECT7, LYC 580). 

4. Aircraft Registration - This means the N# (for USA registered aircraft). 

5. Date of Incident - Give the local date, not the ZULU or GMT date. 

6. Local Time of Incident - Check the appropriate light conditions and fill in the hour and minute local 

time and check AM or PM or use the 24 clock and skip AM/PM. 

7. Airport Name - Use the airport name or 3 letter code if a US airport. If a foreign airport, use the full 

name or 3 letter code and location (city/country). 

8. Runway used - Self explanatory. 

9. Location if En Route - Put the name of the nearest city and state. 

10. Height AGL - Put the feet above ground level at the time of the strike (if you don’t know, use MSL and 

indicate this). For take-off run and landing roll, it must be 0. 

11. Speed (IAS) - Speed at which the aircraft was traveling when the strike occurred. 

12. Phase of Flight - Phase of flight during which the strike occurred. Take-off run and landing roll should 

both be 0 AGL. 

14. Effect on Flight - You can check more than one and if you check “Other”, please explain in Comments 

(#21). 

15. Sky Condition - Check the one that applies. 

16. Precipitation - You may check more than one. 

17. Bird/Other Wildlife Species - Try to be accurate. If you don’t know, put unknown and some 

description. Collect feathers or remains for identification for damaging strikes. 

18. Number of birds seen and/or struck - Check the box in the Seen column with the correct number if 

you saw the birds/other wildlife before the strike and check the box in the Struck column to show how 

many were hit. The exact number, can be written next to the box. 

19. Size of Bird(s)- Check what you think is the correct size (e.g. sparrow = small, gulls = medium and 

geese = large). 

Pilot Warned of Birds - Check the correct box (even if it was an ATIS warning or NOTAM). 

20. Remarks - Be as specific as you can. Include information about the extent of the damage, injuries, 

anything you think would be helpful to know. (e.g., number of birds ingested). 

21. Aircraft time out of service - Record how many hours the aircraft was out of service. 

23. Estimated other cost - Include loss of revenue, fuel, hotels, etc. (see directions for #23). 

Reported by - Although this is optional, it is helpful if questions arise about the information on the form (a 

phone number could also be included). 

Title - This can be Pilot, Tower, Airport Operations, Airline Operations, Flight Safety, etc. 
270 FAA Form 5200-7 Appendix I 

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 271

APPENDIX J: 

Gull Facts For Airport Wildlife Control Personnel 
 272 Appendix J 

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Appendix J 273

Gull Facts for Airport Wildlife Control Personnel 

Richard A. Dolbeer, USDA Wildlife Services 

There are about 50 species of gulls in the world of which about 18 are regularly found in North 

America. North American gulls vary in size from 1/4 lb (little gull) to over 4 lbs (male great 

black-backed gull). 

Gulls are the most frequently reported birds struck by civil aircraft in the USA. From 1990-2004, 

25% of all identified bird strikes involved gulls. 

The sexes are identical in plumage but males are generally slightly larger than females. For 

example, male laughing gulls weigh 10% more than females on average whereas male herring 

gulls weigh 19% more than females. 

Gulls are generally long-lived with annual survival rates of 70 to >90%. A number of banded 

herring gulls have been recovered after 20 years and the record is over 30 years. Gulls begin 

losing bands due to wear and corrosion after 10 to 15 years so we really do not know how long 

they may live in the wild. 

Male and female gulls form pairs during the nesting season and both sexes contribute about 

equally to nest building, incubation, and feeding of chicks. Clutch size is usually 3 eggs and 

incubation takes about 20 (laughing gull) to 28 days (great black-backed gull). Young fledge 

(begin flying) from 35 (laughing gull) to 50 days (great black-backed gull) after hatching. Gulls 

will renest if nests are destroyed early in the nesting season. 

Gulls attain adult body size within 6 to 8 weeks of hatching but do not obtain adult plumage and 

mature sexually until 2 years (for small gulls) to 4-5 years (for large gulls). Plumage is generally 

all brown in the summer-fall of hatching year. Plumage acquires more adult characteristics with 

each successive molt. Plumage of immature gulls can be variable. Species identification and 

age classification of immature gulls can be difficult. 

Gulls struck by aircraft should be identified to species when possible. Because of large 

variations in behavior, migration, and body size among gull species, correct species ID is critical 

for determining management actions at airports and for analysis of engine and airframe 

damage. 

Convenient sources of information about gulls and other birds: 

Dunning, J. B. Jr., editor. 1993. CRC Handbook of Avian Body Masses. CRC Press, Boca 

Raton, Florida. 371 pages. (Data on body weights for birds throughout the world) 

Grant, P. J. 1986. Gulls: A Guide to Identification. Buteo Books, Vermilion, South Dakota. 352 

pages. (Detailed plumage characteristics) 

Ehrlich, P. R., D. S. Dobkin, and D. Wheye. 1988. The Birder’s Handbook. Simon and 

Schuster, New York. 785 pages. (Provides a wealth of conveniently summarized life 

history information on most North American bird species) 

Robbins, C. S., B. Bruun, and H. S. Zim. 1983. Birds of North America. Golden Press, New 

York. 360 pages. (Excellent field guide providing range maps for all bird species nesting 

in North America) 

Sibley, D. A. 2000. The Sibley Guide to Birds. Alfred Knopf, New York. 544 pages. (Detailed 

plumage characteristics and good range maps). 
274 Gull Facts Appendix J 

FACTS FOR SELECTED GULL SPECIES IN NORTH AMERICA 

Mean body mass in lbs (grams) 

Mean length in inches 

(cm) 

Species Male Both sexes Female Bill to tail Wing-span 

Age 

(year) of 

first 

reproduction 

Little Gull 

Larus minutus 0.25 (120) 11 (28) 24 (61) 2? 

Bonaparte’s Gull 

Larus Philadelphia 0.5 (212) 13 (33) 33 (81) 2-3 

Franklin’s Gull 

Larus pipixcan 0.6 (280) 14 (35) 36 (91) 2-3 

Laughing Gull 

Larus atricilla 0.8 (345) 0.7 (312) 16 (41) 41 (104) 2-3 

Mew Gull 

Larus canus 1.0 (432) 0.8 (375 16 (41) 43 (112) 3-4 

Ring-billed Gull 

Larus delawarensis 1.2 (566) 1.0 (471) 17 (43) 49 (124) 3-4 

California Gull 

Larus californicus 1.4 (657) 1.2 (556) 21 (53) 54 (137) 3-4 

Herring Gull 

Larus argentatus 2.7 (1226) 2.3 (1044) 25 (63) 58 (147) 3-5 

Glauc.-winged Gull 

Larus glaucascens 2.2 (1010) 2.2 (56) 26 (66) 58 (147) 3-5 

Western Gull 

Larus occidentalis 2.2 (1011) 25 (63) 58 (147) 3-5 

G. Black-backed gull 

Larus marinus 4.0 (1829) 3.3 (1488) 30 (76) 65 (165) 4-5 
 275

APPENDIX K: 

Assessing Wildlife Hazard Management Plans At Civil 

Airports
 276 Appendix K 

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Appendix K 277

ASSESSING WILDLIFE HAZARD MANAGEMENT PLANS AT CIVIL AIRPORTS

This appendix describes a system (modified from Seubert 19941

) for objectively 

assessing the implementation of wildlife hazard management plans at civil airports. 

Five assessment categories, each with a list of elements to be evaluated, are used to 

indicate how well airport wildlife hazard management plans are being implemented.

Category 1. Management functions related to wildlife hazards on or in the vicinity of 

the airport. 

Category 2. Bird control on or in the vicinity of the airport. 

Category 3. Mammal control on or in the vicinity of the airport. 

Category 4. Management of habitat and food sources on airport property related to 

wildlife hazards. 

Category 5. Land uses and food sources off of airport potentially related to wildlife 

hazards on airport. 

The elements described in Categories 1-4 are assessed as to the degree that 

management programs are being implemented. The elements in Category 5 are rated 

as to the degree of hazard posed. Elements within each category are not intended to 

cover every possibility – they can be modified or expanded to meet situations unique to 

an airport. 

During an assessment, each element in Categories 1-4 is examined and classified as 

one of the following: 

S = Satisfactory. If an assessor finds that an airport has initiated action to reduce a 

wildlife hazard according to plan and is on schedule, the action would be 

considered “satisfactory”. 

U = Unsatisfactory. If no measures have been taken or inappropriate measures taken, 

the assessment would be “unsatisfactory”. 

NI = Needs improvement. If implementation of a control measure is behind schedule 

or only partially accomplished, the assessment would be either “needs 

improvement”, or “unsatisfactory”, depending on the seriousness of the 

hazard. 

NA = Not applicable. If it is apparent that certain listed techniques or items are not 

applicable to the airport, the assessment would be “not applicable”. 

If an assessment is either “NI” or “U”, a comment by an assessor is required on the 

Assessment Summary Form (last page). Examples of assessments requiring 

comments are as follows: 

 

1

 Seubert, J. L. 1994. Assessing the implementation of wildlife hazard management 

programs at civil airports. Proceedings Bird Strike Committee Europe 22:275-284. 
278 Assessing Hazard Management Plans Appendix K 

Category 1. Management functions related to wildlife hazards on or in the vicinity of 

the airport. 

If permits have not been obtained (Code 1.1) for shooting or trapping birds or mammals, 

the assessment would be “U”. 

If animal remains found on runways are being counted to document bird strikes, but are 

not being identified by species (Code 1.13), the assessment would be “NI”. 

Category 2. Bird control on or in the vicinity of airports. 

If bioacoustics are not being used (Code 2.2), the assessment would be “U”. 

If the installation of wires (Code 2.9) over an airport pond is behind schedule, the 

assessment could be “NI” or “U”, depending on the degree of potential hazard. 

If raptors are not being trapped and relocated (Code 2.22), the assessment would be 

“U”. 

Category 3. Mammal control on or in the vicinity of airports. 

If fencing (Code 3.2) is in need of repair, the assessment would be “NI”. 

If rodenticides (Code 3.12) are not being used to control a rodent population attracting 

raptors, the assessment would be “U”. 

Category 4. Management of habitat and food sources on airport property related to 

wildlife hazards. 

If airport litter control is inadequate (Code 4.9), the assessment would be “NI”. 

If trees used as a roost site (Code 4.3) are not being eliminated or thinned to be made 

unattractive, the assessment would be “U”. 

Categories 1-4 focus on actions that can be taken on the airport to reduce wildlife 

hazards. 

Category 5. Land uses and food sources off of airport potentially related to wildlife 

hazards on airport. 

This provides a list of off-airport land uses and food sources that may be attractive to 

birds or other wildlife. The assessor should review this list and score each element on a 

scale of 0 to 3: 

0 = land use or food source not present; 

1 = present but no wildlife problems noted or anticipated; 

2 = site attracts some hazardous wildlife creating possible or potential problem, site 

should be monitored; 

3 = site creates significant wildlife hazard for airport, action should be taken. 

Wildlife hazards at airports frequently are attributable to these off-site attractants, but 

airport managers have no authority over the use of private property. However, airport 

managers can initiate programs to reduce the hazards of these off-airport wildlife 

attractants (e.g., garbage dumps, certain agricultural activities) by informing local 
Appendix K Assessing Hazard Management Plans 279

jurisdictions and landowners of the hazards, and suggesting ways of alleviating them 

(Code 1.12). 
280 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 281

Airport Date Assessment Page 1 of 6 

CATEGORY 1. Management functions related to wildlife hazards on or in the vicinity of the 

airport. 

ASSESSMENT

CODE ITEMS S NI U NA

1.1 Acquiring wildlife control permits from federal, state, and local 

agencies 

1.2 Arranging for wildlife hazard assessments and other studies, as 

needed, to evaluate hazard potential of wildlife attracted by habitats, 

land uses, and food sources on or in vicinity of airport. 

1.3 Developing Wildlife Hazard Management Plan based on Wildlife 

Hazard Assessment and other studies and factors. 

1.4 Defining and delegating authority and responsibility for Wildlife 

Hazard Management Plan. 

1.5 Supervising, implementing, and coordinating airport Wildlife Hazard 

Management Plan. 

1.6 Evaluating Wildlife Hazard Management Plan at least once/yr. 

1.7 Training personnel responsible for implementing airport Wildlife 

Hazard Management Plan, especially field personnel. 

1.8 Operating wildlife patrol system with a trained field staff , conducting 

surveillance/inspections of critical airport areas, and effecting wildlife 

control when needed or requested. 

1.9 Establishing a communication capability between wildlife control and 

ATC personnel. 

1.10 Maintaining a system for warning pilots about wildlife hazards (e.g., 

NOTAMS, ATC, Radar observations). 

1.11 Ensuring that airport habitats are managed to reduce or eliminate 

wildlife attractions. 

1.12 Ensuring that airport policy prohibits feeding of wildlife and exposure 

of food wastes. 

1.13 Interacting with local jurisdictions and landowners about zoning, land 

use, and the resolution of wildlife hazard problems in vicinity of 

airport. 

1.14 Maintaining log book with daily record of wildlife control activities, 

wildlife activity, and reported wildlife strikes and wildlife remains 

found on runways identified by species. 

1.15 Reporting all wildlife strikes to FAA. 
282 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 283

Airport Date Assessment Page 2 of 6 

CATEGORY 2. Bird control on or in the vicinity of the airport. 

ASSESSMENT

CODE TECHNIQUES S NI U NA

DISPERSE, DETER, EXCLUDE, REPEL 

2.1 Bird patrols in vehicle 

2.2 Bioacoustics (distress calls) 

2.3 Electronically generated noise 

2.4 Propane cannons 

2.5 Pyrotechnics

2.6 Shooting to scare 

2.7 Netting hanger rafters, ponds etc. 

2.8 Perching deterrents (e.g., stainless steel needles) 

2.9 Overhead wires for ponds, ditches, roofs etc. 

2.10 Chemical repellents

2.11 Falconry

2.12 Dogs

2.13 Radio-controlled aircraft

2.14 Thinning or eliminating roosting trees and shrubs 

2.15 Grass management

2.16 Scarecrows

2.17 Dead bird effigies 

 

REMOVE 

2.18 Chemical capture (alpha chloralose) 

2.19 Nest and egg destruction 

2.20 Poisoning

2.21 Predators to remove eggs (foxes, pigs, etc.) 

2.22 Shooting

2.23 Trapping and relocation (e.g., raptors) 
284 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 285

Airport Date Assessment Page 3 of 6

CATEGORY 3. Mammal control on or in the vicinity of the airport. 

ASSESSMENT

CODE TECHNIQUES S NI U NA

DISPERSE, DETER, EXCLUDE, REPEL 

3.1 Cattle guards

3.2 Fencing

3.3 Vehicle patrols

3.4 Propane cannons

3.5 Pyrotechnics

3.6 Rodent-resistant sheathing on electrical cables 

REMOVE 

3.7 Controlled hunting (e.g., deer) 

3.8 Den destruction (e.g., coyotes) 

3.9 Fumigants (e.g., woodchucks) 

3.10 Kill trapping (e.g., beavers, muskrats) 

3.11 Live trapping and relocation or euthanasia (e.g., dogs) 

3.12 Rodenticides (e.g., mice, ground squirrels) 

3.13 Shooting (e.g., deer, woodchucks, hares) 
286 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 287

Airport Date Assessment Page 4 of 6 

CATEGORY 4. Management of habitat and food sources on airport property related to 

wildlife hazards. 

ASSESSMENT

CODE ITEMS S NI U NA

AGRICULTURE/VEGETATION MANAGEMENT 

4.1 Agricultural crops (especially cereal grains and sunflowers) 

4.2 Plowing, mowing, harvesting (rodents, insects, worms) 

4.3 Landscaping (fruits & roost sites attractive to birds) 

4.4 Brush, shrubs, wood lots (cover, browse for deer) 

4.5 Misc. nesting sites (e.g., trees) for egrets, raptors, etc. 

WASTE MANAGEMENT/SANITATION 

4.6 Feeding birds and mammals (by people) 

4.7 Food waste storage (e.g., cafeterias, catering services) 

4.8 Garbage dumps

4.9 Litter

4.10 Sewage treatment ponds/lagoons/outfalls 

4.11 Weeds, construction debris, junk yards 

4.12 Animal carcasses (dead livestock, bird strike remains) 

WATER SOURCES 

4.13 Aquatic vegetation

4.14 Canals, ditches, creeks, waterways 

4.15 Low areas on pavement/ground that collect water 

4.16 Retention ponds (water, de-icing fluid) 

4.17 Water fountains

MISCELLANEOUS ATTRACTANTS 

4.18 Earthworms along runways 

4.19 Insects hatches from vegetation or soil 

4.20 Seed-producing vegetation.

4.21 Flat roofs (e.g., gull nesting and loafing sites) 

4.22 Structures (hangers, towers, signs, poles, etc.) 
288 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 289

Airport Date Assessment Page 5 of 6 

CATEGORY 5. Land uses and food sources off airport potentially related to wildlife hazards 

on airport. 

