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U.S. Department of Transportation

FEDERAL AVIATION ADMINISTRATION

Regulatory Evaluation

Safety Management System for Certificated 

Airports

Supplemental Notice of Proposed Rulemaking

(14 CFR Part 139)

Esther Barto

Jose Castedo

Nicole Nance

Office of Aviation Policy and Plans

Regulatory Analysis Division, APO-300
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TABLE OF CONTENTS

EXECUTIVE SUMMARY .......................................................................................................... 1

I. The Proposed Rule............................................................................................................ 4

II. Background ....................................................................................................................... 5

III. The Evolution of SNPRM................................................................................................. 6

IV. Costs and Benefits............................................................................................................. 9

A. Baseline .................................................................................................................................... 9

1. Baseline Costs.................................................................................................................. 9

2. Baseline Benefits...................................................................................11

B. Costs........................................................................................................................................ 13

1. SMS Manual and Implementation Plan ......................................................................... 16

2. New Staffing Requirements.....................................................................18

3. New Materials/Equipment ............................................................................................. 22

4. Training.......................................................................................................................... 23

5. Recording Potential Hazards................................................................. ..30

6. Documenting SRM and Reporting Safety Information ........................... .......31

7. Cost of Compliance..................................................................................................... 34

C. Benefits................................................................................................................................... 37 

1. Benefit Model and Assumptions.................................................................................... 42

2. Effectiveness.............................................................................. 44

3. Results for Each Database ............................................................. 48

4. Sensitivity Analysis ....................................................................................................... 56

5. Benefit-Cost Comparison............................................................................................... 57

V. NPRM Comments and FAA response................................................................................. 58

APPENDIX 1: Accident History .............................................................................................. 68

APPENDIX 2: Aircraft Values.................................................................................................. 91
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APPENDIX 3: Airport Groupings............................................................................................ 93

APPENDIX 4: Benefits............................................................................................................. 115

APPENDIX 5: Pilot Study Participate Breakout................................................................... 122

APPENDIX 6: Compilation of Pilot Study Documentation.................................................. 123
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EXECUTIVE SUMMARY

A safety management system (SMS) is a formalized approach to managing safety, which 

includes an organization-wide safety policy, formal methods of identifying potential hazards, 

formal methods for analyzing and mitigating potential hazards, and an organization-wide 

emphasis on promoting a safety culture. SMS for airports is comprised of four key components:

Safety Policy, Safety Risk Management (SRM), Safety Assurance, and Safety Promotion. These 

components will help airports effectively integrate the formal risk control procedures into normal 

operational practices, thus improving safety at airports throughout the U.S. air transportation 

system that host air carrier operations.

In the NPRM, the FAA proposed that all certificated airports be covered by the SMS 

requirements. Based on comments and information gathered from the FAA SMS pilot studies, it 

became evident that applying SMS across all certificated airports was not practical. In response, 

the FAA revised its assumptions used to calculate overall costs associated with this proposal. 

The FAA also reviewed additional accident and incident databases to obtain more accurate 

assumptions of benefits derived from an SMS. These additional databases included the FAA 

Accident and Incident Database (AIDS), NASA’s Aviation Safety Reporting System (ASRS), 

the FAA’s Wildlife Strike Database, and FAA’s Runway Incursion Database.

Using these revised cost and benefit estimates, the FAA explored various alternatives to 

determine how to apply an SMS requirement to a group of airports whose benefits justify its 

costs and harmonizes with international standards. The FAA focused on airports with the 

highest passenger enplanements and largest total operations so that safety benefits would flow to 

the overwhelming majority of aircraft operations in the United States. The FAA also focused on 

incorporating airports with international passenger operations to ensure conformity with

international standards and recommended practices. The FAA considered multiple alternatives 

for which part 139 certificate holders would be required to implement an airport SMS. The FAA 

analyzed the following alternatives:

 All Part 139 airports (as originally proposed in the NPRM);

 Airport operators holding a Class I airport operating certificate (AOC);

 Certificated airports identified by the U.S. Customs and Border Protection (CBP) 

as a port of entry (under 19 CFR § 101.3), designated international airport (under 
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19 CFR § 122.13), landing rights airport (under 19 CFR § 122.14), or as a user fee 

airport (under 19 CFR § 122.14) (also referred to collectively throughout this 

document as “international airports”); 

 Large, Medium, and Small hub airports (as identified in the National Plan of 

Integrated Airport Systems (NPIAS))

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and certificated airports with more than 

100,000 total annual operations; and

 Large, Medium, and Small hub airports (as identified in the NPIAS), certificated 

airports with more than 100,000 total annual operations, and international airports

Although an airport may belong in more than one classification, the analysis first 

removed multiple airport listings, and then summed benefits across unique airports (see table A.7

in Appendix 3 for airport classifications).

The goal of analyzing these alternatives is to adopt an alternative only upon a reasoned 

determination that its benefits justify its costs while harmonizing with international standards. 

While the FAA is proposing a preferred alternative, each alternative presents various trade-offs 

of interest to the public.

The following table shows benefits and costs of the alternatives over 10 years.

Comparison of Costs and Benefits over 10 years (2014 Dollars)

Base Case All Class I International L, M, S and 

>100K ops

Preferred 

alternative: L, 

M, S, >100K 

ops, and 

International

Benefits $382,987,281 $368,096,671 $360,907,166 $356,128,301 $370,788,457

Costs $471,104,787 $341,021,606 $215,010,997 $163,760,850 $238,865,692

Net Benefits -$88,117,506 $27,075,065 $145,896,169 $192,367,451 $131,922,764

PV Benefits (7%) $233,282,770 $224,210,033 $219,830,291 $216,919,352 $225,850,869

PV Costs (7%) $307,842,595 $223,584,687 $141,796,001 $108,819,973 $157,496,312

PV Net Benefits (7%) -$74,559,825 $625,346 $78,034,290 $108,099,379 $68,354,557

PV Benefits (3%) $307,499,272 $295,542,114 $289,769,378 $285,932,407 $297,704,052

 

1 The FAA’s use of the term hub airport is different than that of airlines, which use the term to denote an airport with 

significant connecting traffic by one or more carriers. The FAA’s authorizing statute defines Large hubs as those 

airports that each account for 1 percent or more of total U.S. passenger boardings (U.S. passenger enplanements). 

Medium hubs are defined as airports that each account for between 0.25 percent and 1 percent of total U.S. 

passenger boardings. Small hubs are defined as airports that enplane 0.05 percent to 0.25 percent of total U.S. 

passenger boardings.
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PV Costs (3%) $389,440,320 $282,304,199 $178,432,284 $136,340,226 $198,211,977

PV Net Benefits (3%) -$74,559,825 $625,346 $78,034,290 $108,099,379 $68,354,557

Mitigation Costs: Not quantified, estimates not included.

Given the range of mitigation actions possible, it is difficult to quantify potential benefits.

The estimated costs of this rule do not include the costs of mitigations that operators 

could incur as a result of conducting the risk analysis proposed in this rule. Given the range of 

mitigation actions possible, it is difficult to provide a quantitative estimate of both the costs and 

benefits of such mitigations. We anticipate that operators will only implement mitigations where 

benefits of doing so exceed the costs of the mitigations. In order for the estimated benefits to 

exceed the costs of the rule, the mitigation costs must be below $68.4 million over 10 years 

(discounted at 7%). The FAA requests comment on this assumption, as well as data regarding 

costs and benefits associated with any mitigations implemented through a voluntary SMS 

program. 

After evaluating the estimated costs and benefits of each alternative, the FAA’s preferred 

alternative, which is proposed in the SNPRM, is to require SMS implementation for (i) Large, 

Medium, and Small hub certificated airports, (ii) certificated airports with more than 100,000 

total operations, or (iii) certificated airports accepting international aircraft operations.

This alternative covers 268 airports across Classes I, II, III, and IV. The airports that 

comprise this preferred alternative account for over 98% of all passenger enplanements in the 

U.S. While simply applying the proposed requirement to Large, Medium, and Small hub 

certificated airports would account for most of this traffic, many critical airports within the U.S. 

system would not be included because they do not meet those enplanement thresholds. Simply 

accounting for airports with higher passenger enplanements fails to acknowledge the many other 

complex certificated airports that have significant levels of total aircraft operations. 

Therefore, to ensure that these busy airports are included in the proposal, the preferred 

alternative includes airports with more than 100,000 total annual operations based on their 

operations data submitted through FAA Form 5010-1, Airport Master Record available on 

August 1, 2012. The FAA acknowledges that data submitted through FAA Form 5010-1 may 

include estimates for airports that do not have an air traffic control tower. While more definitive 

data may be available through the FAA’s air traffic control tower counts, this information may 
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not be readily available, may not be accessible to the public, and does not account for certificated 

airports that do not have an air traffic control tower. 

The pool of airports characterized as Large, Medium, and Small hub airports or 

certificated airports with more than 100,000 total annual operations is large, but still does not 

completely account for all certificated airports able to receive international traffic. In order to 

harmonize with the intent of the International Civil Aviation Organization (ICAO) SMS 

standards, the preferred alternative includes certificated airports accepting international 

operations. These airports together correspond with the intent of ICAO Annexes 14 and 19 

standards.

I. The Proposed Rule

This proposed rule would only require an SMS be developed, implemented, maintained, 

and adhered to at any certificated airport: 

 Classified as a Small, Medium, or Large hub airport in the NPIAS; 

 Identified as an international airport; or 

 Identified as having more than 100,000 total annual operations (according to best 

available data). 

The goal of this proposal is to improve the safety of their airfield environment (including 

movement and non-movement areas). The FAA is issuing this proposed rule under the authority 

described in Subtitle VII, part A, subpart III, section 44706, “Airport operating certificates.” 

SMS includes an organization-wide safety policy, formal methods for identifying hazards, 

analyzing and mitigating risks, and promotion of safety culture. When applied, SMS will 

improve safety by addressing underlying organizational issues that may result in accidents and 

incidents.

II. Background

A. What is a Safety Management System?
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SMS is a systematic and proactive approach to managing safety. SMS allows airports to 

discover and address safety issues before a noncompliant or unsafe condition results. 

Historically, the approach to aviation safety was based on analysis of past accidents and 

introduction of corrective actions to prevent the recurrence of those events.2 SMS, however, 

concentrates on controlling the development stages of safety management rather than solely 

relying on inspection and remedial actions. In its most general form, SMS is a set of decisionmaking processes and procedures that an airport would use to plan, organize, direct, and control 

its everyday activities in a manner that enhances safety. 

In 2001, ICAO adopted a standard in Annex 14 that requires all member countries to

establish SMS requirements for airport operators. The FAA supports conformity of U.S. aviation 

safety regulations with ICAO standards and recommended practices. The proposed rule meets 

the intent of the ICAO standard in a way that complements existing airport safety regulations in 

14 CFR part 139. The philosophy behind SMS for airports is that each airport can develop a 

management system to meet its own unique operating environment. Many airports already have 

functional occupational safety programs in place that have reporting, inspection, and training 

requirements. Airports can use these programs as a foundation for their operational SMS. For 

these reasons, the FAA proposes requirements that allow airports the maximum amount of 

flexibility to develop and achieve safety goals. Accordingly, this proposed rule would prescribe 

only the high level components and airports would be responsible for developing these

components into operational processes and procedures. SMS for airports would be comprised of 

four key components; Safety Policy, Safety Risk Management (SRM), Safety Assurance, and 

Safety Promotion. These four SMS components would offer an effective blueprint in managing 

and reducing the operational risks and are described below.

Safety Policy: Under safety policy, the certificate holder would establish a policy which, 

among other things, defines the certificate holder’s safety objectives, establishes a safety policy 

statement, defines the certificate holder’s management responsibilities and accountabilities for 

safety issues, and identifies and communicates the organization’s structure for handling safety 

issues. The certificate holder also would be required to designate an accountable executive to act 

on its behalf for the implementation and daily operation of the SMS.

 

2 http://onlinepubs.trb.org/onlinepubs/acrp/acrp_rpt_001a.pdf
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Safety Risk Management: Under SRM, the certificate holder would develop processes 

to identify hazards that may impact the airport’s operations. The certificate holder would use 

these processes to systematically analyze those hazards and their risks, as well as proactively 

mitigate risk. The certificate holder must retain any documentation developed through these 

processes to assist in trend and root cause analysis. 

Safety Assurance: Under safety assurance, the certificate holder would develop and 

implement processes to monitor the safety performance of its SMS. Additionally, the certificate 

holder would establish and maintain a hazard reporting system that provides reporters 

confidentiality when communicating safety issues to the system. The certificate holder’s staff 

would regularly update the accountable executive on pertinent safety information such as the 

certificate holder’s performance with regard to its safety objectives, safety critical information, 

the status of any ongoing mitigation established through safety risk management, and the status 

of implementing the SMS.

Safety Promotion: Under safety promotion, the certificate holder would identify 

managers and staff employees responsible for oversight and implementation of the SMS and 

would provide them training on their responsibilities and SMS implementation. For all other 

individuals with regular access to the movement and non-movement areas of the airfield, the 

certificate holder would develop and distribute hazard awareness and reporting orientation 

materials, ensuring those individuals are made aware of hazards and how to report them to the 

certificate holder’s hazard reporting system. The certificate holder would then keep records of 

training provided and hazard awareness materials for 24 calendar months. The certificate holder 

also would develop processes and procedures to communicate important safety information that 

ensures that all persons authorized access to the movement and non-movement areas are aware 

of the SMS and their safety roles and responsibilities. Feedback would be provided to 

individuals using the airport’s hazard reporting system and lessons learned relevant to airport 

employees or stakeholders would be communicated.

III. The Evolution of the SNPRM

The FAA has determined that an SMS would improve safety at certain part 139 

certificated airports. The FAA reached this conclusion based on detailed study of ICAO’s 
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Annexes 14 and 19 requirements, review of NTSB’s recommendations, and the airport SMS 

pilot studies. The FAA expects airports to benefit from increased communication, training, and 

reporting. Since SMS is scalable, airport characteristics, such as size, organizational and 

governance structures, type of air carrier operations, and number of operations, are factors that 

affect a certificate holder’s version of SMS. In an effort to allow for scalability of SMS in the 

NPRM, the FAA estimated the expected compliance cost by the number of 

enplanements/operations and by classes established for part 139 airport operating certificates. 

Under part 139, certificate holders are grouped into four classes based on the type of air carrier 

operations served and the number of passenger seats per aircraft. The airport classifications by 

air carrier operations are listed in the chart below.

Type of Air Carrier Operation3 Class I Class II Class III Class IV

Scheduled Large Air Carrier Aircraft (30+ seats) X

Unscheduled Large Air Carrier Aircraft (30+ seats) X X X

Scheduled Small Air Carrier Aircraft (10-30 seats) X X X

Using revised cost and benefit estimates, the FAA explored various alternatives to 

determine how to apply an SMS requirement to a group of airports that maximized benefits

relative to costs. The FAA focused on airports with high passenger traffic and large numbers of 

operations so that safety benefits would flow to the overwhelming majority of aircraft operations. 

The FAA also focused on incorporating airports with international passenger operations to 

ensure conformity with international standards and recommended practices. To that end, the 

FAA developed the following alternatives for additional analysis:

 All Part 139 airports;

 Airport operators holding a Class I AOC;

 Certificated international airports;

 Large, Medium, and Small hub airports and certificated airports with more than 

100,000 total annual operations; and

 

3 http://www.faa.gov/airports/airport_safety/part139_cert/?p1=classes
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 Large, Medium, and Small hub airports, certificated airports with more than 

100,000 total annual operations, and certificated international airports.