CODE ITEMS Scorea COMMENTS 

AGRICULTURE

5.1 Agricultural crops (especially cereal grains) 

5.2 Aquaculture facilities

5.3 Livestock feedlots

5.4 Grain storage or grain mills 

COMMERCIAL/RECREATIONAL LAND USES 

5.5 Drive-in theaters, amusement parks etc. 

5.6 Restaurants (esp. outdoor eating areas) 

5.7 Picnic areas, parks 

5.8 Marinas

5.9 Golf courses

5.10 Flat roofs (gull nesting sites) 

 

WASTE MANAGEMENT 

5.11 Garbage barges

5.12 Garbage dumps

5.13 Garbage transfer stations 

5.14 Fish processing plants 

5.15 Sewage lagoons, outfalls 

WATER SOURCES 

5.16 Retention ponds (water, feedlots, etc.) 

5.17 Canals, creeks, ditches 

5.18 Reservoirs, lakes, natural ponds 

NESTING/LOAFING/FEEDING AREAS 

5.19 Wildlife refuges/nature preserves 

5.20 Misc. nesting sites (egrets, raptors, etc.) 

5.21 Roosting trees (starlings, egrets, etc.) 

5.22 Marshes, swamps, mud flats 

a

 0 = not present;

 1 = present but no wildlife problems noted or anticipated; 

 2 = site attracts some hazardous wildlife creating possible or potential problem, site should be monitored; 

 3 = site creates significant wildlife hazard for airport, action should be taken. 
290 Assessing Hazard Management Plans Appendix K 

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Appendix K Assessing Hazard Management Plans 291

 

Airport Date Assessment Page 6 of 6 

SUMMARY FORM (Wildlife Hazard Assessment): Comments are required for all elements in 

Categories 1-4 assessed as “Unsatisfactory” or as “Needs Improvement” or with a score of 2 

or 3 in Category 5. 

Manager or wildlife supervisor: Phone: 

Fax:

 E mail:

Assessor: Phone:

 Fax: 

E mail:

Assessor’s comments for elements rated “unsatisfactory” or “needs improvement” in 

Categories 1-4 or for elements scored 2 or 3 in Category 5. 

Element 

code 

Assessment 

symbol Comments 

 

 

 

 

Assessor’s general comments (use back if needed): 
292 Assessing Hazard Management Plans Appendix K 

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 293

APPENDIX L: 

Aviary And Field Evaluations Of Various Wildlife Control 

Products And Strategies For Airports
 294 Appendix L 

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Appendix L Evaluations of Control Products 295

AVIARY AND FIELD EVALUATIONS OF VARIOUS WILDLIFE CONTROL 

PRODUCTS AND STRATEGIES FOR AIRPORTS 

Richard A. Dolbeer 

USDA/APHIS/Wildlife Services 

6100 Columbus Avenue 

Sandusky, OH 44870 USA

Numerous products and strategies are available to reduce bird and other wildlife activity 

around airport buildings and runways. Many of these products and strategies are 

promoted and sold with only anecdotal evidence to support efficacy claims. Wildlife 

damage biologists frequently are asked for advice on the purported efficacy of these 

approaches. Too often, no data or insufficient data are available to make informed 

recommendations about a particular product. Thus, purchases are often made and 

products or strategies deployed that prove unsatisfactory. Not only do these purchases 

result in wasted money, but they may also increase hazards if airport personnel believe 

the deployment of an ineffective strategy has solved the problem. 

Evaluation of these devices and strategies under controlled conditions with sufficient 

replications to provide statistically rigorous results is difficult, especially for birds. The 

Ohio Field Station (OFS) of the U.S. Department of Agriculture’s National Wildlife 

Research Center (NWRC) is located on a 5,400-acre fenced site, Plum Brook Station 

[PBS], operated by the National Aeronautical and Space Administration, Erie County, 

Ohio. PBS provides an ideal outdoor laboratory for wildlife damage control tests. The 

site contains an outdoor aviary and a 10-acre Canada goose pond and grass facility for 

tests with captive birds. PBS also has large populations of free-roaming deer, starlings 

and other wildlife. PBS is within 50 miles of several large gull colonies along the shore 

of Lake Erie where testing also can be done. 

Through an interagency agreement with the Federal Aviation Administration (FAA) and 

cooperative agreements with the Port Authority of New York and New Jersey (PANYNJ) 

and private companies, the OFS has evaluated over 35 wildlife control products and 

strategies from 1992-2004. These tests provide objective data on the efficacy and 

limitations of various products and strategies—information that should be helpful to 

airport personnel and wildlife damage control biologists. Having said this, I emphasize 

that these tests typically do not provide a definitive, all-encompassing assessment of a 

product’s value or limitations. Product efficacy may vary depending on species, time of 

year, context of presentation and other factors. However, the tests do provide objective 

data on performance under controlled or measured conditions so that at least some 

conclusions can be drawn regarding potential usefulness in an airport environment. 

Below is a listing of publications with abstracts by species group that document the 

results of many of these tests. Copies of the full publications can be obtained from 

university libraries or by contacting the NWRC library at www.aphis.usda.gov/ws/nwrc. I 

acknowledge the creative test designs developed and work carried out by the various 

USDA employees listed in the publications. I also acknowledge the support provided by 

the FAA, especially S. Agrawal, M. Hovan, and T. Hupf (William J. Hughes Technical 

Center, Atlantic City, NJ) and E. C. Cleary (Office of Airport Safety and Standards, 

Washington, DC) and the PANYNJ (L. Francoeur). 
296 Evaluations of Control Products Appendix L 

GULLS AND RELATED SPECIES

1. Belant, J. L. 1997. Gulls in urban environments: landscape-level management 

to reduce conflict. Landscape and Urban Planning 38:245-258. Abstract: 

Populations of several species of gulls (Larus spp.) have increased dramatically 

throughout coastal areas of North America and Europe during the past several decades. 

These increases have been attributed to protection from human disturbance, reduction 

in environmental contaminants, availability of anthropogenic food, and the ability of gulls 

to adapt to human-altered environments. Gull abundance in urban areas has resulted 

in numerous conflicts with people including hazards to aircraft, damage to buildings 

from nesting material and defecation, and general nuisance. Various architectural and 

habitat management approaches are available to reduce gull/human conflicts. For 

example, gull use of landfills may be reduced by covering refuse, diverting 

anthropogenic food to covered compost facilities, erecting wire grids over exposed 

refuse, and manipulation of turf height in loafing areas. Nesting on roofs can be 

alleviated through modifications of roofing substrate and placement of overhead wires. 

Also, attractiveness of airports to gulls can be reduced through drainage of temporary 

water and by decreasing the availability of prey and loafing sites through habitat 

management. Although control activities can be effective at the site where the gull 

problem occurs, uncoordinated management efforts may cause relocation of problems 

to surrounding areas. Also, site-specific management will rarely solve the problem 

across a larger scale (e.g., city-wide). A working group comprised of the respective city 

or county planning commission, affected businesses, private citizens, and wildlife 

professionals can provide overall direction for gull management. This working group 

should define the extent and nature of the problem, develop an appropriate 

management strategy incorporating ecology of the nuisance species, and conduct 

periodic assessments of program efficacy. An integrated, landscape-level management 

approach is necessary to ensure an overall reduction in conflict between gulls and 

people in urban environments. 

2. Belant, J. L., S. W. Gabrey, R. A. Dolbeer, and T. W. Seamans. 1995. Methyl 

anthranilate formulations repel gulls and mallards from water. Crop Protection 

14:171-175. Abstract: Two formulations of methyl anthranilate (MA), one (ReJeX-iTTM

TP-40 [TP-40]) containing a surfactant, the other (ReJeX-iTTM AP-50 [AP-50]) a 

miscible, free-flowing powder, effectively repelled captive mallards from pools of water 

in a pen test and/or free-ranging ring-billed and herring gulls from pools of water at a 

landfill for 4 to 11 days. With one exception, pool entries and bill contacts with water 

were reduced (P < 0.02) in pools treated with either formulation compared to untreated 

pools. Overall gull activity was reduced (P < 0.01) when all available water was treated 

with AP-50. Repellency of gulls and mallards from water was achieved with 

concentrations of MA (0.016-0.038%, v/v) 10-60 times lower than needed in previous 

studies to repel birds from food. These tests indicate that MA-based formulations in low 

concentrations should have utility in various agricultural and other situations where it is 

desirable to reduce bird activity in water. 
Appendix L Evaluations of Control Products 297

3. Belant, J. L., and S. K. Ickes. 1996. Overhead wires reduce roof-nesting by

ring-billed and herring gulls. Proceedings of the Vertebrate Pest Conference 

17:108-112. Abstract: We evaluated the effectiveness of overhead wires in reducing 

roof-nesting by ring-billed gulls (Larus delawarensis) and herring gulls (L. argentatus) at 

a 7.2-ha food warehouse in northern Ohio during 1994-1995. In 1994, stainless steel 

wires (0.8 mm diameter) were attached generally in spoke-like configurations between 

2.4 m upright metal poles spaced at 33.7-m intervals over the main portion of roof. The 

6-14 wires radiating from each pole created a mean maximum spacing between wires of 

about 16 m. Nesting by ring-billed and herring gulls was reduced by 76% and 100% in 

1994 and by 99% and 100% in 1995, respectively, compared to 1993 pretreatment 

levels (1,011 ring-billed gull nests and 98 herring gull nests). Ring-billed gulls that 

constructed nests after wire installation gained access to the roof where wires were not 

installed along the roof edge, where wires were broken, by hovering over wires and 

landing between them, or from structures such as air conditioners that were at or above 

the level of surrounding wires. Initial placement of overhead wires above roof structures 

and regular maintenance of broken wires is recommended to increase effectiveness. 

Mean maximum spacing of 16 m between wires was effective in excluding nesting by 

herring gulls; however, narrower spacing is necessary to exclude nesting by ring-billed 

gulls. Also, many of the ring-billed gulls displaced by wires from the warehouse in 1994 

relocated to nest on an adjacent building without overhead wires. Thus, although 

overhead wires can be effective in reducing nesting by gulls on roofs and in other urban 

situations, management should be considered at a scale broader than specific problem 

sites as displacement of nesting gulls may cause relocation of the colonies to 

surrounding areas. 

4. Belant, J. L., and S. K. Ickes. 1997. Mylar flags as gull deterrents. 

Proceedings of the Great Plains Wildlife Damage Control Conference 13:73-80. 

Abstract: During 1996, we evaluated the effectiveness of mylar flags for deterring 

herring gulls (Larus argentatus) from 2 nesting colonies (roof and breakwall) and herring 

and ring-billed (L. delawarensis) gulls from 2 loafing sites at a landfill. Mylar flags (15 

cm x 1.0 m) attached to wire or lathe supports were positioned at 6-m intervals at 

nesting colonies and 3- to 12-m intervals at loafing areas. For both nesting colonies, 

time of nest initiation, nest density, and clutch size in 1996 when flags were present was 

similar to or greater than values obtained for these parameters at the same colonies in 

1995 when flags were not present. The maximum number of chicks observed at the 

roof colony in 1996 was also similar to the maximum number of chicks observed in 

1995. At the landfill, we observed fewer gulls (P < 0.05) at 1 loafing site during the 2 

weeks when mylar flags (6- and 12-m spacing) were present than during the 2 weeks 

when flags were not present. In contrast, gull use of the second loafing area did not 

appear influenced by the presence of mylar flags (3- and 6-m spacing), likely because 

of its small size (6 x 90 m) and proximity to a frequently used pond. We conclude that 

mylar flags are ineffective in deterring herring gulls (and likely other gulls) from nesting 

colonies but can reduce gull use of loafing areas. 
298 Evaluations of Control Products Appendix L 

5. Blackwell, B. F., T. W. Seamans, D. A. Helon, and R. A. Dolbeer. 2000. Early 

loss of herring gull clutches after egg-oiling. Wildlife Society Bulletin 28(1):70-75. 

Abstract: Critical to the success of egg-oiling as a means to control growth of bird 

populations is extension of the incubation period, thereby minimizing renesting 

attempts. Egg-oiling studies conducted with ring-billed (Larus delawarensis) and 

herring (L. argentatus) gulls generally have reported no evidence of abandonment of 

oiled clutches up to the expected hatching date (EHD). However, comparisons of clutch 

loss (assumed primarily to predation) up to EHD among control and treatment groups 

were not reported. Therefore, we evaluated early (oiling 21-27 days before EHD) and 

late (oiling 7-15 days before EHD) oiling protocols in a herring gull colony on Lake Erie, 

Erie County, Ohio. Marked differences (P < 0.01) were observed among treatments in 

the number of nests producing chicks (90.0%, n = 100, control; 20%, n = 100, early oil, 

and 1%, n = 100, late oil). Clutches in nests assigned to the 2 oil groups were more 

frequently (P < 0.01) lost (6% control; 29% early; 38% late) to abandonment, storms, 

and predation up to EHD. Only 56% of oiled clutches were incubated past EHD. Clutch 

loss (including nest abandonment) up to EHD did not differ (P = 0.35) between nests in 

the early and late oil groups. Our data suggest that herring gulls were sensitive to oil 

and that nests were abandoned or clutches lost within the normal incubation period in 

numbers greater than expected under natural conditions. The effectiveness of eggoiling in reducing recruitment in herring gull colonies is improved by oiling nests late in 

the incubation period. Subsequent oil applications will allow for inclusion of late nests 

and renesting attempts. 

6. Dolbeer, R. A. 1998. Keynote Address: Population dynamics: the foundation 

of wildlife damage management for the 21st century. Proceedings of the 

Vertebrate Pest Conference 18:2-11. Abstract: To justify and defend lethal or 

reproductive control programs to solve vertebrate pest problems, wildlife biologists must 

have a sound understanding of the population status and dynamics of the problem 

species. Models are essential to project how populations will respond to proposed 

management actions, providing a scientific foundation to counter the emotional debates 

that often arise. Four population models (PM1-PM4) for predicting population 

responses are described. PM1 and PM2 explore the relative efficacy of reproductive 

and lethal control for vertebrate species over 10-year intervals. PM3 simulates 

population responses to actual management actions through 10-year intervals. PM4 

simulates population changes for a species at weekly intervals over an annual cycle, 

exploring the immediate (<1 year) impact of population management actions. 

Population simulations using PM1 and PM2 demonstrated that for most vertebrate pest 

species considered, lethal control will be more efficient than reproductive control in 

reducing population levels. Reproductive control is more efficient than lethal control 

only for some rodent and small bird species with high reproductive rates and low 

survival rates. A simulation (PM3) of the removal of 47,000 laughing gulls (Larus 

atricilla) from the Long Island-New Jersey population accurately predicted the 33% 

decline of the population over 5 years. A simulation (PM4) of the annual cycle of the 

common grackle (Quiscalus quiscula) population in the eastern United States 

demonstrated why removing 4.2 million birds in 1 winter had no discernible impact on 

subsequent breeding populations. Understanding the population dynamics of wildlife 
Appendix L Evaluations of Control Products 299

species is the cornerstone to successful management, and population models will be 

essential for this task in the years to come. 

7. Dolbeer, R. A., D. P. Arrington, E. LeBoeuf, and C. Atkins. 1996. Can 

albatrosses and aircraft coexist on Midway Atoll? Bird Strike Committee Europe 

23:327-335. Abstract: Aircraft collisions with birds (bird strikes), especially Laysan 

albatrosses (Diomedea immutabilis), have been a problem at Midway Naval Air Facility 

since at least the 1950s. Although aircraft movements at Midway presently are reduced 

relative to 1950-1970 levels, the U.S. Navy in 1993 still reported 57 strikes during 459 

aircraft movements. We visited Midway from 15-21 April 1995 to determine the species 

composition and diurnal pattern of bird flights over Runway 6-24 so that 

recommendations could be made regarding timing of aircraft movements to minimize 

strikes. Midway Atoll in 1994-1995 had an estimated 450,000 nesting pairs of 

albatrosses (900,000 adults), a mean density of 725 nests/ha. We recorded a mean of 

363 birds (89% Laysan albatrosses) crossing the runway/minute during daylight hours. 

At night (2230-2300), we estimated only 5.7 birds/minute (89% Bonin petrels 

[Pterodroma hypoleuca]) flying over the runway, a 98.5% reduction over mean numbers 

during daylight. As Midway Atoll goes through the transition from military base to 

wildlife refuge, nonemergency aircraft movements should be restricted to night from 

November-mid July. Furthermore, any plans to develop "ecotourism" or other activities 

for the Atoll will need to factor in this constraint for aircraft movements. Under present 

conditions, daytime aircraft movements for commercial or private carriers would raise 

serious safety and liability issues. 