Because the FAA chose to analyze various alternatives based on classifications outside 

the scope of the NPRM (e.g., hubs or international status instead of AOC class), it relied on the 

best available information to develop the list of affected airports under each combination. To 

identify those airports classified as Large, Medium, or Small hubs, the FAA relied on the 2011-

2015 NPIAS, current at the time of this analysis. Similarly, the FAA used annual operations data 

reported by airport through FAA Form 5010-1, Airport Master Record. The FAA relied on data 

obtained from Title 19 of the Code of Federal Regulations (See §§ 101.3, 122.13, 122.14, 

122.15) and the U.S. Customs and Border Protection (CBP) to identify certificated airports 

authorized to accept international traffic.

After evaluating the estimated costs and benefits of each alternative, the FAA’s preferred 

alternative is to require SMS implementation for Large, Medium, and Small hub certificated 

airports, certificated airports with more than 100,000 total annual operations, and certificated 

airports accepting international aircraft operations. 

An airport can be a part of multiple alternatives. For example, Hartsfield-Jackson Atlanta 

International Airport (ATL) which is a Large hub airport, has more than 100,000 total annual 

operations, accepts international traffic, and is also a Class I airport. Therefore, ATL would 

appear in all five of the alternatives. Table A.7 in Appendix 3 denotes how each of the 544 part 

139 airports, current at the time of this analysis, is classified.

IV. Costs and Benefits

The objective of this analysis is to evaluate the costs and benefits of implementing an SMS 

for each of the following alternatives:

 All Part 139 airports; 

 Airport operators holding a Class I AOC; 

 Certificated international airports; 

 Large, Medium, and Small hub airports and certificated airports with more than 100,000 

total annual operations; and
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 Large, Medium, and Small hub airports, certificated airports with more than 100,000 total 

annual operations, and certificated international airports.

The analysis described in this regulatory evaluation is based on the following assumptions:

 Estimated costs and benefits are presented in 2014 dollars.

 Potential costs and benefits are estimated over a 10-year period from 2016 through 2025.

 Benefits of SMS implementation would begin to accrue in 2018 up to 2025.

 Costs to airports would begin to accrue in 2016.

 The present value discount rates of 7 percent and 3 percent are applied as required by the 

Office of Management and Budget.4

A. Baseline

1. Baseline Costs

Under Part 139, airports comply with the regulation through self-certification 364 days out of 

the year and then the FAA comes in on the 365th day to verify compliance. The airport typically 

uses a checklist that is very prescriptive and allows for little deviation. While airports currently 

maintain an FAA-approved Airport Certification Manual (ACM), employ resources and staffing 

to maintain compliance with their ACM and Part 139, train their staff, and record information 

like self-inspection results, an SMS would require proactive safety management through the 

identification and analysis of hazards.

Think of these proactive activities like closing the loop on safety. While an airport is 

currently required to conduct and report on daily self-inspections, under an SMS the airport 

would develop processes to identify hazards, analyze hazards, and mitigate identified risk. The 

FAA expects more information being reported than has been in the past. An example we often 

use with industry involves self-inspection and foreign object debris (FOD). Under today’s Part 

139 requirements, if an airport identifies FOD on a taxiway during its self-inspection, the vehicle 

operator usually picks up the FOD and disposes of it. Documenting issues such as these under 

an SMS can help airport management to know whether they have repetitive safety issues on the 

airfield. Similarly, most airports today do not have reporting systems that are available to all 

 

4 http://www.whitehouse.gov/omb/assets/regulatory_matters_pdf/a-4.pdf
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personnel with access to the airfield. With so few operations staff compared to other entities 

with personnel on the ramp and airfield areas, many more safety issues may be identified that the 

airport can take action on before they result in injury, damage, or fatalities.

The FAA learned through the pilot studies that proactive safety management really was a 

new activity for airports. While many of these airports had experience with risk management 

through their human resources and insurance departments, few employed these similar practices 

within their operational environments.

The Regulatory Evaluation for the proposed rule was based on the experiences and responses 

of the pilot study airports and takes into consideration any similar activities that airports 

currently employ for compliance with Part 139 like record keeping, training, and staffing. This 

information has been supplemented by comments received from the NPRM.

The following table compares the baseline to the costs of the regulation.

Factors Baseline SNPRM

Manual

Airport maintains an FAAapproved Airport Certification 

Manual (ACM) (see §139.201).

Airports would develop their 

implementation plan and amend 

their ACM and/or create SMS 

manuals.

Staffing

Airport provides sufficient and 

qualified personnel to comply with 

the requirements of its ACM and 

Part 139 (see §139.303(a)).

Some airports would need 

additional full-time and/or part 

time employees to oversee SMS

implementation.

Equipment

Airport provides sufficient 

equipment for personnel to 

comply with the requirements of 

its ACM and Part 139 (see 

§139.303(b)).

The FAA assumes that some of 

the airports would need new 

software, hardware or promotional 

material to establish and promote 

a hazard reporting system and to 

identify, analyze, and mitigate 

hazards when appropriate.
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Training

Airport trains all persons who 

access movement areas and safety 

areas and perform duties in 

compliance with requirements in 

the ACM and Part 139 (see 

§139.303(c)).

All airports would need to add 

SMS training and SMS e-learning 

for managers and safety staff.

Recordkeeping Potential Hazards

Airport maintains records for selfinspections, accidents and 

incidents, and Notices to Airmen 

(NOTAMs) as required under its 

ACM and Part 139 (see 

§139.301). Airports do not have 

hazard reporting systems for 

reporting of hazards by all 

individuals with access to the 

airfield.

All airports would add hazard 

reporting systems.

Documenting SRM and reporting 

safety information

Airports do not document SRM 

nor are required report safety 

information to their leadership.

Airports would document SRM 

and report safety information.

Mitigation Costs (Unquantified)

Airports are under no obligation to 

analyze or mitigate safety 

issues/hazards beyond prescriptive 

technical requirements in Part 139.

Airports would proactively 

identify and analyze safety 

hazards, mitigating when 

appropriate.

2. Baseline Benefits 

The baseline is not simply the current situation, but an assessment of what would likely 

happen in the absence of the rule. Historically, the airport industry waited for the FAA to issue 

prescriptive regulations and corrective actions typically based on analysis of past accidents. In 

the absence of the rule (i.e., baseline costs), safety will only gradually improve as a result of 

FAA initiated or recommended safety measures.

SMS, however, would expedite safety improvement due to proactive airport actions. It 

concentrates on controlling the development stages of safety management rather than solely 

relying on FAA inspection and remedial actions. In its most general form, SMS is a set of 

decision making processes and procedures that an airport would use to plan, organize, direct, and 
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control its everyday activities in a manner that enhances safety. The proactive approach to 

hazard identification and analysis of accidents, incidents, and other reported or collected data at 

each individual airport through an SMS would likely reduce these incidents.

Because this baseline is an assessment of what would likely happen in the next 10 years, we 

took into account other rules that will come into effect during this period. Of the accidents 

evaluated in this rule, 35 overlap with at least one other rule. The FAA has evaluated the 

historical accidents in context of the other rulemakings such that the sum of the accident 

prevention probabilities for each accident across all these rules will not exceed one. Of the 35 

overlapping accidents, only in one does its sum exceed one (DCA07FA037). See the following 

table for details.

Accident Prevention Probabilities for Overlapping Accidents

Date NTSB #

Part 121 

SMS FDR FOQ

Airport 

SMS Total

12/3/2008 CEN09LA093 0.2 0.2 0.40

9/7/2008 DEN08LA151 0.2 0.2 0.40

1/13/2008 SEA08LA061A 0.2 0.2 0.40

1/13/2008 SEA08LA061B 0.2 0.2 0.40

4/12/2007 DCA07FA037 0.9 0.15 0.4 1.45

12/23/2006 ANC07LA008 0.2 0.2 0.40

11/7/2006 CHI07LA021A 0.2 0.2 0.40

11/7/2006 CHI07LA021B 0.2 0.2 0.40

6/8/2006 CHI06LA161 0.2 0.4 0.60

5/12/2006 NYC06LA114 0.2 0.4 0.60

12/14/2005 ATL06LA024 0.2 0.2 0.40

8/20/2005 CHI05LA238 0.2 0.4 0.60

8/8/2005 IAD05LA118A 0.2 0.4 0.60

8/8/2005 IAD05LA118B 0.2 0.4 0.60

7/8/2005 CHI05LA179 0.2 0.2 0.40

6/7/2005 DCA05MA070 0.2 0.15 0.2 0.55

3/11/2005 CHI05FA077 0.2 0.4 0.60

1/8/2005 DEN05LA048 0.2 0.4 0.60

10/27/2004 NYC05LA013 0.2 0.4 0.60

10/25/2004 DFW05LA010 0.2 0.2 0.40

4/1/2004 NYC04LA099 0.2 0.4 0.60

3/15/2004 CHI04LA086 0.2 0.4 0.60

2/24/2004 CHI04LA077 0.2 0.2 0.40

12/14/2003 ATL04LA053 0.2 0.2 0.40
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9/12/2003 NYC03LA199 0.2 0.2 0.40

8/1/2003 ATL03LA124 0.2 0.2 0.40

6/2/2003 DEN03LA096 0.2 0.2 0.40

5/20/2003 LAX03LA167 0.2 0.4 0.60

10/24/2002 CHI03FA014 0.2 0.4 0.60

7/21/2002 NYC02LA146 0.2 0.2 0.40

7/2/2002 FTW02LA199 0.2 0.4 0.60

1/20/2002 NYC02LA056 0.2 0.2 0.40

2/3/2001 NYC01LA075A 0.2 0.2 0.40

2/3/2001 NYC01LA075B 0.2 0.2 0.40

12/27/2000 NYC01LA076 0.2 0.4 0.60

We removed the DCA07FA037 accident from the benefit analysis because its sum exceeds one.

B. Costs

To better understand how SMS could change the existing airport baseline, the FAA

funded airport pilot studies to evaluate the usefulness, applicability, and implementation of SMS 

in an airport environment. Since 2007, roughly 30 certificated airports of varying size and 

complexity operating with a Class I, II, III, or IV AOC participated in the studies. (See 

Appendix 5 for a breakout of the types of airports that participated.) The first and second studies 

focused on conducting a gap analysis and developing an SMS manual and implementation plan. 

The third study was a proof-of concept study that included three airports of varying size and 

operations. The last study, also referred to as the SMS Implementation Study, had 14 of the 

airports that participated in earlier studies implementing portions of their SMS manual. (See 

Appendix 6 for a compilation of pilot study documentation.)

As discussed in the NPRM, the pilot study participants noted that Part 139 compliance 

does not constitute an SMS. While certificate holders currently maintain FAA-approved ACMs, 

provide, train, and equip personnel, and maintain records to document self-inspections, accidents 

and notices to airmen, these activities do not address the risk management, assurance, 

confidential reporting, and safety data management inherent to SMS. However, the pilot studies 

revealed that airports may use these existing requirements to serve as building blocks for 

developing and implementing their SMS, thus enhancing scalability.
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To calculate some of the costs and benefits associated with SMS, the FAA followed-up 

with pilot study participants for the Initial Regulatory Evaluation. The FAA later followed-up 

with the Implementation Study airports.

The FAA-funded studies likely resulted in upward biased estimates since the FAA 

established the deliverables required and allowed the airports various means for developing those 

deliverables. Similarly, the FAA established maximum funding levels for each study. Airports 

had an incentive to use all available FAA funds. The airports also did not have knowledge of 

FAA's proposed requirements while establishing their SMS programs since most of the studies 

occurred before the FAA published the NPRM.

Examples of differences between study deliverables and the proposed rule include the 

gap analysis and SMS manual. The first two studies required a gap analysis and creation of a 

separate SMS manual, and all of the pilot study airports gave cost estimates for a separate SMS 

manual. In reviewing the findings of the first two studies, the FAA found that while a gap 

analysis could be helpful to an airport in developing its SMS, it could be completed in a variety 

of ways, and it was not a required activity to complete implementation. Therefore, the proposed 

rule does not require a gap analysis. Similarly, minimum compliance with the rule would require 

only an addition to the Airport Certification Manual (ACM) and not a separate SMS manual. 

Because SMS was not required under part 139, the FAA required pilot study airports to keep 

their SMS deliverables separate from their ACM so that the FAA would not have to include 

review of those items during its periodic inspection. The FAA also found that many pilot study 

airports extended applicability of their SMS program to the terminal environment and integrated 

other regulatory compliance programs, such as occupational health and safety, into their SMS

development.

The FAA is unable to estimate the size of this compliance cost bias. Therefore, the pilot 

study responses are the foundation of the costs in this revised regulatory evaluation.

The costs of implementing an SMS for each group of airports are the following:

Costs Over 10 Years

Costs All Class I International L, M, S and 

>100K ops

Preferred 

alternative: L, M, 
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S, >100K ops, and 

International

Undiscounted $471,104,787 $341,021,606 $215,010,997 $163,760,850 $238,865,692

Present value 

(7%) $307,842,595 $223,584,687 $141,796,001 $108,819,973 $157,496,312

Present value 

(3%) $389,440,320 $282,304,199 $178,432,284 $136,340,226 $198,211,977

The FAA determined that the following factors represent the compliance costs of this SNPRM:

1. SMS Manual and Implementation Plan;

2. New Staffing Requirements;

3. New Equipment and Materials;

4. Training;

5. Recording Potential Hazards; and

6. Documenting SRM and Reporting Safety Information.

In addition, the FAA also received comments questioning whether the cost of mitigations 

should have been included. The purpose of SMS is to analyze hazards, assess the risk those 

hazards present to the system, and develop appropriate mitigations to address the risk. 

Mitigations that might be developed will depend on the nature of the hazard and resulting risk 

that the hazard may present to the airport operator’s unique operational environment. These 

mitigations could range from increased communication with staff via email safety bulletins, to 

changes in operational procedures, additional training, etc. 

Given the range of mitigation actions possible, it is difficult to provide a quantitative 

estimate of both the costs and benefits of such mitigations. We anticipate that operators will 

only implement mitigation where benefits of doing so exceed the costs of the mitigation. In 

order for the estimated benefits to exceed the costs of the rule, the mitigation costs must be 

below $68.4 million over 10 years (discounted at 7%). The FAA requests comment on this 

assumption, as well as data regarding costs and benefits associated with any mitigation 

implemented through a voluntary SMS program.

1. SMS Manual and Implementation Plan
16

The proposed rule would require certificate holders to document the structure of their SMS,

and this section focuses on the cost of this documentation and the cost of creating an 

implementation plan. Certificate holders have the option of either developing and maintaining a 

separate SMS Manual in addition to the ACM or incorporating these SMS requirements directly 

into the ACM. However, under the pilot studies all airports were required to create a separate 

manual which is the basis of the costs below. The proposal would also require development of an 

implementation plan. The implementation plan serves as a tool to help the certificate holder 

implement the various components and elements of SMS. The manual and implementation plan 

costs are combined.

An airport’s characteristics determine the size and scope of both the implementation plan 

and the manual. At larger airports, these documents could be fairly detailed and complex. The 

average cost per airport was calculated by taking the average cost per manual from the pilot 

study airports. For the purpose of this analysis, the Large, Medium and Small Hub airports were 

classified as large airports, while all other airports were classified as small airports. In general,

large airports typically have dedicated Operations and Maintenance staff, equipment and more 

complex operations. Small airports are typically run by a small staff having multiple 

responsibilities and these airports may receive support and equipment from their municipalities 

to maintain compliance with part 139.