8. Dolbeer, R. A., J. L. Belant, and J. Sillings. 1993. Shooting gulls reduces 

strikes with aircraft at John F. Kennedy International Airport. Wildlife Society

Bulletin 21:442-450. Abstract: The collision of birds with aircraft is a serious problem 

at John F. Kennedy International Airport (JFKIA), New York City. Laughing gulls 

comprised 47% of the birds colliding with aircraft from 1988 to 1990, averaging 170 bird 

strikes per year. This species is present from May to September in association with a 

7,600-nest colony (1990) adjacent to the airport. Other gulls (herring, great blackbacked, and ring-billed), which are present year-round, comprised 37% of the strikes 

and another 52 species of birds comprised the remaining 16%. The airport has an 

active bird management program involving habitat alteration and the use of birdfrightening techniques to discourage birds from feeding, drinking, and loafing on airport 

grounds. However, these measures do little to prevent laughing gulls and other gull 

species from flying over the airport to non-airport feeding sites. An experimental 

program to reduce gull collisions with aircraft was undertaken in 1991 and 1992 in which 

2 to 5 people stationed on airport boundaries used shotguns to shoot gulls flying over 

the airport from mid-May to early August. There were high levels of gull activity at 

JFKIA in the summers of 1991 and 1992, as evidenced by the ability of shooters to kill 

26,038 laughing gulls and 2,314 other gulls flying over the airport in 2,206 person-hours 

of shooting. Shooting did not appear to condition gulls to avoid flying over the airport. 

The shooting program at JFKIA substantially reduced the incidences of strikes between 

all species of gulls and aircraft, by 70% in 1991 and 89% in 1992. The laughing gull 

nesting colony in its present location presents an unacceptable safety hazard to aircraft. 

The annual killing of large numbers of laughing gulls on the airport, while effective in 

reducing strikes, may not be effective in eliminating the colony from its present location. 
300 Evaluations of Control Products Appendix L 

Discussions should continue with NPS personnel to develop a plan to relocate the 

colony from Jamaica Bay. This plan could include habitat alteration, nest destruction, 

and other harassment and management techniques at the colony. However, a 

seasonal shooting program should continue on the airport to minimize the number of 

gull-aircraft collisions until the laughing gull colony is relocated from Jamaica Bay. 

9. Dolbeer, R. A., R. B. Chipman, A. L. Gosser, and S. C. Barras. 2003. Does 

shooting alter flight patterns of gulls: case study at John F. Kennedy International 

Airport. Proceedings of 26th International Bird Strike Committee meeting. WPBB5 Abstract. The collision of birds with aircraft (bird strikes) is a serious problem at 

John F. Kennedy International Airport (JFK), New York. Gulls (Larus spp.), of which 

60% were laughing gulls (L. atricilla), accounted for 86% of bird strikes from 1988-1990, 

averaging 261 strikes per year. Laughing gulls are present from May-September in 

association with a nesting colony in Jamaica Bay adjacent to the airport. A program to 

reduce gull strikes was conducted from May-August 1991-2002 in which 2-5 people 

stationed on airport boundaries shot gulls flying over the airport. As a result of the 

shooting program, the number of strikes with laughing gulls was reduced to 38% of 

1988-1990 levels in 1991 and to 1-24% of 1988-1990 levels in 1992-2002. Strikes by 

the 3 other gull species were reduced to 24-52% of preshooting levels over the same 

time period. The laughing gull colony in Jamaica Bay has declined 58% from 7,629 

nests in 1990 to 3,238 nests in 2002. That the colony size declined by only 58% from 

1990-2002 while the annual strike rate of laughing gulls declined by 97% (1990-2002) 

indicated that many laughing gulls altered flight patterns in response to shooting to 

avoid the airport. Although the shooting program has reduced the local population of 

gulls flying over JFK, the regional population has not been negatively impacted. Our 

recommended long-term solution to minimize gull-aircraft collisions and the number of 

gulls shot is to relocate the nesting colony away from JFK. This study demonstrated that 

shooting can significantly reduce gull-aircraft collisions at an airport by both reducing the 

local population and altering flight patterns of surviving gulls. A seasonal gull-shooting 

program should continue at JFK as part of the integrated management program to 

reduce bird hazards to aviation. 

10. Ickes, S. I., J. L. Belant, and R. A. Dolbeer. 1998. Nest disturbance 

techniques to control nesting by gulls. Wildlife Society Bulletin 26:269-273. 

Abstract: Urban-nesting gulls throughout the lower Great Lakes often conflict with 

human activities. We evaluated 5 nest disturbance techniques (nest-and-egg removal, 

egg removal, nest-and-egg destruction, egg destruction, and egg replacement) to 

reduce herring gull (Larus argentatus) and ring-billed gull (L. delawarensis) nesting in 

urban habitat, primarily roofs, in northern Ohio. Nest disturbance techniques were more 

effective in causing colony abandonment for ring-billed gulls than for herring gulls. Nest 

disturbance conducted for 1 year at an established ring-billed gull colony, and for <1 

week at a newly established ring-billed gull colony caused abandonment. Nest 

disturbance conducted for 1 to 10 years did not cause herring gulls to abandon 5 of 6 

established colonies; however, reductions were observed in annual maximum number 

of nests or eggs. Egg removal was at least as effective as nest-and-egg removal and 

required about 60% less effort. Egg replacement was the least effective of the 

techniques evaluated. Unless structural damage to buildings is of concern, egg removal 

is recommended over other nest disturbance techniques evaluated for inexpensive, 
Appendix L Evaluations of Control Products 301

long-term reductions of roof-nesting colonies. Nest-and-egg or egg destruction is 

recommended for ground-nesting colonies. Use of other control methods (e.g., habitat 

modification, frightening techniques) in addition to nest disturbance may increase the 

potential for colony abandonment.

11. Seamans, T. W., and J. L. Belant. 1999. Comparison of DRC-1339 and alphachloralose for reducing herring gull populations. Wildlife Society Bulletin 

27(3):729-733. Abstract: Results of several herring gull (Larus argentatus) control 

programs using DRC-1339 (3-chloro-4-methyl-benzenamine hydrochloride) suggested 

that the published median lethal dose (LD50) of 2.9 mg of DRC-1339/kg of body weight 

may not be accurate in some environments. We conducted laboratory trials to estimate 

LD50 values of DRC-1339 and of alpha-chloralose (AC) for herring gulls inhabiting fresh 

water. We also conducted field trials to compare effectiveness of these compounds in 

simulated gull control operations. We calculated the LD50 for DRC-1339 as 4.6 mg/kg 

and 43.1 mg/kg for AC. Mean (± SD) time to death for DRC-1339-dosed birds varied 

from 34.0 (± 12.2) hours at LD96 to 109.5 (± 55.5) hours at LD27. AC time to death 

varied from 2.3 (± 0.5) hours at >LD99 to 5.8 (± 0.0) hours at LD13. In field trials, DRC1339 baits treated at 27.4 mg/kg (LD99) resulted in 29% known mortality. In contrast, 

AC baits with a 30 mg/kg dosage (<LD01) resulted in 50% capture success and no 

mortality. AC baits at 58 mg/kg (LD99) resulted in 89% capture success and 41% 

mortality. With AC baits at 95 mg/kg (> LD99), 65% of gulls were captured with 82% 

mortality. AC was more effective than DRC–1339 in removing gulls from a nesting 

colony. We recommend AC as a gull population management chemical because it is 

fast acting, humane, and can be used as a nonlethal capture agent.

BLACKBIRDS AND STARLINGS

12. Belant, J. L., S. K. Ickes, L. A. Tyson, and T. W. Seamans. 1997. Comparison 

of d-pulegone and mangone as cowbird feeding repellents. International Journal 

of Pest Management 43:303-305. Abstract: We compared the effectiveness of dpulegone and mangone as feeding repellents to captive adult male brown-headed 

cowbirds (Molothrus ater) during October-November 1995. For each repellent, we 

conducted 4-day, 1- and 2-choice cage tests using concentrations (g/g) of 0.1%, 0.01%, 

and 0.001% with millet. During 1- and 2-choice tests, 0.1% d-pulegone reduced (P < 

0.01) cowbird feeding but lower concentrations did not. In contrast, concentrations of 

mangone as low as 0.001% reduced (P < 0.05) food consumption during 2-choice tests. 

Consumption of mangone-treated millet, however, was similar (P > 0.05) among 

1-choice tests and similar to total food consumption observed during 2-choice tests. We 

conclude that mangone is less effective than d-pulegone and would likely be ineffective 

as a repellent for seed treatment. We recommend field tests to further assess the 

effectiveness of d-pulegone as an avian feeding repellent.

13. Belant, J. L., P. P. Woronecki, R. A. Dolbeer, and T. W. Seamans. 1998. 

Ineffectiveness of five commercial deterrents for nesting starlings. Wildlife 

Society Bulletin 26:264-268. Abstract: We evaluated the effectiveness of phenethyl 

alcohol (PEA), eyespots, magnetic fields, and avian-predator effigies to deter European 

starlings (Sturnus vulgaris) from nesting in artificial cavities in Ohio during 1993, 1995, 

and 1996. Each year, 81 nest boxes attached to utility poles were assigned at random 
302 Evaluations of Control Products Appendix L 

equally among 3 treatments (including control): 1993 - PEA or eyespots, 1995 - 

magnetic fields of 88 or 118 Gauss, and 1996 - great horned owl or merlin effigy. 

Starlings nested in 84% (1993), 58% (1995), and 90% (1996) of the boxes. There was 

no difference (P > 0.13) among treatments each year in 6-7 measures of starling 

nesting activity. Four species other than starlings (eastern bluebirds [Sialia sialis], 

house wrens [Troglodytes aedon], tree swallows [Tachycineta bicolor], and house 

sparrows [Passer domesticus]) occupied 13 (1993), 23 (1995), and 2 (1996) nest boxes. 

We conclude that PEA, eyespots, magnetic fields <118 Gauss, and avian-predator 

effigies are ineffective as deterrents for starlings nesting in artificial cavities. 

14. Clark, L., and J. L. Belant. 1998. Contribution of particulates and pH on 

cowbirds' avoidance of food treated with agricultural lime. Applied Animal 

Behavior Science 57:133-144. Abstract: Agricultural lime used as a grain coating can 

be repellent to graniverous birds. However, whether repellency is achieved depends 

upon the method of preparation. The primary mechanism for mediating repellency is 

pH. Cowbirds avoid seed coated with agricultural lime (5% wt/wt) when the pH exceeds 

12.3. A second underlying component mediating repellency exits that is based on 

avoidance of particulates. If the particulate seed coating consists of particles sized ~63-

150 um, and has a pH of 11.4 or less, the repellent potency is about half that observed 

for raw unprocessed lime. Together, these data help explain emerging conflicting 

reports on the efficacy of agricultural lime as a bird-repellent. Finally, short-term data on 

food and water intake and energy balance suggest that periodic intake of agricultural 

lime does not adversely affect birds. 

15. Dolbeer, R. A., and S. K. Ickes. 1994. Red-winged blackbird feeding 

preferences and response to wild rice treated with portland cement or plaster. 

Proceedings of the Vertebrate Pest Conference 16:279-282. Abstract: The 

California wild rice (Zizania aquatica) industry considers red-winged blackbirds 

(Agelaius phoeniceus) their most important pest problem. Farmers often have asked if 

crop-damaging blackbirds can be killed by mixing dry Portland cement or plaster-ofParis with grain bait. We conducted a series of tests to determine the effect of cement 

or plaster mixed with wild rice fed to captive redwings and to determine feeding 

preferences of redwings for wild rice in relation to other grains. Birds would not eat 

cement- or plaster-treated rice when untreated rice was available and no mortality 

occurred when birds were offered only treated rice over a 4-day period. Thus, treating 

grain with cement or plaster will not kill redwings, but cement or plaster might serve as 

useful bird repellents for seed grain. Proso millet was strongly preferred over wild rice 

by redwings, indicating millet would be an excellent candidate as a lure crop and as a 

bait for trapping or for delivering a chemical. Sunflower would perhaps not be preferred 

bait or lure crop in wild rice areas and cracked corn would not be preferred bait. 

16. Dolbeer, R. A., D. F. Mott, and J. L. Belant. 1997. Blackbirds and starlings 

killed at winter roosts from PA-14 applications: implications for regional 

population management. Proceedings of the Eastern Wildlife Damage 

Management Conference 7:77-86. Abstract: The surfactant PA-14, registered with 

the U.S. Environmental Protection Agency in 1973 by the federal Wildlife Services (WS) 

program, was used for 19 years (1974-1992) for lethal control of roosting blackbirds 
Appendix L Evaluations of Control Products 303

(Icterinae) and European starlings (Sturnus vulgaris) in the USA. In 1992, the WS 

program withdrew the registration of PA-14 because of costs required to provide 

additional EPA-requested data. There were 83 roosts encompassing 178 ha treated 

with 33,300 L of PA-14 from 1974-1992. An estimated 38.2 million birds (48% common 

grackles [Quiscalus quiscula], 30% European starlings, 13% red-winged blackbirds 

[Agelaius phoeniceus], and 9% brown-headed cowbirds [Molothrus ater]) were killed, an 

average of 2.0 million/year. The annual kill represented <1.3% of the national winter 

population of blackbirds and starlings. We found no evidence using North American 

Breeding Bird Survey (BBS) data that PA-14 applications caused declines in regional 

breeding populations. Furthermore, there was no evidence of secondary poisoning or 

other adverse environmental effects from PA-14 applications. If regional population 

management of blackbirds and starlings is to be implemented to reduce agricultural 

damage or conflicts with native songbirds, new approaches, such as reproductive 

control, are needed because PA-14 alone will not be adequate. However, PA-14 could 

have a role in such regional programs in addition to solving localized roost problems. 

PA-14 was a useful management tool safely applied in human-populated areas (where 

most roost problems occur); its reregistration should be considered as part of an 

integrated management program for blackbirds and starlings.

17. Seamans, T. W., C. D. Lovell, R. A. Dolbeer, and J. D. Cepek. 2001. 

Evaluation of mirrors to deter nesting starlings. Wildlife Society Bulletin 

29(4):1061-1066. Abstract: European starlings (Sturnus vulgaris) nesting in buildings 

and structures can cause health, nuisance, and safety problems. We evaluated 

effectiveness of flashing lights combined with mirrors and mirrors alone as deterrents for 

starlings nesting in starling nest boxes in northern Ohio, 1998–2000. Each year, 100 

nest boxes attached to utility poles were randomly assigned equally among 4 

treatments (including untreated boxes): 1998- mirrored (internally placed on the back 

and 2 sides walls of nest boxes), mirrored with red-flashing lights, and mirrored with 

green-flashing lights; 1999- convex mirror above entrance hole, convex mirror at back of 

nest box, and flat mirror at back of nest box; 2000- mirrors on 3 sides with exposed 

surface areas of 263 cm2

, 527 cm2, or 790 cm2. Starlings nested in 67% (1998) and 

78% (1999 and 2000) of the nest boxes. In 1998, boxes within the 3 treatments with 

mirrors, regardless of lights, had fewer nests and fewer nests with eggs, nestlings, or 

fledglings than did control boxes (P [ 0.002). Boxes with mirrors and lights had fewer (P

< 0.05) nestlings than mirrored boxes. No difference was noted in number of fledglings 

produced/nest with nestlings for each treatment. In 1999 and 2000 there was no 

difference (P > 0.25) among the 4 treatments in proportion of nest boxes with starling 

nests, eggs, nestlings, and young fledged. However, in 2000, boxes with complete 

mirror coverage did show the least occupancy rate of the 4 treatments. Mean dates of 

first egg, clutch size, number of nestlings, and number of fledglings/nest also were 

similar (P > 0.06) among treatments. We conclude that mirrors, although slightly 

repellent under some configurations, are not a practical method to repel starlings from 

nesting in structures.
304 Evaluations of Control Products Appendix L 

Geese and Miscellaneous Birds 

18. Belant, J. L., S. K. Ickes, L. A. Tyson, and T. W. Seamans. 1997. Comparison 

of four particulate substances as wildlife feeding repellents. Crop Protection 

16:439-447. Abstract: We compared the effectiveness of dolomitic lime, activated 

charcoal, Nutra-lite (a silica-based compound), and white quartz sand as feeding 

repellents for brown-headed cowbirds (Molothrus ater), white-tailed deer (Odocoileus 

virginianus), and Canada geese (Branta canadensis). In 4 day, 2-choice aviary tests 

with cowbirds, consumption of treated millet (1% to 4% g/g) was less (P < 0.01) than 

consumption of untreated millet for all particulates except Nutra-lite at 1% g/g. Greatest 

reductions in consumption occurred with lime-treated millet, followed by charcoal, Nutralite, and sand. Overall mean daily consumption of treated millet by cowbirds in 1-choice 

tests was similar (P > 0.05) to total consumption of millet in comparable 2-choice tests 

for each particulate. However, millet treated with 4% lime reduced cowbird 

consumption for 1 day. Similarly, in 4-day, 2-choice tests field tests involving freeranging deer, deer consumed less corn treated (4% g/g) with lime or charcoal than corn 

treated with Nutra-lite or sand. Corn treated with sand did not reduce (P = 0.44) 

consumption by deer relative to untreated corn. Lime applied to turf in 10- x 21-m 

enclosures at an application rate of 270 kg/ha did not suppress grazing by geese. 