Available data from pilot study participants suggests that the average cost for the 

implementation plan and the manual was about $225,8005(about $209,400 in 2009 dollars) for 

large airports. For small airports, implementation plan and manual cost was about $124,500

(about $115,500 in 2009 dollars).

6

 The average cost by airport was then multiplied by the 

number of airports in each airport group. Total cost equals the sum of costs for large and all 

other airports then adjusted by the GDP deflator to 2014 dollars. 

For the purpose of this analysis the FAA assumes an inspector would require 16 hours for a 

large airport and 4 hours for a small airport to review the implementation plan in the first year. 

Additionally, an inspector would require on average 8 hours per airport for both large and small 

airports to review the manual in the second year. An inspector would be tasked to read, analyze, 

 

5 The SMS document costs that are in the paperwork analysis are included in the manual and implementation costs.

6 The FAA provided AIP funding for these studies which ranged from $36,000 to $200,000.
17

and coordinate an SMS implementation plan at an hourly wage of $66.76.

7

 In general, it is 

assumed the FAA’s evaluation of a large airport’s implementation plan will take more time and 

effort than the SMS Manual because of the complexity of their operations and organizations. An 

inspector would review these plans to verify the certificate holder provided a detailed proposal 

on how they will meet the SMS requirements and a schedule for implementing SMS. The 

inspector will also have to evaluate existing programs, policies, or procedures if the certificate 

holder intends to use these for compliance with the SMS requirements. By ensuring a thorough 

review of the certificate holder’s implementation plan, the FAA hopes to catch any potential 

compliance issues early, before the certificate holder spends time and money setting up their 

SMS programs.

The cost for implementation and manual development will be amassed over 24 months. 

All costs associated with the development of the implementation plan, established by this 

schedule, are expected to accrue in 2016. All costs associated with the development of SMS 

documentation will take place by 2017. Half of the costs would take place in 2016 and the 

remaining half would take place in 2017.

The FAA considered recurring costs associated with updates to the manual. The FAA 

estimates that it will take 12 hours for a clerical employee at an hourly rate of $19.41 to update 

the SMS manual, and it will take an inspector 1.25 hours to review the revised SMS manual.

Using the preceding information, The FAA estimates the following cost for the manual and 

implementation plan:

 

7 The FAA assumes a GS-13 step 5 for the inspector. The compensation information comes from the Bureau of 

Labor Statistics.
18

2. New Staffing Requirements

Many pilot study airports mentioned additional staffing to oversee SMS and manage 

several of the more complex aspects of implementation. They believed existing staff would be 

overwhelmed by the additional workload, which would require airports to identify, collect, track, 
19

and analyze data, plus monitor progress and promote safety. Accordingly, the FAA accounted for 

the additional personnel. Over 75% of the total costs are the additional personnel costs.

There were 31 airports reported in Appendix A of the Technical Report, which participated in the 

SMS pilot studies. These airports were asked about the number of full-time and part-time 

employees currently working on SMS during the pilot studies. Fifty percent of airports reported

the current use of one full-time employee, 35% reported no additional full-time staffing, and 

15% reported using two full-time employees. Separately, 61% reported not requiring a part-time 

employee, 15% reported requiring one part-time employee, 8% reported requiring two part-time 

employees, 8% reported three part-time employees, and lastly 8% required reporting four parttime employees. 8

 These percentages were applied to the number of airports in each alternative 

for an estimated number of full-time and part-time employees.

Information from the Initial Regulatory Evaluation and follow-up with some of the pilot 

study participants provides details on the type of staffing. The most common positions, reported

by pilot study airports, were an SMS manager/coordinator, a safety specialist or auditor, an 

executive, and a data analyst. Salary and compensation information for these positions comes

from the Bureau of Labor Statistics (BLS). The salaries for these BLS job titles, under the air 

transport category, were used to represent the industry titles listed above: General and 

Operations Manager (11-1021) for the SMS manager; Operations Research Analysts (15-2031)

for the data analyst; Management Occupations (11-0000) for the executive; and Airfield 

Operations Specialist (53-2022) for the safety specialist/auditor.

The FAA employed the annual mean or average wage for these occupations. Salaries,

including benefits, are about $137,859 annually for an SMS manager, about $96,972 for an 

operations research analyst, about $61,976 for an airfield operations specialist, and about 

$131,280 for a general and operations manager.

9 Many of these positions would spend less than 

20 hours a week on SMS; however, all positions would be permanent. Consequently, these 

salaries are recurring annual costs that an airport would incur for the life of the program. These 

personnel costs would begin in 2018 after the safety manual and initial training is completed. 

 

8 http://www.faa.gov/airports/airport_safety/safety_management_systems/media/smsPilotTechReportMay2011.pdf, 

page 11.

9 http://www.bls.gov/news.release/ecec.nr0.htm, Relative importance of employer costs for employee 

compensation, March 2013 that additional employer compensation per employee is roughly 35 % of an employee’s 

salary
20

Airports reported that employees that worked part-time on SMS spent between one and 

twenty hours a week on SMS with an average of eight hours a week. The eight hours a week 

was applied to all part-time staff. 

Using the preceding information, the FAA estimates the following annual costs for 

staffing:
21 Employees # of Employees Salary plus Benefits (per YR)

Hourly 

Wage

Average Hours 

for Part Time 

Employee Cost Per Year

SMS Manager 218 $137,859 $30,053,210

Airfield Operations Specialist 217 $61,976 $13,448,807

Total Full Time Employees 435 $43,502,017

SMS Manager 119 $66.28 8 $63,099

Airfield Operations Specialist 118 $29.80 8 $28,131

General and Ops Manager 118 $63.12 8 $59,585

Operations Research Analyst 118 $46.62 8 $44,009

Total Part Time Employees 473 $194,824

Total Full Time Employees and Part 

Time Employees 908 $43,696,841

Employees # of Employees Salary plus Benefits (per YR)

Hourly 

Wage

Average Hours 

for Part Time 

Employee Cost Per Year

SMS Manager 156 $137,859 $21,505,967

Airfield Operations Specialist 155 $61,976 $9,606,291

Total Full Time Employees 311 $31,112,257

SMS Manager 85 $66.28 8 $45,070

Airfield Operations Specialist 85 $29.80 8 $20,264

General and Ops Manager 84 $63.12 8 $42,417

Operations Research Analyst 84 $46.62 8 $31,329

Total Part Time Employees 338 $139,080

Total Full Time Employees and Part 

Time Employees 649 $31,251,337

Employees # of Employees Salary plus Benefits (per YR)

Hourly 

Wage

Average Hours 

for Part Time 

Employee Cost Per Year

SMS Manager 96 $137,859 $13,234,441

Airfield Operations Specialist 96 $61,976 $5,949,703

Total Full Time Employees 192 $19,184,144

SMS Manager 52 $66.28 8 $27,572

Airfield Operations Specialist 52 $29.80 8 $12,397

General and Ops Manager 52 $63.12 8 $26,258

Operations Research Analyst 52 $46.62 8 $19,394

Total Part Time Employees 208 $85,621

Total Full Time Employees and Part 

Time Employees 400 $19,269,765

Employees # of Employees Salary plus Benefits (per YR)

Hourly 

Wage

Average Hours 

for Part Time 

Employee Cost Per Year

SMS Manager 71 $137,859 $9,787,972

Airfield Operations Specialist 71 $61,976 $4,400,301

Total Full Time Employees 142 $14,188,273

SMS Manager 39 $66.28 8 $20,679

Airfield Operations Specialist 39 $29.80 8 $9,298

General and Ops Manager 38 $63.12 8 $19,188

Operations Research Analyst 38 $46.62 8 $14,172

Total Part Time Employees 154 $63,338

Total Full Time Employees and Part 

Time Employees 296 $14,251,611

Employees # of Employees Salary plus Benefits (per YR)

Hourly 

Wage

Average Hours 

for Part Time 

Employee Cost Per Year

SMS Manager 107 $137,859 $14,750,887

Airfield Operations Specialist 106 $61,976 $6,569,463

Total Full Time Employees 213 $21,320,351

SMS Manager 59 $66.28 8 $31,284

Airfield Operations Specialist 58 $29.80 8 $13,827

General and Ops Manager 58 $63.12 8 $29,288

Operations Research Analyst 58 $46.62 8 $21,632

Total Part Time Employees 233 $96,031

Total Full Time Employees and Part 

Time Employees 446 $21,416,381

Note: The sum of individual items may not equal totals due to rounding.

Large, Medium, Small, Greater than 100,000 operations and International Airports

Class I Airports

All Part 139 Airports

Staffing Costs per Year

International Airports

Large, Medium, Small and Greater than 100,000 operations Airports
22

3. New Materials/Equipment

The SNPRM would require airports to establish a hazard reporting system, and to identify,

analyze, and mitigate hazards when appropriate. Based on this proposed requirement, airports 

indicated the need for new equipment and materials to store, track, and analyze data and to 

promote safety. Equipment can be placed into one of the three categories: software, hardware, 

and promotional material. 

Two out of eight (25 percent) pilot study airports asserted that they would need very little 

in terms of new equipment or material. For example, one of the airports mentioned that all 

management personnel have computers, cell phones, radios, email, and GIS software, which 

should be sufficient to meet its obligations. By multiplying 25% by the total number of airports, 

the FAA estimates the number of airports that will choose similar no cost options for equipment. 

For the remaining airports, the FAA retained the cost of software data from the Initial Regulatory 

Evaluation. Several pilot study airports provided information on two companies whose software 

packages include the following options: a data warehouse, a hazard reporting system, a training 

suite, and an audit module. These software packages can be customized for an airport for 

roughly $23,500 ($21,80010 in 2009 dollars). The software also has recurring costs associated 

with licensing and IT support or maintenance. The fee for this support is calculated at 25% of 

the fee for the systems, suites, modules, etc. equaling about $5,900 ($5,500 in 2009 dollars) per 

airport. This information was collected in 2009 and was adjusted by the GDP deflator to reflect

2014 dollars. The initial purchase of software would take place in 2018 with recurring costs

starting in 2019 and continuing until 2025. 

Some of the larger airports also described upfront new hardware required to house the 

data and provide training. Examples of hardware, as provided by the pilot study airports, include 

laptops, printers, and cameras. Initially, the FAA assessed costs for hardware. However, after 

receiving more information from pilot study airports, the FAA determined that airports already 

owned items that could be used to help comply with the proposal. For example, an airport 

should already have vehicles to respond to wildlife issues and safety issues on the airport to 

comply with existing part 139 operations. 

 

10 Reported in the NPRM from INTELEX, www.intelex-exchange.com, 2009
23

The proposal would also require airports to promote safety. Each airport has the ability to 

determine the best way to promote safety, offering a variety of possible methods of safety 

promotion. This can range from stickers, to slogans, to posters, to newsletters following up on 

safety issues, to SMS briefing materials. To estimate costs associated with this proposal, the 

FAA followed up with Class I pilot study airports. Based on the responses, we updated the 

average cost to $2,110 for every other year beginning in year 3 (up from $100 in the Initial 

Regulatory Evaluation). Costs for promotional material would recur every other year given the 

constant need to foster an airport operating environment that encourages safety.

Using the preceding information, the FAA estimates the following annual costs for the 

new materials/equipment:

Total New Material/Equipment Costs 

* Costs for promotional material recurs every other year

4. Training

In the NPRM, the FAA proposed formal safety training for all airport employees with 

access to the movement and non-movement areas. However, the FAA envisioned that greater 

benefits could be achieved if the training requirement were applied to all individuals with access 

to the movement and non-movement areas and welcomed comment on the alternative option. 

The goal was to keep employees aware of current safety measures while also keeping them 

aware of (or on the lookout for) potential safety problems to reduce the number of accidents or 

incidents on the airfield. For the initial regulatory evaluation, the FAA estimated the costs 

associated with a proposed requirement on airport employees and not the broader training 

requirement for all individuals accessing these areas. Commenters stated that the alternative

proposed training requirements were cumbersome, time consuming, and excessively costly. In 

light of these comments and lessons learned from the pilot studies, the SNPRM instead proposes

a two-pronged approach to training. First, the certificate holder would provide comprehensive 

SMS training specific to the individual's role and responsibility in implementation and 
24

maintenance of the SMS. Second, training would include hazard awareness and hazard reporting 

awareness orientation for all other individuals with access to the movement and non-movement 

areas.

While the pilot study airports reported higher estimates for the number of employees it

planned to train, the FAA analyzed each airport's responses to better estimate training that 

complies with the supplemental proposal. This analysis produced an average of 10 employees 

requiring comprehensive SMS training. (These 10 employees would consist of at least one 

airport manager or executive, mid-level supervisor, operations or maintenance personnel, and 

clerical staff). 

However, the FAA found that using one average for all airports in the preferred alternative 

failed to adequately account for the smaller, less complex airports with fewer employees. For a 

small airport, the FAA assumes 3 employees, on average, would receive comprehensive SMS 

training at the airport. These 3 employees would consist of one airport manager, one or two 

operations or maintenance personnel, and clerical staff. Therefore, the FAA used two averages 

when costing training and used information provided by the smaller pilot study airports to 

determine the second average.

The FAA expects certificate holders to provide training appropriate to the individual’s role 

in the certificate holder’s SMS. Persons with responsibilities for implementation or oversight of 

the certificate holder’s SMS would be required to receive training specific to their roles and 

responsibilities. For example, those persons responsible for analyzing hazard reports to 

determine action should be properly trained in safety risk management and hazard assessment 

procedures. Individuals, including staff and/or managers, with responsibility for daily oversight 

of the SMS should be trained in all requirements of the SMS. The FAA estimates that on 

average, either 3 or 10 employees per airport would require this type of training. 

For costing purposes, the FAA used a $180 training fee per employee in year 2 and $90

every other year (beginning in year 4), which includes both managers and employees.11 For 

large airports, we estimate that one airport manager or executive, two mid-level supervisors, five 

maintenance personnel, and two clerical staff members will incur this training fee. For small 

airports we estimate that one airport manager, one maintenance personnel and a clerical staff 

 

11 Accessed on February 21, 2012 at http://www.omniairgroup.com./sms_pricing.html. SMS e-Learning for 

personnel and managers (discounted at 50% of published rates).
25

member will incur the training fee. Additionally, the FAA determined that 3 hours will be 

needed in year 2 and 1.5 hours every other year (beginning in year 4) for the training time of 

both these managers and employees. We assume no travel costs for the training as it will be 

delivered electronically.

Three certificate holders stated that the Initial Regulatory Evaluation did not account for

the attrition rate and lost productivity during training. The FAA is not including an attrition rate 

in this analysis because the number of employees requiring training significantly decreased 

compared to the number covered by the NPRM’s proposed training requirements and there is no 

basis to determine that attrition rate for the estimated 3 or 10 employees per airport. 

Additionally, concerning the lost productivity, we added training time for both managers and 

employees to account for the opportunity cost of the training. Using the preceding information, 

the FAA estimates the following training costs:
26
27

For costing purposes, the FAA estimates that it would take five minutes to update an 

employee’s training record every other year. The FAA estimates that 3 employee training 

records would be updated at a small airport and 10 employee training records would be updated 

at a large airport. A clerical position (occupation code 43-6014) would be tasked with updating 

the training records at an hourly wage of $19.41. Salary and compensation information for the 

clerical position comes from the Bureau of Labor Statistics (BLS). 

Using the preceding information, the FAA estimates the following annual updating of training

record costs:
28

 Note: The sum of individual items may not equal totals due to rounding.