Nutra-lite applied to turf at the manufacturer-recommended rate of 2,568 kg/ha reduced 

overall goose presence on treated plots in enclosures for 3 days but suppressed goose 

grazing for 1 day only. We conclude that lime is more effective overall as a white-tailed 

deer and brown-headed cowbird feeding repellent than is charcoal, Nutra-lite, or sand. 

Lime has considerable potential as a feeding repellent in agricultural and possibly turf 

situations. Charcoal could be used effectively in situations where lime is impractical. 

19. Belant, J. L., and T. W. Seamans. 1999. Alpha-chloralose immobilization of 

rock doves in Ohio. Journal of Wildlife Diseases 35:239-242. Abstract: The 

effectiveness of 3 dosages (about 60, 120 and 180 mg/kg) of alpha-chloralose (AC) 

were compared for immobilizing pigeons (Columba livia). Responses to immobilization 

using about 180 mg/kg AC also was compared in pigeons food deprived for 24 hr and 

not food deprived. Mean (+ SE) time to first effects (33 + 2 min) and mean time to 

capture (94 + 5 min) was significantly less for pigeons receiving 180 mg/kg than for 

pigeons receiving lower dosages (>53 + 3 min and >153 + 17 min, respectively). Ten, 

10 and 8 pigeons immobilized with 60, 120 and 180 mg/kg AC recovered within 24 hr, 

respectively; all pigeons recovered within 29 hours. Although food-deprived pigeons 

showed effects of AC immobilization earlier than did pigeons with food, time to capture 

was similar between these 2 groups. This new formulation should improve capture 

success of pigeons substantially and improve the ability to resolve nuisance pigeon 

problems. 

20. Belant, J. L., T. W. Seamans, L. A. Tyson, and S. K. Ickes. 1996. Repellency 

of methyl anthranilate to pre-exposed and naive Canada geese. Journal Wildlife 

Management 60:923-928. Abstract: To improve our understanding of the 

effectiveness of avian feeding repellents, we evaluated whether Canada geese (Branta 

canadensis) exhibited learned avoidance of ReJeX-iT AG-36 (AG-36), a methyl 

anthranilate (MA) formulation containing 14.5% MA (vol/vol). During 2 experiments in 

August-September 1995, we pre-exposed geese orally to 0.0, 1.3, or 4.0 g AG-36 and 
Appendix L Evaluations of Control Products 305

released them onto 10- x 10-m grass plots treated with AG-36 at rates of 22.6 and 67.8 

kg/ha. Mean numbers of bill contacts and mean numbers of geese observed on control 

and treated plots were similar (P > 0.21) for geese pre-exposed or naive to AG-36. 

Overall, mean numbers of bill contacts and mean numbers of geese also were similar 

(P > 0.56) on control and treated plots. Mean mass of droppings on control and treated 

plots was similar (P > 0.99) during the experiment with 22.6 kg/ha AG-36 but was 

greater (P = 0.01) on control plots during the experiment with 67.8 kg/ha AG-36. We 

conclude that learned avoidance of AG-36 by Canada geese pre-exposed orally to 1.3 

or 4.6 g AG-36 did not occur and that AG-36 applied to turf in enclosures at rates of 

22.6 and 67.8 kg/ha was not effective as a grazing repellent for geese.

21. Belant, J. L., L. A. Tyson, T. W. Seamans, and S. K. Ickes. 1997. Evaluation of 

lime as an avian feeding repellent. Journal of Wildlife Management 61:917-924. 

Abstract: We evaluated the effectiveness of dolomitic hydrated lime as a feeding 

deterrent to captive brown-headed cowbirds (Molothrus ater) and Canada geese 

(Branta canadensis) during July-September 1995. We conducted 1- and 2-choice tests 

using grains with caged cowbirds and geese, and applications of lime to turf in dry and 

slurry form for geese. Lime mixed with millet or whole-kernel corn at 25, 12.5, and 

6.25% (g/g) reduced cowbird and goose feeding in 4 day, 2-choice (treated or untreated 

grain) cage trials. Reductions in total food intake occurred for both species during 

similar 1-choice tests with lime (25% [g/g]) and millet or corn. Body mass of cowbirds 

and geese increased or remained constant during 2-choice tests. In contrast, body 

mass declined for both species during 1-choice tests. Application of lime to enclosed 

10- x 10-m-grass plots in powder or slurry form at an application rate of 544 kg/ha also 

reduced goose feeding on treated plots for 2-3 days. Mean numbers of geese and 

mean fecal mass on control and treated plots were similar during both turf experiments. 

No phytotoxicity of grass was observed >40 days post treatment. We recommend 

additional studies to determine the lower limit of repellency of lime to various bird 

species and its utility for turf and crop damage reduction. 

22. Blackwell, B. F., G. E. Bernhardt, and R. A. Dolbeer. 2002. Lasers as nonlethal avian repellents. Journal of Wildlife Management 66(1):250-258. Abstract: 

Lasers have been demonstrated to be potentially effective avian repellents; however, 

studies combining adequate controls and replication that test such applications of lasers 

in wildlife management have not been reported. We conducted 2-choice cage tests to 

quantify the effectiveness of a 10-mW, continuous wave, 633-nm laser as a visual 

repellent (treating a perch) against brown-headed cowbirds (Molothrus ater) and 

European starlings (Sturnus vulgaris), and a 68-mW, continuous wave, 650-nm laser in 

dispersing (i.e., targeting birds with the laser) starlings and rock doves (Columba livia) 

from perches and Canada geese (Branta canadensis) and mallards (Anas 

platyrhynchos) from grass plots. All experiments were conducted under low ambient 

light (≤3 lx) conditions. In 3 experiments with stationary and moving laser beams 

treating a randomly selected perch, brown-headed cowbirds were not repelled. 

Similarly, a moving beam did not repel European starlings from treated perches, nor 

were they dispersed when targeted. Rock doves exhibited avoidance behavior only 

during the first 5 min of 6 80-minute dispersal periods. Notably, 6 groups of geese (4 

birds/group) exhibited marked avoidance of the beam during 20-min periods (n = 23), 

with a mean 96% of birds dispersed from laser-treated plots. Six groups of mallards (6 
306 Evaluations of Control Products Appendix L 

birds/group) were also dispersed (x= 57%) from treated plots during 20-minute periods 

(n = 12), but habituated to the beam after approximately 20 min. We contend that 

lasers will prove useful as avian repellents, but further controlled studies are needed to 

evaluate species-specific responses relative to laser power, beam type, wavelength, 

light conditions, and captive versus field scenarios.

23. Blackwell, B. F., T. W. Seamans, and R. A. Dolbeer. 1999. Plant growth 

regulator enhances repellency of anthraquinone formulation to Canada geese. 

Journal of Wildlife Management 63:1336-1343. Abstract: There is a need for 

nonlethal methods of reducing conflicts between burgeoning populations of resident 

Canada geese (Branta canadensis) and humans at airports and other settings. An 

anthraquinone-based formulation (Flight ControlTM [FC], 50% anthraquinone [AQ], 

active ingredient) has shown promise in deterring grazing by Canada geese. We 

hypothesized that the addition of a plant growth regulator (StrongholdTM [SH]) might 

enhance the effectiveness of FC by minimizing the exposure of new, untreated grass. 

To isolate the effects of grass height, plant growth regulator, and the combination of a 

repellent with a plant growth regulator on grazing by geese, we conducted 3 

experiments, each using 24 geese in 6 18 x 31-m pens, in northern Ohio during 1998. 

We evaluated the response of geese to short (4-11 cm) and tall grass (16-21 cm) in a 9-

day test. Next, SH (applied at 1.2 L/ha) was evaluated as a grazing repellent in a 14-

day test. Finally, we evaluated the effectiveness of FC (2.3 L/ha), combined with SH 

(0.9 L/ha SH), as a grazing repellent in a 22-day test. We found no difference (P = 

0.53) in the number of geese per observation in tall- (1.7 ± 1.5; x ± SE) and short-grass 

plots (2.3 ± 1.5), nor in bill contacts per minute (P = 0.78) in tall- (12.6 ± 9.3) versus 

short-grass plots (11.1 ± 7.9). In the SH test, 14 days post application, mean grass 

height was 12.9 cm in untreated plots and 7.2 cm in treated plots. However, the 

number of geese per observation on untreated (1.8 ± 1.3) and treated plots (2.2 ± 1.3) 

did not differ (P = 0.57). Also, there was no difference (P = 0.71) in the number of bill 

contacts per minute in untreated (15.3 ± 9.9) and treated plots (18.1 ± 14.2). In 

contrast, over a 22-day FC/SH test, the mean number of geese per observation was 2.6 

times greater (P < 0.01) on untreated (2.9 ± 0.5) than on treated plots (1.1 ± 0.5). 

Further, the mean number of bill contacts per minute was 8.2 times greater (P < 0.01) 

on untreated (54.4 ± 11.2) than treated plots (6.6 ± 2.3). We observed no abatement in 

repellency 22 days post treatment. Thus, we conclude that SH greatly enhanced the 

repellency of FC to grazing Canada geese. The use of a plant growth regulator with FC 

should reduce goose foraging on turf.

24. Dolbeer, R. A., J. L. Belant, and L. Clark. 1993. Methyl anthranilate 

formulations to repel birds from water at airports and food at landfills. 

Proceedings of the Great Plains Wildlife Damage Control Conference 11:42-53. 

Abstract: We conducted 2 sets of experiments to evaluate methyl anthranilate (MA) as 

an avian repellent. The first set (May-Aug 1991) evaluated 2 Rejex-ItTM formulations of 

MA applied to water at John F. Kennedy International Airport (JFKIA), New York. Our 

second set of experiments (Aug-Sep 1992) tested the hypothesis that MA mixed with a 

landfill cover material (ConCover 180R) would reduce consumption by birds when 

applied to food in a controlled environment (captive birds in cages). At JFKIA, fewer 

birds were seen in treated standing water than in untreated water, which supported 
Appendix L Evaluations of Control Products 307

results obtained in previous cage trials. In the landfill cover experiments, MA was 

repellent to cowbirds and ring-billed gulls at food sources, although a higher 

concentration (0.5% MA) was required to repel ring-billed gulls than cowbirds (0.15% 

MA). Cowbirds were repelled by similar concentrations of MA during tests using millet 

mixed with ConCover 180R. MA appears promising as a bird repellent when applied to 

standing water and may help deter birds from feeding in landfills when incorporated into 

a landfill cover material such as ConCover.

25. Dolbeer, R. A., T. W. Seamans, B. F. Blackwell, and J. L. Belant. 1998. 

Anthraquinone formulation (Flight Control) shows promise as avian feeding 

repellent. Journal of Wildlife Management 62:1557-1563. Abstract: We evaluated 

the effectiveness of Flight ControlTM [FC] (50% anthraquinone [AQ]) as a grazing 

repellent for Canada geese (Branta canadensis) and as a seed-treatment repellent for 

brown-headed cowbirds (Molothrus ater) in northern Ohio in 1997. For the turf test, FC 

was applied at 4.5 L/ha in 6 18.3- ∗ 30.5-m pens. There were 2.5 times more (P < 0.01) 

bill contacts/min observed on untreated plots (26.4 ± 6.0; x ± SE) compared to treated 

plots (10.4 ± 3.8) during a 7-day test with captive geese. Mean numbers of geese per 

observation were also greater (P = 0.02) on untreated plots (2.6 ± 0.4) compared to 

treated plots (1.4 ± 0.4). Residue analyses indicated AQ declined from 2.02 kg/ha at 

application to 0.22 kg/ha after 1 week. Individually caged cowbirds were presented 

untreated millet or millet treated with FC at 0.1, 0.5 and 1.0% (g/g) levels in 1- and 2-

choice tests for 3--4 days. Flight ControlTM was repellent to cowbirds at all levels in both 

1- and 2-choice tests. In the 2-choice test, birds in the 1.0% treatment level lost body 

mass (P = 0.04), whereas birds at the other levels did not. Each group of treated birds 

in the 1-choice test lost mass (P ≤ 0.01), whereas the control group did not. Birds in the 

0.5 and 1.0% groups ate minimal amounts; 3 of 12 birds died. We conclude that FC 

was an effective foraging repellent for Canada geese in a 7-day pen experiment and for 

brown-headed cowbirds as a seed repellent in aviary experiments. Flight ControlTM 

shows promise as an avian feeding repellent. Further lab and field studies are needed 

to refine minimum repellent levels and to enhance retention of AQ on treated 

vegetation. 

26. Seamans, T. W. 2004. Response of roosting turkey vultures to a vulture 

effigy. Ohio Journal of Science 104:136-138. Abstract: Increasing populations of 

turkey vultures (Coragyps atratus) and black vultures (Cathartes aura) cause concerns 

for human health and safety in areas where large roosting concentrations occur. Dead 

bird effigies are one proposed method of dispersing roosting vultures. In 1999 and 

2000, tests were conducted using a supine and hanging turkey vulture effigy (a 

taxidermy mount) to disperse a vulture roost in a tower in northern Ohio. In all tests, 

fewer (P [ 0.04) vultures were observed in the roost during the treatment period when 

compared to the pretreatment period. In tests ending in fall migration the posttreatment 

period differed (P < 0.01) from the pretreatment period. In tests ending in summer the 

pre- and posttreatment periods did not differ (P > 0.23). Vulture effigies are promising 

tools that may be used as part of integrated programs to disperse vultures from problem 

roosting sites. 
308 Evaluations of Control Products Appendix L 

27. Seamans, T. W., and G. E. Bernhardt. 2004. Response of Canada geese to a 

dead goose effigy. Pages 104-106 in Proceedings of the 21st Vertebrate Pest 

Conference. University of California, Davis. Abstract: The North American Canada 

goose population increased at a rate of 10.5%/year, 1966 - 2001. Canada geese rank 

as the third most hazardous species in regards to collisions with aircraft. Sound 

Canada goose management tools are critical for a safer airport environment. We 

conducted field evaluations of a Canada goose effigy during the breeding season with 

territorial pairs and with post-fledging flocks in late summer to determine if geese were 

deterred by the effigy. No difference in territorial pairs was found between pretreatment 

and treatment periods for Canada geese when goose effigies were placed within their 

territories. In post-fledging flocks the mean number of geese observed during 

pretreatment (74.9 ± 12.9), treatment (14.8 ± 4.5), and post treatment (53.6 ± 14.2) 

periods differed (P < 0.01). There was no difference (P = 0.56) between the mean 

number of geese observed during a second round of 5-day pretreatment (58.7) and 5-

day second round treatment (43.7) periods. By itself, the goose effigy was not effective 

as a Canada goose deterrent after approximately 5 days. However, this effigy may 

have some potential in an integrated goose control program conducted outside of the 

breeding season. Further evaluation of the effigy as part of an integrated Canada 

goose control program is recommended.

28. Seamans, T. W., B. F. Blackwell, and J. T. Gansowski. 2002. Evaluation of 

Allsopp Helikite as a bird scaring device. Proceedings of the Vertebrate Pest 

Conference 20:129-134. Abstract: We evaluated the effectiveness of Allsopp Helikites 

as a gull (Larus spp.) deterrent at loafing and nesting areas and as a bird deterrent in a 

sunflower field. In 1998, a 10-day trial was conducted at 2 0.5 ha ponds at the Erie 

County, Ohio landfill (EC) and a 2-week trial on 2 0.1 ha plots on the Tru-Serv 

Corporation (TSC) warehouse roof in Cuyahoga County, Ohio. Also in 1998, a 5-week 

trial in a sunflower field was conducted in Erie County, Ohio. In 1999, a 24-day trial was 

conducted at the Service Liqueur Distributors (SLD), Inc. warehouse roof, 1.6 km from 

the Albany, NY landfill. At the EC LANDFILL the mean number (± SE) of ring-billed (L. 

delawarensis) and herring gulls (L. argentatus) on the treated pond decreased (P < 

0.05) from 421 ± 292 to < 1 after Helikite deployment. Whereas the mean number of 

gulls on the untreated pond increased (P < 0.05) from 73 ± 135 to 412 ± 456. At the 

TSC roof, the herring gull nest density differed (P < 0. 01) between areas covered and 

not covered by Helikites. Nest density under Helikites decreased from 41/ha to 18/ha 

within 7 days of deployment. Nest density in areas not covered by Helikites increased 

from 23/ha to 42/ha within 14 days of deployment. At the SLD warehouse, when 

Helikites were not in place, the mean number (! SD) of gulls on the roof was 41 (! 38). 

When Helikites were in place, no gulls were observed on the roof at any time. Mean 

damage to sunflower heads remained similar in the Helikite-treated and untreated plots 

until the last week of measurement when damage in the untreated plot increased to 26 

% seed loss/head whereas damage in the treated plot remained at about 8 %. Helikites 

are a high-maintenance tool and are limited by weather conditions, electrical lines and 

structures that can damage Helikites. We conclude that Allsopp Helikites have the 

potential to deter gulls from preferred loafing and nesting areas and could be included 

as part of an integrated management program to disperse gulls. Further research on 

Helikites is needed to determine optimum deployment heights, habituation rates for 
Appendix L Evaluations of Control Products 309

gulls and other species and the actual sphere of influence of the kite for various 

species. 

29. Woronecki, P. P., R. A. Dolbeer, T. W. Seamans, and W. R. Lance. 1992. 

Alpha-chloralose efficacy in capturing nuisance waterfowl and pigeons and 

current status of FDA registration. Proceedings of the Vertebrate Pest 

Conference 15:72-78. Abstract: During 1990 and 1991 we conducted safety, efficacy 

and clinical trials required to register alpha-chloralose (A-C) for capturing nuisance 

waterfowl and pigeons with the U.S. Food and Drug Administration (FDA). We 

determined the Most Effective Dose (MED) to be 30 and 60 mg of A-C/kg of body 

weight for capturing waterfowl and pigeons, respectively. We conducted 11 field trials in 

4 states, capturing 587 waterfowl and 1,370 pigeons with 8% mortality for ducks, 0% for 

geese, and 6% for pigeons. We submitted a New Animal Drug Application to FDA in 

October 1991 and received registration in 1992 for use of A-C by Wildlife Services 

biologists. 

DEER

30. Belant, J. L. and T. W. Seamans. 2000. Comparison of three devices to 

observe white-tailed deer at night. Wildlife Society Bulletin 28(1):154-158. 

Abstract: To further reduce deer-aircraft collisions, a method for observing deer on 

airports at night that does not affect aircraft operations is required. We compared the 

effectiveness of forward-looking infrared (FLIR), spotlight, and night vision goggles 

(NVG) to monitor the abundance of white-tailed deer (Odocoileus virginianus) along a 

10-km route in Ohio during 12 nights in winter (Jan-Feb) and summer (Jul) 1997. 

Numbers of deer observed with FLIR (825 in winter, 570 in summer) and spotlight (716 

and 445) were similar (P>0.05); number of deer observed with NVG (243 and 152) was 

less (P<0.05) in winter and summer. The FLIR provided the best overall observability of 

deer of the 3 devices tested. The FLIR was less affected than spotlights by inclement 

weather and was not obtrusive. Biologists working in suburban areas or on airports can 

use FLIR to detect deer in areas where a spotlight would be inappropriate. Under 

conditions tested, we do not recommend using NVG to detect white-tailed deer at night.

31. Belant, J. L., T. W. Seamans, and C. P. Dwyer. 1996. Evaluation of propane 

exploders as white-tailed deer deterrents. Crop Protection 15:575-578. Abstract: 

In response to increased white-tailed deer (Odocoileus virginianus) depredation of 

agricultural crops and encroachment on airports, we evaluated the effectiveness of 

systematic and motion-activated propane exploders as deer frightening devices. We 

conducted 3 experiments in a 2200-ha fenced facility in northern Ohio with high 

(91/km2

) deer densities during 1994-1995. Systematic exploders were calibrated to 

detonate once at 8- to 10-minute intervals whereas motion-activated exploders 

detonated 8 times/deer intrusion. Systematic propane exploders were generally 

ineffective, deterring deer from corn for <2 days only, whereas motion-activated 

exploders repelled deer for 0-6 weeks. Repellency of motion-activated exploders varied 

seasonally, possibly in response to variations in deer density, availability of alternate 

food, or reproductive and social behavior. We recommend motion-activated exploders 

over systematic exploders as deer frightening devices for crop damage mitigation and 

on airports; however, systematic exploders may have utility for short-term (a few days) 

use.
310 Evaluations of Control Products Appendix L 

32. Belant, J. L., T. W. Seamans, and C. P. Dwyer. 1998. Cattle guards reduce 

deer crossings through fence openings. International Journal of Pest 

Management 44:247-249. Abstract: In response to increased white-tailed deer 

(Odocoileus virginianus) encroachment on airports, we evaluated the effectiveness of 

cattle guards as deer exclusion devices. We conducted 3 experiments in a 2,200 ha 

fenced facility in northern Ohio with high (91/km2

) deer densities during 1994-1995. 

During each experiment, we monitored deer crossings at 2-3 cattle guards (4.6 

[L]x3[W]x0.5 or 1.0[D] m) constructed at fence openings for 2 weeks pre- and postinstallation. For each experiment, the mean daily number of deer crossings after 

installation of cattle guards was reduced (P < 0.01) by >88% compared to respective 

crossing rates during pretreatment. Reductions in deer crossings using cattle guards 

with 0.5 or 1.0 m deep excavations were similar (95-96% vs. 98%) overall. Cattle 

guards at permanent openings used for vehicular traffic appear a viable technique to 

exclude deer from fenced airports and other facilities where deer exclusion is desired. 

33. Belant, J. L., T. W. Seamans, and L. A. Tyson. 1997. Evaluation of three 

electronic frightening devices as white-tailed deer deterrents. Proceedings of the 

Vertebrate Pest Conference 18:107-110. Abstract: We evaluated the effectiveness of 

the motion-activated Usonic Sentry (with and without strobe), motion-activated Yard 

Gard, and Electronic Guard for deterring white-tailed deer (Odocoileus virginianus) from 

preferred feeding areas during February-April 1996. We conducted 2 4-week 

experiments, monitoring deer use (number of intrusions and corn consumption) at 8 

feeding stations in a 2,200-ha fenced facility in northern Ohio with high deer densities 

(>38/km2

). During these experiments, we positioned 1 of the devices at each of 4 sites. 

The mean (+ SE, n = 4) daily number of deer intrusions at feeding stations during 

treatment (96.5 + 12.6-169.0 + 22.0) was similar (P > 0.13) to or greater (P < 0.04) than 

the mean daily number of deer intrusions during pre- or posttreatment (109.8 + 15.6-

148.8 + 21.4). Corn consumption declined (P < 0.05) only at stations with Usonic 

Sentrys without strobes for 1 week. We conclude that the electronic frightening devices 

tested were generally ineffective in deterring white-tailed deer from preferred feeding 

areas. 

34. Belant, J. L., T. W. Seamans, and L. A. Tyson. 1997. Predator urines do not 

deter white-tailed deer from feeding areas or trails. Proceedings of the Vertebrate 

Pest Conference 18:359-362. Abstract: We assessed whether bobcat (Lynx rufus) or 

coyote (Canis latrans) urine could reduce white-tailed deer (Odocoileus virginianus) use 

of established feeding areas or trails. A 4-week experiment evaluating deer use of 8 

feeding stations, 4 each with coyote or bobcat urine was conducted at a 2,200-ha 

fenced facility in northern Ohio with high deer densities (38/km2

). At this same facility, 

we also monitored deer use of 4 trails where coyote urine was applied. For both 

experiments, urine was placed in holders positioned at ground level within 2 m of the 

area being protected . The number of deer entering feeding stations after 2 weeks 

exposure to predator urines was 15-24% less (P < 0.05) than the number of deer 

entering feeding stations during pretreatment. Deer use of trails did not decrease in 

response to presence of coyote urine. We conclude that predator urines used as a 

chemical barrier were of limited effectiveness in deterring high concentrations of whitetailed deer from areas with established sources of food and ineffective in deterring deer 

from trails. 
Appendix L Evaluations of Control Products 311

35. Belant, J. L., L. A. Tyson, T. W. Seamans, and S. K. Ickes. 1997. Mylar flags 

do not deter white-tailed deer from feeding areas. Journal Wildlife Research 

2:210-212. Abstract: We evaluated the effectiveness of mylar flags for deterring whitetailed deer (Odocoileus virginianus) from feeding areas during December 1996. We 

conducted a 3-week experiment, monitoring deer use (number of intrusions and corn 

consumption) at 10 feeding stations in a 2,200-ha fenced facility in northern Ohio with 

high deer densities (>21/km2

). We positioned 2 mylar flags (15 cm x 1 m) attached to 

lathe at each of 5 sites; remaining sites received lathe only (untreated). Mylar flags did 

not reduce (P > 0.43) the number of deer intrusions into feeding stations or the amount 

of corn consumed relative to feeding stations without mylar flags. We conclude that 

mylar flags are ineffective for deterring white-tailed deer from feeding areas during 

winter. 

36. Seamans, T. W., B. F. Blackwell, and J. D. Cepek. 2002. Coyote hair as an 

area repellent for white-tailed deer. International Journal of Pest Management 

48(4):301-306. Abstract: Increasing white-tailed deer (Odocoileus virginianus) 

populations create numerous conflicts with agricultural production and transportation 

safety. Lethal control is not always an option and area repellents, such as predator 

waste products, have generally shown limited effectiveness. We tested coyote (Canis 

latrans) hair as a repellent at feeding stations during the winters of 2000 and 2001 and 

along established deer trails during the summer of 2000 in northern Ohio. Feeding 

station experiments were conducted in which five treatment sites received one or three 

bags containing 17 g of coyote hair placed adjacent to or in front of a trough of whole 

kernel corn and five control sites received empty bag(s). In all feeding trials, corn 

consumption decreased at treated sites from 59 - 91%. Intrusions by deer at treated 

sites decreased by 48 - 96% in three tests but did not vary in the first 3-week test when 

coyote hair was adjacent to the corn. Corn consumption and deer intrusions at control 

sites generally remained constant or showed an increase over the test period. In the 

deer trail test, use of trails did not differ between the pre-treatment and treatment 

periods for the control or treated trails. Coyote hair therefore served as an effective 

repellent to keep deer from a desired food source and should have utility in protecting 

limited, discrete sites. However, coyote hair did not deter deer from moving along 

established trails. 

HABITAT MANAGEMENT AND MISCELLANEOUS

37. Barras, S. C., M. S. Carrara, R. A. Dolbeer, R. B. Chipman, and G. E. 

Bernhardt. 2000. Bird and small mammal use of mowed and unmowed 

vegetation at John F. Kennedy International Airport, 1998 to 1999. Proceedings 

Vertebrate Pest Conference 19:31-36. Abstract: We evaluated bird and small 

mammal use of two mowed (15 to 25 cm height) and two unmowed vegetation plots (40 

to 88 ha) at John F. Kennedy International Airport (JFKIA), New York, in 1998 to 1999 

to determine which management strategy would best reduce wildlife use of the airport. 

We counted more birds per 5-minute observation period in unmowed plots than mowed 

plots in both 1998 (9.0 versus 7.9) and 1999 (11.7 versus 8.6). Maximum vegetation 

height was greater (P<0.05) for unmowed areas than mowed areas after mowing 

commenced in 1998 and 1999 for each two-week monitoring period. In 1998 to 1999, 

vegetation density was also higher (P<0.05) for unmowed plots for 13 of 14 sampling 
312 Evaluations of Control Products Appendix L 

periods. The species composition of vegetation differed (X2=20.54, df=3, P<0.01) 

among mowed and unmowed plots. Mowed plots contained a higher percentage of 

grasses (81% versus 68%), and a lower percentage of forbs (16% versus 25%) and 

woody plants (1% versus 4%) than unmowed plots. Vegetation was generally sparse in 

both unmowed and mowed plots, a consequence of the poor, sandy soils on much of 

the airport. We captured 33 small mammals from three species in unmowed plots and 

12 individuals of one species in mowed plots in 1999. Small mammal populations 

increased seasonally in unmowed plots, but remained constant in mowed plots over the 

same time period. We recommended JFKIA switch from the unmowed vegetation 

management regime in place since 1986 to a regime of maintaining vegetation mowed 

at 15 to 25 cm height. This management strategy should reduce bird and small 

mammal use of grassland areas at JFKIA. Further research should examine use of 

alternative vegetation types to improve ground cover and vegetation density at JFKIA 

while minimizing attraction to wildlife. 

38. Barras, S. C. and T. W. Seamans. 2002. Habitat management approaches for 

reducing wildlife use of airfields. Proceedings of Vertebrate Pest Conference 

20:309-315. Abstract: Wildlife-aircraft collisions (wildlife strikes) pose safety risks to 

aircraft and cost civil aviation over $390 million annually in the USA. We reviewed 

published studies to summarize findings on habitat management techniques that have 

shown potential for wildlife strike reduction. Habitat components that may attract wildlife 

to airports include food, cover, water, and loafing areas. Although maintaining tall 

herbaceous vegetation on airfields may reduce the attractiveness of loafing and feeding 

sites for some species of birds such as gulls, this strategy may also increase cover and 

food resources for other hazardous species. Thus, optimum vegetation height 

management strategies require further research and may be site-specific. Replacing 

attractive vegetation with less palatable vegetation has also been recommended, but 

studies with widespread application are lacking. Removal of ornamental trees and 

shrubs reduces cover for deer and small mammals and nesting sites for birds while also 

reducing availability of perches. However, exclusion techniques are also needed for 

reducing the availability of artificial perches and water. Despite more than 30 years of 

substantive discussion on the importance of these habitat management techniques, few 

reliable studies of the effectiveness of these techniques have been conducted under 

operational airport conditions. 

39. Gabrey, S. W., and R. A. Dolbeer. 1996. Rainfall effects on bird-aircraft 

collisions at two United States airports. Wildlife Society Bulletin 24:272-275. 

Abstract: We examined the influence of rainfall on bird-aircraft collisions at 2 major 

United States airports. Presence of standing water from rainfall did not increase the 

probability of bird-aircraft collisions at John F. Kennedy International airport during AprilOctober, 1986-1990. However, at O’Hare International Airport there was evidence that 

standing water increased collision rates. During April-October 1992-1994, collision 

rates were higher 1 day after >2.54 cm rain than at other times. Although this analysis 

showed no clear-cut influence of rainfall on bird-aircraft collisions, airport operations 

personnel, as precautionary measures, should continue efforts to remove standing 

water and deter bird use of puddles. Detailed long-term data on daily bird-aircraft 

collisions, rainfall, and bird use of standing water are needed from other airports so that 
Appendix L Evaluations of Control Products 313

a more comprehensive and generalized analysis of collisions in relation to rainfall can 

be made.
314 Evaluations of Control Products Appendix L 

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 315

APPENDIX M: 

A Wetland Banking Mitigation Strategy For FAA 
 316 Appendix M 

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Appendix M 317

A WETLAND BANKING MITIGATION STRATEGY FOR FAA 

JULY 1996 

Ed Melisky, Office of Airport, Community and Environmental Needs Division (APP-600), 

Ann Hooker, Office of Environment and Energy (AEE-300), and Jerry Schwartz, Office 

of Communications, Navigation, and Surveillance Systems (AND-420). 

III. Is Wetland Mitigation Banking New To The FAA? 

4. Ensure That The Wetland Banker Has Posted An Appropriate Environmental 

Performance Bond. 

Federal Aviation Administration, 800 Independence Avenue SW, Washington, DC 

20591 (202-267-5869). 

TABLE OF CONTENTS 

Preface 

I. What Is Wetland Mitigation Banking? 

II. Why Would The FAA Or An Airport Sponsor Want To Use Wetland Mitigation 

Banking? 

IV. Banking Sounds Like A Good Idea 

V. Are FAA Programs Or Airport Sponsors Required To Use Wetland Mitigation 

Banking For All Actions Affecting Wetlands? 

VI. Who Is Responsible For Maintaining A Wetland Bank? 

VII. What Is Sequencing? 

1. Evaluate Practicable Alternatives. 

2. Minimize Unavoidable Adverse Impacts. 

3. Compensate Wetland Impacts That Do Occur. 

VIII. If An FAA Service Or Airport Sponsor Chooses To Use A Wetland Mitigation Bank, 

How Does It Decide If A Bank Is Acceptable For FAA Purposes? 

1. Ensure That The Bank Does Not Pose A Threat To Aviation 

2. Consult The Appropriate Wetland Resource Agencies. 

3. Select Only Corps-Approved Wetland Banks. 

5. Exercise Fiduciary Responsibilities. 

IX. How To Determine The Number Of Credits That Must Be Purchased. 
318 Wetland Banking Appendix M 

X. How Will The FAA Or An Airport Sponsor Purchase Credits For A Wetland 

Mitigation Bank? 

1. Protection From Bank Failures. 

2. Protection From Wildlife Hazards. 

I. WHAT IS WETLAND MITIGATION BANKING? 

XI. What Happens To The Bank When All Of Its Credits Are Sold? 

PREFACE. 

This document describes the concept of wetland mitigation banking and how the FAA 

and airport sponsors can use this newly accepted mitigation strategy to more efficiently 

meet Section 404 permit requirements and environmental responsibilities. Wetland 

mitigation banking, although not a new ecological idea, is rapidly gaining support from 

all levels of government and private developers because it offers a proven, costeffective way to compensate successfully for unavoidable wetland impacts. An example 

of this recent acceptance is the November 28, 1995, joint issuance of wetland banking 

guidance by five federal agencies that once held widely divergent views on wetland 

banking. 

This document does not provide instructions on implementing a wetland banking 

strategy, since each FAA service has specific operating procedures to accomplish its 

respective mission. Instead, this document provides information and "ground rules" that 

each service should follow as it "custom designs" wetland banking instructions that 

meet the service's particular needs. 