Hazard awareness and reporting awareness orientation also would be required for all 

other individuals with access to the movement and non-movement areas. It would take an SMS 

manager 8 hours in the second year to develop and 2 hours beginning in the fourth year to update 

the hazard awareness orientation at each airport. 

The FAA estimates that there would be on average 50 tenants at a large airport and 10 

tenants at a small airport. The FAA estimates that updating distribution logs would require 15 
29

minutes and 5 minutes at large and small airports, respectively. A clerical staff member would be 

tasked with updating the distribution logs.

Using the preceding information, the FAA estimates the following development and 

updating of hazard awareness orientation as well as updating of the distribution logs:
30

5. Recording Potential Hazards

The SNPRM would require airports to establish a hazard reporting system. Based on this 

requirement, the FAA estimates 15 minutes to record one potential hazard a week. Therefore, the 
31

FAA estimates 52 potential hazards (one per week) would be recorded annually. A clerical 

position would be tasked with recording the potential hazard.

Using the preceding information, the FAA estimates the following annual recording of 

potential hazards costs:

6. Documenting SRM and Reporting Safety Information

The SNPRM would require airports to document SRM. Based on this requirement, the 

FAA estimates 30 minutes a week to document SRM. Therefore, the FAA estimates 52 
32

documents annually beginning in the third year. A clerical staff member would be tasked with 

recording the potential hazard. 

Using the preceding information, the FAA estimates the following annual documenting 

of SRM costs:
33

The SNPRM would require airports to report safety information under SA. Based on this 

requirement, the FAA estimates 1 hour to report safety information. Therefore, the FAA 

estimates 2 documents annually beginning in the third year. For the purposes of establishing a 

wage rate, the FAA used the operations research analyst position for reporting the airport’s 

safety information. 

Using the preceding information, the FAA estimates the following annual recording of 

safety information costs:
34

7. Costs of Compliance

The following tables show the costs for each of the alternatives, which include: SMS 

manual and implementation plan, staffing, new materials/equipment, training, updating training 

records, and hazard recording. The preferred alternative has estimated costs of $238.9 million 

($157.5 million when discounted at seven percent and $198.2 million when discounted at three 

percent).
35
36
37

C. Benefits

The objective of SMS is to proactively manage safety, to identify potential hazards or 

risks, and to implement measures that mitigate those risks. The FAA envisions a certificate 

holder being able to use the components and elements of SMS to enhance its ability to identify 

safety issues and spot trends before they result in an incident or accident. Airports have already 

seen benefits from increased communication, training, and reporting. A functioning SMS would

help a certificate holder ensure that individuals know how to report hazards. Proactive processes 

would help certificate holders analyze those reported hazards or other changes to the airport 

environment which could increase safety risks, while reactive processes such as evaluations and 

investigations would analyze near-misses, incidents, and accidents after they occur to determine 

root causes and seek future mitigations. These efforts could in turn prevent future accidents and 

incidents thereby reducing the direct and indirect costs of incidents and accidents. Further, this 

data and analysis would put a certificate holder in a unique position to share lessons learned with 

the many individuals and tenants that access the movement and non-movement areas of the 

airport, thereby possibly preventing similar hazards or future incidents and accidents.

In the Initial Regulatory Evaluation, the FAA identified 57 National Transportation 

Safety Board (NTSB) accidents, 18 insurance claims, and 15 Occupational Safety and Health 

Administration (OSHA) investigations to affirm its rationale and compute derived benefits of an 

airport SMS. However, limiting analysis to only those accidents, especially to those meeting the 

NTSB’s reporting and investigation threshold, fails to account for many other accidents and 

incidents occurring on airports. Under SMS, the FAA would expect a certificate holder to 

evaluate and analyze a broader pool of events occurring on the airport in addition to reported 

hazards. Therefore, for this revised analysis, the FAA pooled additional sources of incident and 

accident data all resulting in damage to aircraft or operational facilities/equipment on airports. 

While the FAA recognizes that this new pool does not cover all events (e.g., near misses or other 

less costly incidents) occurring on the airport or potential reported hazards, it accounts for the 

most costly incidents and accidents reported to the FAA or NTSB. These new pools include 

FAA’s Aviation Accident/Incident Database (AIDS), the Aviation Safety Reporting System 

(ASRS), and the FAA’s Runway Incursion Database.

Under an SMS and its Safety Assurance program, the FAA anticipates that a certificate 

holder would analyze the variety of accidents and incidents occurring on the airport, not just 
38

those investigated by the NTSB. The certificate holder would identify root causes, proactively 

identify hazards, and implement mitigations where appropriate. This holistic approach would 

help the certificate holder better understand and implement its role in applying defenses through 

mitigations or controls to prevent accidents before they occur.

Using this expanded rationale, the FAA explored additional reporting sources to identify 

accidents and incidents where the certificate holder’s actions or the airport environment 

contributed to the accident or incident. The FAA also reviewed accidents and incidents where 

the FAA believes the certificate holder had some control to prevent the accident or incident from 

occurring, but less control than others, like the air carrier or fixed-base operator. For example, 

while a ramp accident caused by an improperly trained air carrier employee directly relates to an 

air carrier’s operations, the certificate holder has some control or role in the ramp area to defend 

against accidents like these including oversight and licensing of drivers with unescorted access to 

the airport. Similarly, if a certificate holder is aware of systemic incidents occurring in the 

airport environment, it may be able to take action to prevent future incidents or accidents or 

share lessons learned with all tenants.

To clarify the FAA’s use of these databases, the following section identifies an example 

from each of these databases.

NTSB

Accident No: DEN07IA069

On February 16, 2007, a Frontier Airlines A319 sustained a fractured windshield due to 

impact with foreign object debris (FOD). During the course of the afternoon, at that same 

airport, 14 other aircraft experienced 26 similar fractured windshields. The examination revealed 

that the impact markings on all 26 windshields were the result of impact with FOD. This 

accident, and especially some of the 14 others that afternoon, may have been prevented through 

an airport’s Safety Assurance and SRM processes and procedures. Under SMS, the certificate 

holder would have a hazard reporting system (See §139.402(c)(2)) and enhanced communication 

networks/procedures for reporting immediate safety issues (See §139.402(d)(5)) such as FOD in 

the movement and non-movement areas. Airport employees and tenants, including air traffic 

control, would receive hazard reporting materials (See §139.402(d)(1)) making them aware of 

the reporting system and how to make a report.
39

Hazard reports would trigger hazard identification and analysis (See §139.402(b)(1) and 

(2)). A certificate holder would have processes and procedures in place to quickly complete this 

identification and analysis to determine how to proceed. Unlike more complex analysis which 

would typically be required for analysis of activities such as construction or future changes in 

operations, in this case, the quantity and location of reported FOD would trigger immediate 

action and mitigation. While it is expected that the first hazard report would result in action by 

the certificate holder, should multiple reports be made to the certificate holder’s hazard reporting 

system the airport would have additional data to later determine root causes (See 

§139.402(c)(1)).

OSHA

Nr: 310468418/Report Id: 0830500

On August 6, 2007, a rubber removal contractor’s employee was operating a truckmounted high pressure water sprayer to remove rubber contamination on the runway. After 

completing the evening’s work, the employee exited the cab of the truck to determine the 

remaining work and was struck by one of two airport-operated wire brush sweepers that sweep 

up the rubber residue. While the wire brush sweeper vehicle made an abrupt turn, the employee 

was wearing dark clothes and not wearing a reflective vest.

While this accident was reported through the OSHA, the event still represents potential 

operational safety issues on the airport. Under SMS, the FAA would expect the certificate 

holder to conduct proactive hazard identification and analysis (See §§139.402(b)(1) and (2)) on 

construction activities and major operational or maintenance procedures. Through formal SRM 

analysis and documentation the certificate holder would make updates to those procedures and 

activities as necessary.