This document does not discuss building a wetland bank, but, instead, emphasizes and 

provides information on purchasing credits from an agency or person or "banker" 

operating such a facility. Operating a wetland bank requires extensive knowledge of 

complex wetland management techniques and specially trained personnel. Since the 

primary mission of the FAA and airport sponsors is aviation, the purchase of credits 

from a wetland banker frees the FAA and airport sponsors to concentrate on the 

complex business of managing aviation, not the complex business of managing 

wetlands. Anyone wishing to build a wetland bank should contact environmental 

specialists in the Office of Airports (202-267-5869) or the regional Army Corps of 

Engineers (COE) office for information. 

Wetland mitigation banking provides a way to mitigate unavoidable wetland impacts 

before those impacts occur. Purchasing credits from a bank does not give the 

purchaser title to wetlands tracts that comprise a bank. Rather, the purchase is simply 

a payment to the wetland banker for wetland mitigation services that the bank provides. 

To establish a wetland bank, the banker owning and/or managing the bank can restore, 

enhance, or create wetlands within a watershed or region. Implementing one of these 

measures or a combination of them is necessary to replace the wetland functions lost 

due to constructing a project within a wetland. In rare instances, preserving existing, 

high quality wetlands is an acceptable banking plan, but this is rarely the case because 

it does not truly meet the President's "no net loss" policy for wetlands. Once a bank is 

established and the COE has approved the bank's use, the banker is allowed to sell 
Appendix M Wetland Banking 319

credits from the bank to 404 permittees (see section II). The sale of credits from a bank 

signifies that the bank is capable of: 

• replacing wetland functions in a watershed where unavoidable development of a 

wetland occurs; or 

• providing wetland functions that are necessary to achieve a designated wetland 

management plan in the affected watershed. 

II. WHY WOULD THE FAA OR AIRPORT SPONSOR WANT TO USE WETLAND MITIGATION 

BANKING? 

Section 404 of the Clean Water Act requires any one seeking authority to dredge and/or 

fill a wetland (404 permittee) to obtain a Section 404 permit before conducting those 

activities. One of the steps in the 404 permit application process requires the permit 

applicant to show that the proposed action includes ways to minimize unavoidable 

wetland impacts. This is where wetland banking plays a role. 

• Banking provides FAA program offices and airport sponsors with a strategy for 

satisfying resource agency demands and mitigating wildlife and wetland impacts, while 

reducing wildlife and bird hazards to aviation. 

• Because banking enhances the probability that FAA or an airport sponsor will obtain 

Section 404 permits in a more timely manner, the FAA or airport sponsor would be 

better able to meet tight construction deadlines more often and to complete essential 

projects more quickly. 

• The purchase of credits from a wetland bank absolves the FAA or a project sponsor of 

the responsibility for undertaking, monitoring, and maintaining a complex, often difficult, 

wetland mitigation plan. As a result, the FAA and the airport sponsor can focus 

If the COE issues a 404 permit authorizing dredge and/or fill activities in a wetland, that 

permit will probably contain requirements compelling the permittee to implement a plan 

to reduce the project's unavoidable wetland impacts. Because wetlands are 

ecologically complex and dynamic, the development of a wetland mitigation plan 

capable of replicating or replacing lost functions is often the most difficult and time 

consuming step of the 404 permit process. For most aviation-related projects built in 

wetlands, the FAA program office or the airport sponsor, as the permittee, is responsible 

for complying with permit required mitigation measures. Wetland banking will help FAA 

program offices and airport sponsors to satisfy 404 permit conditions in a cost-effective 

and efficient manner. 

Wetland banking will enable the FAA to achieve the President’s regulatory streamlining 

efforts and to achieve the Administration's long-term goal of increasing the quality of the 

Nation's wetlands. In addition, wetland mitigation banking has the following potential 

benefits: 

• Banking can increase the quality of the Nation's wetlands. 

• Banking is part of DOT's strategy to take a pro-active approach in 

addressing environmental issues and improving its working relationships with federal, 

state, local, and private agencies responsible for protecting wetlands. 
320 Wetland Banking Appendix M 

primarily on aviation needs, not on managing a wetland. 

III. IS WETLAND MITIGATION BANKING NEW TO THE FAA? 

• FHWA's financial participation in the establishment of wetland mitigation banks for 

highway projects throughout the USA. 

• The purchase of thousands of wetland acres in Florida by aviation departments to 

mitigate project-related wetland impacts. 

• The State of Florida's acceptance of the Walker Ranch Bank to show that a privately 

financed bank can be used to mitigate successfully unavoidable impacts to thousands 

of acres of Florida wetlands. 

IV. BANKING SOUNDS LIKE A GOOD IDEA. 

• Since the price of credits from a particular bank are known, banking can greatly 

enhance the ability of FAA program offices or airport sponsors to estimate the financial 

costs of mitigating unavoidable project-related wetland impacts. 

Yes, but it isn't new to land developers, who have used wetland banks for the past 10 to 

15 years. What is new is the acceptance of wetland banking by state governments and 

federal agencies. These parties now realize that wetland banking offers far greater 

ecological benefits than many of the on-site strategies commonly used today to mitigate 

wetland impacts. Examples of this new way of thinking are: 

• The development of regulations and guidelines governing wetland banking by the 

federal government and the states of California, Florida, Maryland, Minnesota, and 

Oregon. 

• The commitment of The Urban Land Institute, an organization of federal and state 

agencies, private land developers, and environmental groups, to provide administrative 

support, expertise, and a forum that allows interested parties to discuss openly and 

constructively their respective wetland mitigation banking concerns and problems. 

• The Administration's commitment to wetland banking by convening a federal interagency task force that developed mutually acceptable banking guidelines. 

• The Federal Highway Administration's (FHWA) program to encourage the use of 

wetland banks for roadway projects and its issuance of banking guidelines. 

In response to the President's support for wetland banking, the COE, the National 

Resources Conservation Service (formerly the Soil Conservation Service), EPA, the 

U.S. Fish and Wildlife Service, and the National Marine Fisheries Service have 

embraced wetland banking and have issued final guidelines (Federal Register, Vol. 60, 

No. 228, November 28, 1995). California, Florida, Minnesota, and other states have 

recognized the value of banking and actively promote it. 

To protect wetlands, Executive Order 11990 and various regulations require 404 permit 

applicants to ensure that federal agencies complete the sequencing procedure (item 

VII). This safeguard should suffice to ensure that the selected wetland site is truly the 

only practicable alternative that would meet a proposed project's specifications, 

purpose, and need. In addition, the inter-agency wetland mitigation banking guidelines 

require the COE and other federal resource agencies to oversee the permit process to 
Appendix M Wetland Banking 321

ensure that sequencing occurs and to ensure that the banks successfully mitigate 

wetland impacts. 

V. ARE FAA PROGRAMS OR AIRPORT SPONSORS REQUIRED TO USE WETLAND MITIGATION 

BANKING FOR ALL ACTIONS AFFECTING WETLANDS?

No. Banking is strictly a voluntary way to satisfy wetland mitigation requirements. The 

FAA and airport sponsors may continue to engage in more traditional wetland mitigation 

approaches. Different mitigation strategies may be pursued for different programs or 

projects. Appropriate wetland banks may not always be available. In summary, each 

FAA program office or airport sponsor has the option of using or not using wetland 

banking for each project under its purview. 

If the 404 permit applicant chooses to use wetland mitigation banking, he/she may 

consider two options: 

• Under option one, the 404 permit applicant may propose to build a wetland 

bank within the same watershed as the proposed project and use credits from that bank 

to mitigate unavoidable wetland impacts resulting from proposed and future actions. 

The COE must approve the use of the banked credits as mitigation for wetland functions 

or values lost due to each particular project. In this situation, the permittee is 

responsible for wetland success. 

Note: FAA offices and airport sponsors are less likely to choose option one. The 

complex, dynamic nature of wetlands requires specialists in wetland management. The 

FAA and sponsors normally don't possess this expertise, so wetland banking option 

Two (below) would be the more likely choice. 

• Under option two, the 404 permit applicant can agree to purchase a specific 

number of credits from a bank owned by another party, provided the bank is in the same 

watershed as the proposed project and the permitting agency approves such a 

measure. Here, the banker is responsible for wetland success. 

Here are two examples of the available wetland mitigation options: 

An airport development project: 

An airport sponsor proposing a new runway knows that constructing this facility would 

require filling 50 acres of wetland and that a taxiway proposed for construction 2 years 

later would require the filling of 10 additional wetland acres. To mitigate these impacts, 

the sponsor can select one of the following options and present it to the COE for 

approval: 

• mitigate wetland impacts by traditional replacement methods that are consistent with 

FAA safety concerns (i.e., new wetlands should not be established in areas where they 

could create hazards to aviation); 

• establish a 60-acre bank offsite before beginning construction of either project; or 

• buy 60 credits from an acceptable, offsite wetland bank that is owned by a wetland 

banker who meets the criteria in item VIII. 

NOTE: 1:1 impact: compensation ratios in the above examples are sometimes, but not 

always, acceptable. 
322 Wetland Banking Appendix M 

Siting a FAA facility: 

The division office planning to site a radar at a preferred location knows that 

construction specifications would require the filling of 2.2 acres of wetlands for 

foundations to support the radar's superstructure and pilings to support a 0.5-mile long 

access road. To mitigate these impacts, the program manager could select one of the 

options discussed above to offset the 2.2-acre loss. 

VI. WHO IS RESPONSIBLE FOR MAINTAINING A WETLAND MITIGATION BANK? 

When a 404 permittee such as an FAA program office or airport sponsor purchases 

credits from a bank meeting the criteria in section VIII., the banker operating that bank is 

solely responsible for maintaining the bank, ensuring that it is fully-functional and that it 

meets its intended purposes. Those purposes are clearly stated in a Memorandum of 

Understanding between the banker and the COE. If the COE authorizes the 404 

permittee to use a designated bank, the purchase of credits from that bank fulfills the 

permittee's wetland mitigation obligations. The permittee has no further wetland 

mitigation responsibilities. 

VII. WHAT IS SEQUENCING? 

Sequencing is a federally-required, analytical procedure that all 404 permit applicants 

must complete as part of the 404 permit application process. This process follows a 

similar process required by the regulations implementing the National Environmental 

Policy Act (see Council on Environmental Quality regulations at 40 CFR section 

1502.2(f)). Before using banking or any other measure to mitigate wetland impacts, the 

404 permit applicant must complete the sequencing procedures described below. 

1. Evaluate practicable alternatives. When proposing an action that would affect 

wetlands, section 2 of Executive Order 11990 and paragraph 5 of DOT's wetland order 

(5660.1A) require the appropriate FAA program office to demonstrate that there are no 

practicable alternatives that avoid the wetland. For DOT purposes, a practicable 

alternative is an alternative that is feasible when safety, transportation objectives, 

design, engineering, environment, and economics are considered. If a practicable 

alternative exists, the Executive Order and the DOT order require the FAA decision 

maker to select it. DOT's wetland order states that additional project expenses to 

mitigate wetland impacts or to implement an alternative do not make the mitigation or 

alternative impractical, since such expenses are normally considered necessary to meet 

national wetland policy objectives. 

2. Minimize unavoidable adverse impacts. The aviation safety or aeronautical design 

requirements of many facilities often do not allow the responsible FAA program 

office or airport sponsor to build a needed facility outside a wetland. For example, to 

meet location and distance specifications necessary for some radars to perform their 

aeronautical function properly, the radars must be built at specific locations, some of 

which may be in wetlands. When no practicable alternative outside a wetland exists 

because of radars' performance requirements, the responsible FAA program office 

must demonstrate that the radars have been designed to minimize wetland impacts to 

the greatest extent practicable. An example of a design consideration that would 

minimize unavoidable wetland impacts is to place radar supports on pilings, instead of 
Appendix M Wetland Banking 323

excavating and filling the wetland to accommodate a foundation for the supports. 

3. Compensate wetland impacts that occur. After modifying the design to minimize 

wetland impacts, the FAA program office or airport sponsor must then compensate for 

any remaining adverse wetland impacts that occur due to constructing, operating, 

and/or maintaining the proposed facility. At this point, wetland banking is a mitigation 

option. 

VIII. IF AN FAA SERVICE OR AIRPORT SPONSOR CHOOSES TO USE A WETLAND MITIGATION 

BANK, HOW DOES IT DECIDE IF A PARTICULAR BANK IS ACCEPTABLE FOR FAA PURPOSES?

To meet the provisions of this strategy, the FAA program office or airport sponsor must 

complete the following steps before purchasing credits from a bank. 

• 10,000 feet of a runway that serves turbine-powered aircraft. 

NOTE: These distances are based on a study completed by the Office of Airports' 

Airport Safety and Operations Division (AAS-300) that assessed aircraft approach and 

takeoff profiles and bird flight behavior . 

1. Ensure that the bank does not pose a threat to aviation. Wetlands and wetland 

banks provide excellent habitats for birds and wildlife hazardous to aviation. Although it 

is ecologically desirable to restore or enhance affected wildlife habitat at or near the 

project site to maintain ecological functions in a watershed, aircraft accident 

investigations have shown that hazardous wildlife attracted to wetland habitats near 

airports sometimes collide with aircraft causing costly damage to aircraft or injury or 

death to aircraft occupants. Therefore, to minimize wetland-related risks to aviation 

safety, FAA program offices and airport sponsors are strongly encouraged not to 

establish a bank or purchase credits from banks that are located within: 

• 5,000 feet of a runway that serves piston-powered aircraft; or 

FAA program offices and airport sponsors may consider using a wetland bank not 

meeting these distance criteria only when the bank provides special ecological functions 

such as: 

• maintaining habitat essential to federally-listed endangered or threatened species; or 

• maintaining unique wetland functions (e.g., aquifer recharge, flood control, filtration). 

When these special ecological functions exist, the FAA program office or airport 

sponsor should consult AAS-300 at (202) 267-3389. AAS can provide 

recommendations for a wildlife hazard management plan to protect aviation safety. 

2. Consult the appropriate wetland resource agencies. A 404 permit applicant must 

consult with the COE, the U.S. Fish and Wildlife Service, (the National Marine Fisheries 

Service when marine mammals or anadromous fish species are involved), the EPA, and 

the state agency having jurisdiction over the affected wetland. Consultation should 

focus on the agencies' respective concerns for wetland values and functions that the 

proposed project would affect and any applicable watershed or ecosystem conservation 

plans. Agencies should state if they will accept wetland banking as appropriate 

mitigation; however, as the ultimate 404 authority, the COE is responsible for 

authorizing the use of a particular bank and determining the number of credits required. 
324 Wetland Banking Appendix M 

3. Select only COE-approved wetland banks. For permitting purposes, the COE will 

not allow a permittee to use a wetland bank that does not meet the success criteria 

stated in the Memorandum of Understanding (MOU) between the COE and the banker 

that establishes the wetland bank. If the 404 permittee chooses to buy credits available 

from a bank owned by another agency or a private entity, the responsible FAA program 

office must have written proof that the COE has approved the bank. This provision 

ensures that permittees will be dealing with a reputable wetland banker who has met 

federal wetland mitigation guidelines. 

NOTE: For projects in Michigan and New Jersey, consult with the state wetland 

permitting agency. The COE and EPA have authorized these states to administer the 

Section 404 permitting process for wetland actions within respective state boundaries. 

5. Exercise fiduciary responsibilities. As a federal agency entrusted with allocating or 

using federal funds, the FAA program office must be financially responsible when 

mitigating wetland impacts or providing money to do so. Although wetland impacts 

must be properly mitigated, the program office must ensure that it does not overpay for 

credits purchased from a bank. FAA project offices or airport sponsors should negotiate 

with the permitting and resource agencies to ensure that the number of credits 

purchased fairly reflects unavoidable project-related wetland impacts. They should also 

negotiate to secure a fair price for those credits. 

In most cases, the COE will base success on a wetland bank's ability to provide those 

wetland functions that resource agencies have determined are necessary to protect a 

particular ecological system or watershed. Examples of such functions are floodwater 

retention, sediment control, providing fishery or wildlife nursery areas, removing toxic 

substances, or aquifer recharge. If the permittee will purchase credits from a banker, 

the banker should provide written assurances that the wetland mitigation bank will be 

self-sustaining within 3 to 5 years, the period during which most wetlands become selfsustaining. 

4. Ensure that the wetland banker has posted an appropriate environmental 

performance bond. When purchasing credits from a bank meeting the criteria 

discussed in the above items, the FAA program office or airport sponsor must also 

ensure that the banker has posted an environmental performance bond equal to 100% 

of the cost needed to build or establish a bank that meets the objectives stated in the 

MOU. This bond ensures that sufficient money is available for the wetland bank to meet 

the success criteria in item 3., if the banker goes out of business or declares 

bankruptcy. The banker should provide written proof of bonding to the FAA or airport 

sponsor. 

IX. HOW TO DETERMINE THE NUMBER OF CREDITS THAT MUST BE PURCHASED. 

Determining the number of credits that must be purchased is done on a case-by-case 

basis. This should be a point of negotiation among the 404 permitting agency, other 

resource agencies, and the 404 permittee. Experience shows that the number of 

credits purchased should be based on the functions lost or diminished due to project 

construction, the functions that the bank provides, and/or the role that surrounding 

upland areas play in increasing the bank's overall ecological functions. Examples of 

compensation : impact ratios (usually expressed in acres) are: 
Appendix M Wetland Banking 325

4:1 when credits are sold to create a buffer between a wetland and other uses; 

3:1 when credits are sold to protect uplands essential to wetland survival; 

2:1 when credits are sold in a bank being established; or 

1:1 when credits are sold in a functioning bank; 

NOTE: Actual negotiations may result in different ratios!! The above ratios are based 

on information from workshops and discussions with wetland bankers and wetland bank 

customers. They are presented only as generic guidelines. 

do so via a legally binding purchasing contract. Contract signatories should include the 

404 permitting agency (usually the COE), the appropriate resource agencies, the 

wetland banker, the responsible FAA program office and, when appropriate, the airport 

sponsor. The contract should contain the following contingencies to protect FAA 

funding and aviation safety. 

• the purchase of a specified number of credits from the named bank completely

X. HOW WILL THE FAA OR AN AIRPORT SPONSOR PURCHASE CREDITS FROM A WETLAND 

MITIGATION BANK? 

When the FAA program office or airport sponsor purchases credits from a bank, it will 

Protection against wetland bank failure. This contingency is necessary to protect the 

FAA from spending additional funds on wetland mitigation after it has provided funds to 

purchase the permit-required number of bank credits. This contingency verifies that if a 

bank failure occurs, the FAA program office or the airport sponsor is not accountable for 

any future wetland mitigation requirements that are needed to satisfy the applicable 

permit. The purchasing instrument should contain the following statements:

satisfies the permittee's wetland mitigation responsibilities; and 

• in the event of a bank failure or bankruptcy, the permittee is not responsible for any 

future financial responsibilities or other liabilities needed to mitigate wetland impacts 

that result from a 404 permit-authorized action. 

2. Protection from wildlife hazards. Written verification that the bank is not within the 

5,000 or 10,000-foot criteria discussed earlier (see section VIII) shows that the bank 

providing the credits should not pose hazardous conditions to aviation. 

XI. WHAT HAPPENS TO THE BANK WHEN ALL OF THE BANK'S CREDITS ARE SOLD? 

Once the COE determines that a bank is self-sustaining, and the banker has sold all of 

its available credits, the banker has at least three options to ensure the wetland exists in 

perpetuity: 

• retain ownership of the wetland bank and continue to manage it; 

• transfer ownership of the wetland bank to a state or a Native American tribe, if either 

party desires to take possession of the bank to enhance its wetland sources; or 

NOTE: In situations where a wetland fulfills unique functions, such as serving as 

recharge areas for water supply aquifers or as habitat for federally-listed endangered or 

threatened species, the above distance criteria may not be applicable. In such cases, 

contact AAS-300 for assistance. 
326 Wetland Banking Appendix M 

• transfer the wetland bank to an environmental group whose primary mission is to 

protect wetlands and/or wildlife habitat. 

Organizations having expertise in wetland management, such as state wetland or 

wildlife agencies or The Nature Conservancy, often seek title to banks, since their 

primary missions are to protect valuable wetland functions and habitats. 

A NOTE REGARDING AIP-FUNDED CREDIT PURCHASES. When the FAA approves an airport 

development project that causes wetland impacts and requires the sponsor to mitigate 

those impacts, the airport sponsor may recover the costs of establishing a wetland bank 

or purchasing credits from a wetland bank. AIP funds can be used to reimburse the 

sponsor for the cost of building only that portion of its wetland bank that is used to 

mitigate impacts resulting from a specific, FAA-approved action. The cost of building 

the entire wetland bank is not AIP reimbursable, unless other FAA-approved airport 

developments use the remainder of the bank to mitigate wetland impacts. AIP funds 

may also be used to reimburse the sponsor for purchasing a specified number of credits 

from a bank owned by another party to mitigate project-specific wetland impacts 

resulting from FAA-approved airport actions. 
 327

APPENDIX N: 

Liability Issues For Airport Managers Related To Wildlife 

Hazards 
 328 Appendix N 

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Appendix N Liability Issues 329

Bird and Other Wildlife Hazards at Airports: Liability Issues for Airport 

Managers

Richard A. Dolbeer, PhD 

6100 Columbus Avenue 

U.S. Department of Agriculture/Wildlife Services 

National Coordinator, Airport Safety and Assistance Program 

Sandusky, OH 44870 USA

richard.a.dolbeer@usda.gov

Aircraft collisions with birds (bird strikes) and other wildlife are a serious economic and 

safety problem. The problem has increased in the past decade because of expanding 

populations of many wildlife species that are hazardous to aviation (Dolbeer and 

Eschenfelder 2002). Cleary et al. (2004) estimated wildlife strikes (98% involving birds) 

cost the civil aviation industry in the USA about $500 million/year, 1990-2003. Allan and 

Orosz (2001) estimated that bird strikes annually cost commercial air carriers over $1.2 

billion worldwide, 1999-2000. At least 194 people died and 164 aircraft were destroyed 

as a result of bird and other wildlife strikes with civil and military aircraft from 1988-2004 

(Richardson and West 2000, Thorpe 2003, Cleary et al. 2004, Dolbeer unpublished 

data). 

Questions are often asked about liability issues related to wildlife strikes. To help clarify 

this complex legal subject, I have listed below several cases involving wildlife strikes 

where liability issues related to airport management have been raised. This is not a 

complete list of liability cases and is not intended as a legal review of the cases 

presented. These cases are presented simply as an overview of potential liability 

issues that airport managers may face as a result of wildlife strikes on or near their 

airports. 

26 February 1973. Atlanta, Georgia, USA. On departure from Dekalb-Peachtree 

Airport, a Learjet 24 struck a flock of brown-headed cowbirds attracted to a nearby 

trash-transfer station. Engine failure resulted. The aircraft crashed, killing 8 people and 

seriously injuring 1 person on the ground. This incident prompted the Federal Aviation 

Administration to develop guidelines concerning the location of solid-waste disposal 

facilities on or near airports. The incident generated a lengthy legal case called the 

“Miree” litigation in which the court finally determined that the airport manager could be 

held liable for failing to take the precautions possible at his level to end bird hazards 

(Michael 1986). 

12 December 1973. Norwich, England. A Falcon Business Jet with 9 people on 

board struck common and black-headed gulls on takeoff from Norwich Airport. The 

strike caused severe damage to both engines. One minor injury resulted from the crash 

which destroyed the aircraft. The judge presiding over the case wrote that the 
330 Liability Issues Appendix N 

Defendants (airport operator) owed the Plaintiffs (aircraft operator and occupants) the 

“common duty of care”. After weighing the considerable evidence, the judge decided 

that the Defendants failed in their duty, and that there must be judgment for the Plaintiffs 

for damages. In other words, the airport operator failed to show due diligence in 

managing the airport’s bird hazards (Michael 1986, MacKinnon et al. 2001). 

14 June 1975. Watertown, South Dakota, USA. A NA265 Sabreliner twin-engine jet 

ingested gulls in both engines at rotation from the Watertown Airport. The aircraft 

crashed, both wings were torn off, and a severe fire ensued. Three of the 6 people on 

board were injured and the aircraft was destroyed. The Safeco Insurance Company 

brought an action against the airport operator, the City of Watertown. The court 

maintained that the proximate cause of the crash was the failure to warn the pilot of the 

presence of birds. Judgment for the full value of the destroyed aircraft was entered 

against the airport operator (Michael 1986, MacKinnon et al. 2001). 

12 November 1975. New York, New York, USA. An Oversees National Airlines DC10-30 ingested several gulls into the #3 engine during the takeoff run at John F. 

Kennedy International Airport. The engine caught fire, several wheels and tires 

disintegrated, and the landing gear collapsed during the aborted takeoff. The aircraft 

then caught fire and was destroyed. Miraculously, the 139 passengers and crew (all 

ONA employees being ferried overseas) were able to escape the burning aircraft. 

There were 30 injuries but no deaths. The National Transportation Safety Board noted 

ineffective control of bird hazards by the airport as one of the contributing factors to the 

accident. A complex legal battle ensued in 1979 with ONA and the Bank of America 

(aircraft owner) suing the FAA, the Port Authority of New York and New Jersey, New 

York City (because of two landfills near the airport), and several aerospace companies 

in Federal or State courts. The total settlement, reached in 1985, was in excess of $15 

million. Amounts paid by each party and their insurance companies are not known 

(Aviation Week and Space Technology 1977, U.S. Court of Appeals 1985).

7 June 1989. Genoa, Italy. A BAE 146 operated by TNT Air Cargo departing Genoa 

Airport at night flew through a flock of gulls at rotation. The pilot managed to return the 

severely damaged aircraft to the airport. Three engines were damaged. The carrier 

sued a number of entities for damages resulting from this bird-strike event at the airport. 

A decision on this case, pronounced by the Civil Court of Genoa in 2001 after 11 years 

of litigation, awarded the carrier $2 million in compensation. Liability was assigned as 

50% to the Ministry of Transport, 30% to the private company operating the airport, and 

20% to the Port Authority (Battistoni 2003). 

11 January 1990. Nashville, Tennessee, USA. A Hawker-Siddeley 125 jet with 4 

people on board hit a deer on takeoff from John Tune Airport. The impact tore one of 

the engines loose from the plane. The experienced pilot was able to get airborne and 

fly to nearby Nashville International Airport where an emergency landing was made. 

Ren Corporation (owner of jet) sued the Metropolitan Nashville Airport Authority and 

John Tune Aviation Corporation for damages to cover the cost of replacing the $1.4 

million plane and chartering another plane until a replacement plane was acquired 

(Nashville Tennessean 1990). The lawsuit was won in trial court, but lost in the 

Tennessee Court of Appeals (Gilbert 2004). The ruling was based on the Tennessee 

Governmental Tort Liability Act (TGTLA) capping government liability for property 
Appendix N Liability Issues 331

damage to $50,000 (Neill 2003). 

20 January 1995. Paris, France. A Dassault Falcon 20 business jet struck lapwings 

during takeoff from Le Bourget Airport. The pilot was unable to control the jet after the 

ingested birds destroyed the left engine. The aircraft crashed, killing all 10 people 

aboard. A subsequent inquiry found that airport staff failed to perform routine birdscaring operations prior to the accident. In 1998, French authorities laid charges of 

involuntary manslaughter against the Paris Airport Authority and 3 former officers for 

their roles in the accident. The airport authority was accused of “negligently failing to 

follow normal security procedures.” The disposition of the case is not known at this time 

(MacKinnon et al. 2001). 

3 June 1995. New York, New York, USA. An Air France Concorde, at about 10 feet 

AGL while landing at John F. Kennedy International Airport, ingested 1 or 2 Canada 

geese into the #3 engine. The engine suffered an uncontained failure. Shrapnel from 

the #3 engine destroyed the #4 engine and cut several hydraulic lines and control 

cables. The pilot was able to land the plane safely, but the runway was closed for 

several hours. Damage to the Concorde was estimated at over $7 million. The French 

Aviation Authority sued the Port Authority of New York and New Jersey and eventually 

settled out of court for $5.3 million (MacKinnon et al. 2001). 

22 September 1995. Elmendorf Air Force Base, Alaska, USA. A U.S. Air Force 

Airborne Warning and Control System (AWACS) aircraft (modified Boeing 707) crashed, 

killing all 24 on board, after ingesting 4 Canada geese into the #1 and #2 engines during 

takeoff from Elmendorf Air Force Base. Investigators found the “worst possible 

combination of operational conditions” including infrequent and inadequate wildlife 

patrols. Furthermore, the senior tower controller was reported by witnesses as saying 

he "observed geese lift off and turn directly into the path of the aircraft." When 

interviewed, the senior controller and another controller on duty at the time of the 

accident (both of whom "had an excellent view of the runway”) invoked their right to 

remain silent. The accident investigator concluded that controllers "had a duty to warn 

the flight crew and that failure to do so was a contributing factor to the accident" (Flight 

Safety Foundation 1996). One outcome of the investigation was that the people in the 

top 3 leadership positions at the air base were reassigned. 

13 November 1996. Pula International Airport, Pula, Croatia. A Croatia Airlines B737-200 ingested a gull into the #1 engine during the takeoff run at 1511 hours, causing 

an “insidious explosion” from the engine. The pilot was able to abort the takeoff, but the 

engine had to be replaced and the plane was out of service for 2 days. Croatia Airline’s 

insurer paid the airline for the damaged engine but then presented a bill to the airport for 

the cost of repairs. The airport refused to pay, claiming that the airport had fulfilled all 

the conditions for the protection of aircraft from wildlife (including a runway sweep at 

0430 hours) and that they had a permanent NOTAM to warn air carriers of 

concentrations of birds in the vicinity of the runway. The insurance company sued the 

Airport Authority in the Municipal Court of Pula. The Municipal Court dismissed the 

lawsuit, but on appeal, the County Court of Pula ruled in favor of the insurance 

company. An appeal of this decision by the airport was unsuccessful (18 April 2000), 

and the airport had to reimburse the insurance company for cost of engine repairs. The 

court noted that that the airport acknowledged that a problem existed by having a 
332 Liability Issues Appendix N 

permanent NOTAM regarding bird hazards, and yet failed to undertake all measures at 

its disposal to alleviate the hazard (Pula County Court 2000). 

22 March 1998. Marseille Provence Airport, France. An Air France A-320 

encountered a flock of about 20 gulls during the takeoff run, ingesting several birds into 

the #2 engine which was destroyed. The pilot executed a high-speed aborted takeoff. 

The gull strike was directly attributed to a dead hedgehog on the runway which the gulls 

were feeding on when the mishap occurred. The air carrier sued the French 

government for negligence in operating the airfield and in January 2005 was awarded 

$4 million USD (Agence France Presse 2005). The hedgehog had likely been struck by 

an earlier flight, but Airport Operations personnel had failed to remove the carcass. 

Conclusions:

Based on the cases presented above and legal or insurance reviews by Michael (1986), 

Wilkinson (1998), Robinson (2000), and Matijaca (2001), it is apparent that airport 

operators must exercise “due diligence” in managing wildlife hazards to avoid potentially 

serious liability issues. 

The exercise of “due diligence” to manage wildlife hazards involves (in the USA) the 

assessment of wildlife hazards at the airport and, if needed based on the assessment, 

the implementation of a wildlife hazard management plan (FAA regulations in CFR 14 

Part 139.337). An important component of the wildlife hazard management plan is the 

prevention of habitats and land uses on or in the vicinity of the airport that are attractive 

to hazardous wildlife. Wildlife hazard management at airports is a complex, publicsensitive, endeavor involving many species of wildlife and their habitats governed by 

various federal and state regulations. Airports need to employ professional biologists 

trained in wildlife damage control to assist in the development, implementation, and 

evaluation of wildlife hazard management plans. Such professionally developed and 

implemented management plans will minimize the likelihood of catastrophic or majordamage wildlife strikes on an airport and provide crucial support during litigation in the 

aftermath of any significant strike event that might occur. Cleary and Dolbeer (1999) 

provide detailed information on the development of these management plans as well as 

on FAA regulations and guidelines regarding wildlife hazards to aviation. 

Acknowledgments: I thank L. C. Francoeur, Port Authority of New York and New 

Jersey; A. Matijaca, Airport Split, Croatia; and A. L. Gosser, C. Washburn, and S. E. 

Wright, U.S. Department of Agriculture, for providing information and helpful comments 

during the compilation of these cases. 

References cited 

Agence France Presse. 2005. A dead hedgehog and a flock of seagulls cost France 3 

million euros after runway mishap. Marseilles, France. 1 February 2005. 

Allan, J. R., and A. P. Orosz. 2001. The costs of birdstrikes to commercial aviation. 

Pages 218-226 in Bird Strike 2001, Proceedings of the Bird Strike CommitteeUSA/Canada meeting. Calgary, Alberta, Canada: Transport Canada, Ottawa, 

Ontario Canada. 

Aviation Week and Space Technology. 1997. Recommendations made in ONA crash. 
Appendix N Liability Issues 333

August 15, Page 61. 

Battistoni, V. 2003. Bird strikes in courts: the Genoa case. Pages 169-174 in 

Proceedings of the 26th International Bird Strike Committee meeting (Volume 1). 

Warsaw, Poland. 

Cleary, E. C., and R. A. Dolbeer. 1999. Wildlife hazard management at airports, a 

manual for airport personnel. U.S. Department of Transportation, Federal 

Aviation Administration, Office of Airport Safety and Standards, Washington, DC 

USA 248 pages (http://wildlife-mitigation.tc.faa.gov/). 

Cleary, E. C., R. A. Dolbeer, and S. E. Wright. 2004. Wildlife strikes to civil aircraft in the 

United States, 1990-2003. U.S. Department of Transportation, Federal Aviation 

Administration, Serial Report No. 10, DOT/FAA/AS/00-6(AAS-310). Washington 

DC USA. 55 pages (http://wildlife-mitigation.tc.faa.gov/). 

Dolbeer, R. A., and P. Eschenfelder. 2002. Population increases of large birds, 

airworthiness standards, and high-speed flight: a precarious combination. Pages 

273-281 in Proceedings of the 55th International Air Safety Seminar, Dublin, 

Ireland (Copyright Flight Safety Foundation, Alexandria, Virginia USA). 

Flight Safety Foundation. 1996. Military Boeing 707 strikes birds after liftoff; damages to 

engines no. 1 and no. 2 results in loss of power and impact with terrain. Accident 

Prevention. Volume. 53, Number 11. 

Gilbert, Harris A. 2004. Attorney representing REN Corp. Personal communication.23 

January. 

MacKinnon, B., R. Sowden, and S. Dudley (Editors). 2001. Sharing the skies: an 

aviation guide to the management of wildlife hazards. Transport Canada, 

Aviation Publishing Division, Tower C, 330 Sparks Street, Ottawa, Ontario, K1A 

0N8 Canada. 316 pages. 

Matijaca, A. 2001. Damage liability and compensation in case of bird strike. Pages 89-

100 in Bird Strike 2001. Proceedings of the Bird Strike Committee-USA/Canada 

meeting, Calgary, Alberta. Transport Canada, Ottawa, Ontario Canada. 

Michael, R. A. 1986. Keep your eye on the birdie: aircraft engine bird ingestion. Journal 

of Air Law and Commerce. Space Law Issue. Summer 1986, Number 4:1007-

1035. 

Nashville Tennessean. 1990. Dialysis firm files suit after plane strikes deer. By Kirk 

Loggins, January.

Neill, R. 2003. Municipal and personal liability under the Tennessee Government Tort 

Liability Act. Municipal Technical Advisory Service (MTSA). [online] 

(www.mtas.utk.edu/knowledgebase.nsf/0/c0fead9bb6aca88685256d3600653d26

/$FILE/Governmental%20Tort%20Liability%20Act.pdf); accessed 23 January 

2004.

Pula County Court. 2000. Liability of Pula Airport for the damages from bird strikes. 

County Court, Pula, Republic of Croatia, case Gž-2141/00. 

Richardson, W. J., and T. West. 2000. Serious birdstrike accidents to military aircraft: 
334 Liability Issues Appendix N 

updated list and summary. Pages 67-98 in Proceedings of 25th International Bird 

Strike Committee meeting. Amsterdam, The Netherlands. 

Robinson, M. 2000. The duty of care—failure to maintain an effective “wildlife control 

programme” might result in significant legal liability consequences. Aon Group 

Limited, Aviation Reinsurance Department, 8 Devonshire Square, EC2M 4PL, 

London, UK (mike.robinson@aon.co.uk). 

Thorpe, J. 2003. Fatalities and destroyed aircraft due to bird strikes, 1912-2002. Pages 

85-113 in Proceedings of the 26th International Bird Strike Committee meeting 

(Volume 1). Warsaw, Poland. 

U.S. Court of Appeals for the Second Circuit. 1985. Overseas National Airways, Inc. 

Plaintiff, v. United States of America, Defendant-Third-party Plaintiff-Appellant, 

Port Authority of New York and New Jersey, Third–party Defendant-Appellant, 

and The City of New York, Third-Party Defendant-Appellee. Nos. 84-6232, 84-

6254 (Aug. term, 1984). Decided 27 June 1985. 

Wilkinson, C. 1998. Now aviation insurers must watch the birdie. Insurance Day. 

Lloyd’s of London Press Ltd, London, UK. 5 February. 2 pages. 
 335

APPENDIX O: 

Summary of Studies on Vegetation Management for North 

American Airfields 
 336 Appendix O 

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Appendix O 337

Summary Of Studies On Vegetation Management For 

North American Airfields 

Thomas W. Seamans 

USDA/APHIS/Wildlife Services, National Wildlife Research Center, 

Ohio Field Station, Sandusky, Ohio 44870 

Habitat management is a critical element in any wildlife hazard management program at 

an airport. Non-woody or herbaceous vegetation accounts for the majority of wildlife 

habitat at most airports. If this vegetation is not managed, the site will often become 

overgrown and attractive to wildlife that are hazardous to aircraft (Barras et al. 2000, 

Cleary et al. 2003). 

Vegetation management on many USA airports consists of mowing the vegetation to 

some set height. The Federal Aviation Administration has not specified the height that 

vegetation is to be maintained away from the movement area. One method often 

suggested for reducing bird numbers on airports is to maintain vegetation at 6-10 

inches, as opposed to standard mowing practices that maintain vegetation at 2-4 inches 

(Transport Canada 1994, US Department of Agriculture 1998, Civil Aviation Authority 

2002). Vegetation 6-10 inches high is thought to interfere with visibility and ground 

movements of flocking birds such as European starlings and gulls (Solman 1966, 

Blokpoel 1976). However, the scientific support for this height is based on studies done 

in Great Britain (Brough 1971, Mead and Carter 1973, and Brough and Bridgman 1980), 

in which bird species of concern in North America were not present. Many other 

sources recommend tall vegetation but do not present data to support the 

recommended height (Wright 1968, Creswell 1988, Blokpoel 1976, Burger 1983, 

Solman 1970, 1973, 1976, Transport Canada 1994, Dekker and van der Zee 1996, US 

Department of Agriculture 1998). In Great Britain, long-grass management involves a 

rigorous regime of mowing within a 2-inch window along with thatch and weed removal 

and the use of fertilizers to maintain an erect, dense stand of grass (Civil Aviation 

Authority 2002). North American airfields generally do not have similar vegetation 

management plans. Therefore, observations drawn from long-grass management in 

Great Britain must be applied cautiously in North America. 

Previous studies on tall vegetation management at airports in the United States have 

produced conflicting results (Buckley and McCarthy 1994, Seamans et al. 1999, Barras 

et al. 2000). Further, other published views that may not be scientifically defensible 

(Barras and Seamans 2002) have indicated that “tall vegetation” should not be on 

airfields (van Tets 1969, Solman 1970). Blokpoel (1976) indicated that vegetation 

height management should be dependent on the bird species using the airfield. 

Mowing has been shown to at least temporarily reduce small mammal populations 

(Wilkins and Schmidly 1979, Lemen and Clausen 1984, Grimm and Yahner 1988, Edge 

et al. 1995). Fewer small mammals may reduce the attractiveness of the area to birds 

of prey (e.g. red-tailed hawks, great-horned owls) and predatory mammals (e.g. 

coyotes) that pose hazards to aircraft (Phelan and Robertson 1977, Baker and Brooks 

1981a, Dolbeer et al. 2000). Should a small mammal population remain after mowing,
338 Airfield Vegetation Management Appendix O 

predators will be attracted to the area because of improved opportunity to capture prey 

due to the removal of protective overhead vegetation (Wakeley 1978, Baker and Brooks 

1981b, Bechard 1982, Preston 1990, Sheffield et al. 2001, Fitzpatrick 2003). It is also 

likely that small mammals in unmowed areas will exploit adjacent mowed areas (Cleary 

et al. 2003) due to a lack of competition in mowed areas. Therefore, despite the 

decrease in small mammals caused by mowing, the number or frequency of potential 

predators in this area could be higher because of the potential for efficient foraging 

along the edge of the two areas. To avoid this conflict, airports should mow all areas 

within their control. Additional small mammal control (e. g. using a rodenticide) may be 

necessary if mowing does not reduce the population to a point that the area becomes 

unattractive to predators. 

Vegetation density, structure, species composition and size of grassy areas have been 

shown to influence bird use of grasslands (Mead and Carter 1973, Frawley and Best 

1991, Delisle and Savidge 1997, Norment et al. 1999, Washburn et al. 2000, Johnson 

and Igl 2001). Ideally, vegetation found on airports should have low attraction to birds, 

small mammals and insects; have hardy growth and good survival; and provide good 

ground coverage without being a fire hazard (Austin-Smith and Lewis 1969). No 

published studies have been conducted on field evaluations that provide information on 

vegetation that meets these requirements. Initial pen trial results at the USDA National 

Wildlife Research Center (NWRC)/Ohio Field Station (OFS) using tall fescue containing 

the fungal endophyte (Neotyphodium coenophialum) indicate that Canada geese do not 

prefer to feed on the grass (Washburn and Seamans 2004). 

Research at the NWRC/OFS has shown that vegetation height alone does not reduce 

bird use of grassland areas (Seamans et al. 2005). Species-specific responses may be 

expected. For example, brown-headed cowbirds and American robins prefer short (<6 

in) vegetation, starlings do not differentiate between short (<6 in) and tall (>6 in) 

vegetation and eastern meadowlarks prefer tall (>6 in) vegetation. Airport managers 

need to work with airport wildlife biologists to determine what species of concern in 

regards to aircraft safety are in their area and what the habitat needs are for those 

species. 

Response of vegetation to mowing must also be considered. Some species of 

vegetation will not live if mowers are set below 4 inches. Drought conditions may also 

necessitate a change in timing of mowing or height of mowers in order to avoid causing 

vegetation die offs. 

Considering bird, mammal and vegetation limitations, mowing at least monthly at a 

target of 5 - 8 inches may work in many airport environments as part of a wildlife hazard 

management program. Most grasses used on airfields in non-arid habitats should be 

able to survive this mowing height. In addition, vegetation will be short enough to 

enable observers to see larger birds yet long enough to prevent birds that prefer short 

vegetation from using the area. However, starlings and meadowlarks will use both tall 

and short vegetation. Density and species of vegetation may limit both species use but 

these specifications have not been determined. Any area that has sparse vegetation 

will allow birds to move through or land. Mowing at 5 - 8 inches should also reduce 

small mammal abundance. 
Appendix O Airfield Vegetation Management 339

A dense, monotypic stand of vegetation that wildlife do not prefer for food or cover 

would be ideal airfield vegetation. Researchers will continue to work on this issue to 

find species that meet airport demands in the various regions of the United States. 

References 

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153—160 in Proceedings of the World Conference on Bird Hazards to Aircraft. 

Baker, J. A., and R. J Brooks. 1981a. Raptor and vole populations at an airport. 

Journal of Wildlife Management 45:390—396. 

Baker, J. A., and R. J Brooks. 1981b. Distribution patterns of raptors in relation to 

density of meadow voles. Condor 83:42—47. 

Buckley, P. A., and M. G. McCarthy. 1994. Insects, vegetation, and the control of 

laughing gulls (Larus atricilla) at Kennedy International Airport, New York City. 

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Kennedy International Airport, 1998-1999. Proceedings of the Vertebrate Pest 

Conference 19:31—36. 

Barras, S. C. and T. W. Seamans. 2002. Habitat management approaches for 

reducing wildlife use of airfields. Proceedings of the Vertebrate Pest Conference 

20:309—315. 

Bechard, M. J. 1982. Effect of vegetative cover on foraging site selection by 

Swainson’s hawk. Condor 84:153—159. 

Blokpoel, H. 1976. Bird hazards to aircraft. Clarke, Irwin and Company and Canadian 

Wildlife Service, Ottawa, Canada. 

Brough, T. E. 1971. Experimental use of long-grass in the U.K. Bird Strike Committee 

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Burger, J. 1983. Bird control at airports. Environmental Conservation 10:115—124. 

Civil Aviation Authority. 2002 Aerodrome Bird Control. CAP 680. Aerodrome 

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Sussex, UK. 

Cleary, E. C., R. A. Dolbeer, and P. R. Bastida. 2003. The Mexico City International 

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International Airport, New Zealand, between 1986 and 1988: implications for a 

preventative bird strike program. New Zealand Natural Sciences 15:61—70. 
340 Airfield Vegetation Management Appendix O 

Dekker, A., and F. F. van der Zee. 1996. Birds and grassland on airports. Bird Strike 

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Delisle, J. M, and J. A. Savidge. 1997. Avian use and vegetation characteristics of 

conservation reserve program fields. Journal of Wildlife Management 61:318—

325. 

Dolbeer, R. A., S. E. Wright, and E. C. Cleary. 2000. Ranking the hazard level of 

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342 Airfield Vegetation Management Appendix O 

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Appendix P: 

Title 14, Code of Federal Regulations, Part 139.337 
 344 Appendix P 

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Appendix P 14 CFR 139.337 345

Title 14, Code of Federal Regulations, part 139.337 

(a) In accordance with its Airport Certification Manual and the requirements of this 

section, each certificate holder must take immediate action to alleviate wildlife hazards 

whenever they are detected. 

(b) In a manner authorized by the Administrator, each certificate holder must ensure 

that a wildlife hazard assessment is conducted when any of the following events occurs 

on or near the airport 

(b) (1) An air carrier aircraft experiences multiple wildlife strikes: 

(b) (2) An air carrier aircraft experiences substantial damage from striking wildlife. 

As used in this paragraph, substantial damage means damage or structural failure 

incurred by an aircraft that adversely affects the structural strength, performance, or 

flight characteristics of the aircraft and that would normally require major repair or 

replacement of the affected component; 

(b) (3) An air carrier aircraft experiences an engine ingestion of wildlife; or 

(b) (4) Wildlife of a size, or in numbers, capable of causing an event described in 

paragraph (b)(1), (2), or (3) of this section is observed to have access to any airport 

flight pattern or aircraft movement area. 

(c) The wildlife hazard assessment required in paragraph (b) of this section must be 

conducted by a wildlife damage management biologist who has professional training 

and/or experience in wildlife hazard management at airports or an individual working 

under direct supervision of such an individual. The wildlife hazard assessment must 

contain at least the following: 

(c) (l) An analysis of the events or circumstances that prompted the assessment. 

c) (2) Identification of the wildlife species observed and their numbers, locations, 

local movements, and daily and seasonal occurrences. 

(c) (3) Identification and location of features on and near the airport that attract 

wildlife. 

(c) (4) A description of wildlife hazards to air carrier operations. 

(c) (5) Recommended actions for reducing identified wildlife hazards to air carrier 

operations. 

(d) The wildlife hazard assessment required under paragraph (b) of this section must 

be submitted to the Administrator for approval and determination of the need for a 

wildlife hazard management plan. In reaching this determination, the Administrator will 

consider—
346 14 CFR 139.337 Appendix P 

(d) (1) The wildlife hazard assessment; 

(d) (2) Actions recommended in the wildlife hazard assessment to reduce wildlife 

hazards; 

(d) (3) The aeronautical activity at the airport, including the frequency and size of air 

carrier aircraft; 

(d) (4) The views of the certificate holder; 

(d) (5) The views of the airport users; and 

(d) (6) Any other known factors relating to the wildlife hazard of which the 

Administrator is aware. 

(e) When the Administrator determines that a wildlife hazard management plan is 

needed, the certificate holder must formulate and implement a plan using the wildlife 

hazard assessment as a basis. The plan must— 

(e) (1) Provide measures to alleviate or eliminate wildlife hazards to air carrier 

operations; 

(e) (2) Be submitted to, and approved by, the Administrator prior to implementation; 

and 

(e) (3) As authorized by the Administrator, become a part of the Airport Certification 

Manual. 

(f) The plan must include at least the following: 

(f) (1) A list of the individuals having authority and responsibility for implementing 

each aspect of the plan. 

(f) (2) A list prioritizing the following actions identified in the wildlife hazard 

assessment and target dates for their initiation and completion: 

(f) (2) (i) Wildlife population management; 

(f) (2) (ii) Habitat modification; and 

(f) (2) (iii) Land use changes. 

(f) (3) Requirements for and, where applicable, copies of local, State, and Federal 

wildlife control permits. 

(f) (4) Identification of resources that the certificate holder will provide to implement 

the plan. 

(f) (5) Procedures to be followed during air carrier operations that at a minimum 

includes— 

(f) (5) (i) Designation of personnel responsible for implementing the 

procedures; 

(f) (5) (ii) Provisions to conduct physical inspections of the aircraft movement 

areas and other areas critical to successfully manage known wildlife hazards 

before air carrier operations begin; 
 347

(f) (5) (iii) Wildlife hazard control measures; and 

(f) (5) (iv) Ways to communicate effectively between personnel conducting 

wildlife control or observing wildlife hazards and the air traffic control tower. 

(f) (6) Procedures to review and evaluate the wildlife hazard management plan 

annually or following an event described in paragraphs (b)(1), (2), and (3) of this 

section, including: 

(f) (6) (i) The plan's effectiveness in dealing with known wildlife hazards on 

and in the airport's vicinity and 

(f) (6) (ii) Aspects of the wildlife hazards described in the wildlife hazard 

assessment that should be reevaluated. 

(f) (7) A training program conducted by a qualified wildlife damage management 

biologist to provide airport personnel with the knowledge and skills needed to 

successfully carry out the wildlife hazard management plan required by paragraph 

(d) of this section. 

(g) FAA Advisory Circulars contain methods and procedures for wildlife hazard 

management at airports that are acceptable to the Administrator. 
348 14 CFR 139.337 Appendix P 

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