Many of the pilot study airports found that safety communications (See §139.402(d)(5)) 

through Safety Promotion increased vigilance during construction activities and 

operations/maintenance procedures. These airports included additional communications, 

procedures, and training, resulting from hazard identification and analysis, to remind employees 

and contractors of operational safety during these activities (See §139.402(b)(2)(v)). Reactively, 

an event such as this would be evaluated or investigated under the certificate holder’s Safety 

Assurance processes to identify hazards and root causes (See §139.402(c)(1)). Mitigations 
40

would be put in place to avert future similar accidents and the certificate holder could 

communicate lessons learned to employees, contractors, and tenants through its Safety 

Promotion processes (See §139.402(d)(5)).

AIDS

Report No: 20081215855079I

On December 15, 2008, during taxi to the ramp after a normal landing, the flight crew of 

a Northwest Airlines DC-9 had difficulty distinguishing the boundaries of the ramp and ramp 

marking due to compacted snow. The aircraft left the ramp and ended up on a non-paved area of 

compacted snow. While the ramp was cleared of snow before the flight’s arrival, airport 

personnel pushed the snow past the ramp boundary, causing an illusion that the ramp area was 

larger than it actually is.

Some of the pilot study airports used the hazard identification and analysis tools (See 

§§139.402(b)(1) and (2)) under SRM to proactively review their winter operations procedures 

before the snow season. The FAA anticipates that other certificate holders would choose similar 

triggers which would help identify hazards such as the one that caused this event. Potential 

mitigations such as enhanced communications with employees or contractors before snow 

removal operations or additional inspections before air carrier operations would be put in place 

before the beginning of the snow season (See §139.402(b)(2)(v)). Similarly, a certificate holder 

would reactively evaluate or investigate such an event using its Safety Assurance processes to 

identify hazards and root causes (See §139.402(c)(1)). The results of those activities would 

either trigger SRM processes (See §139.402(b)) or communications (See §139.402(d)(5)) to 

employees, contractors, or tenants under Safety Promotion.

ASRS

Report No: 643094

In January 2005, a small aircraft’s wing struck a tree on a visual approach to Runway 

31L. On the evening of the event, ramp lighting was illuminated to work on a jet being prepared 

for delivery. The pilot claimed the ramp lighting obscured the VASI lighting, causing a low 

approach into the runway.
41

Under SMS, the certificate holder would evaluate or investigate such an event using its 

Safety Assurance processes to identify hazards and root causes (See §139.402(c)(1)). 

Mitigations would be put in place where necessary (See §139.402(b)(2)(v)). In this case, the 

airport could work with tenants to identify areas of the airport where lighting would not affect 

the runway environment.

The FAA would also expect a certificate holder to periodically review accident and 

incident databases such as ASRS for events occurring on their airport which may have not been 

reported through the certificate holder’s hazard reporting system (See §139.402(c)(1)). Such 

data would provide valuable actionable information which the certificate holder could analyze 

for hazards and institute mitigations (See §§139.402(b)(1) and (2)) to prevent future similar 

occurrences.

RI Database

Event Id: 2480

On June 17, 2004, an unmanned catering truck crossed Runways 22R and 22L in the 

vicinity of Taxiway R and came to a stop after hitting a runway sign. Four arrivals for Runway 

22L were sent around with the closest on 2.5 mile final. Three departures were held but none 

had been cleared for takeoff.

Under SMS, an event like this would be evaluated or investigated using the Safety 

Assurance processes (See §§139.402(c)(1) and (2)). Certificate holders are currently required to 

establish procedures for access to the movement areas of the airport, identify consequences of 

non-compliance, and ensure that each employee, tenant, or contractor is trained on these 

procedures (See §139.239). SMS would provide a more formalized approach to analyzing these 

events to determine root cause and the effectiveness of existing procedures. The FAA would 

expect a certificate holder to follow its procedures for non-compliance and communicate with 

employees and tenants any lessons learned using Safety Promotion processes. The FAA would 

also expect the certificate holder to change ineffective procedures based on these analyses (See 

§139.402(b)(2)(v)).

The benefits of implementing a SMS for each group of airports are the following:

Benefits Over 10 Years
42

Benefits All Class I International L, M, S and 

>100K ops

Preferred alternative: 

L, M, S, >100K ops, 

and International

Undiscounted $382,987,281 $368,096,671 $360,907,166 $356,128,301 $370,788,457

Present value 

(7%) $233,282,770 $224,210,033 $219,830,291 $216,919,352 $225,850,869

Present value 

(3%) $307,499,272 $295,542,114 $289,769,378 $285,932,407 $297,704,052

To calculate the benefits, we considered the following six databases:

 National Transportation Safety Board Aviation Accident/Incident Database (NTSB) ; 

 FAA Wildlife Strike Database;

 Aviation Accident/Incident Database (AIDS); 

 Aviation Safety Reporting System (ASRS);

 Occupational Safety and Health Administration (OSHA ); and

 Runway Incursion Database (RI).

1. Benefit Model and Assumptions

We developed a model to estimate the benefits of the SNPRM. The relationships of the 

model may be summarized as follows: 

Benefits = (Fatalities + Serious injuries + Minor injuries + Aircraft + Out-of-service + 

Investigation) × Effectiveness

Where:

Fatalities = Fatality costs;

Serious injuries = Serious injury costs;

Minor injuries = Minor injury costs;

Aircraft = aircraft damage cost;

Out-of-service = out-of-service cost;

Investigation = investigation cost; and

Effectiveness = effectiveness measure.

In the benefit model, we assumed that:
43

 The rule would take effect in 2016. 

 The baseline value of a statistical life (VSL) for 2014 is $9.4 million.1

 VSL in future years were estimated to grow by 1.03 percent per year before discounting 

to present value.

 The value of a serious injury is $987,000.

2

 The value of a minor injury is $28,200.

3

 Because in the AIDS, ASRS, and RI databases, the type of injury was not specified, we 

assumed all injuries were minor.

 Benefits are delayed to 2018 since airports have 2 years for implementation.

 We valued destroyed aircraft at an average replacement cost of aircraft potentially 

affected by this rule, and we valued aircraft with substantial damage at an average 

restoration cost of aircraft potentially affected by this rule, which we estimated at about 

13% of the replacement cost. We valued aircraft with minor damage at about 5% of the 

replacement cost.

 For the ASRS database, we assumed minor damage for all accidents since there is no 

consistent data available for severity of aircraft damage.

 The FAA estimated that the daily loss of an aircraft being out of service4is roughly 7% 

of the value of the aircraft multiplied by days out of service divided by 365 days 

(opportunity cost of capital). The FAA contacted industry for information on repair times 

for both minor and substantial aircraft damage. Although there is a substantial amount of 

variability in repair times alone, based on the severity of the damage and the availability

of parts, a range was given by several of these contacts. The FAA chose to use the lower 

estimates, given the nature of the accidents on airports and the range of aircraft types. 

For minor damage, the minimum was 3 days and for substantial damage the minimum 

was 30 days.

 

1Office of the Secretary of Transportation Memorandum, "Guidance on Treatment of the Economic Value of a 

Statistical Life in U.S. Department of Transportation Analyses,” June 2015.

2

Ibid.

3

Ibid.

4 Out of service costs were not calculated for the Safety Management Systems for Certificate Holders Operating 

under 14 CFR part 121 final rule even though they could have been added to benefits.
44

 NTSB accident investigation costs for 2014 for GA aircraft are estimated at about

$40,440 per accident, and about $542,000 per accident for passenger or cargo aircraft. 

2. Effectiveness

Holistic Approach

In the NPRM’s Initial Regulatory Evaluation, the FAA identified 57 NTSB accidents, 18 

insurance claims, and 15 OSHA investigations to affirm its rationale and compute derived 

benefits of an airport’s SMS. However, limiting analysis to only those accidents, especially to 

those meeting the NTSB’s reporting and investigation threshold, fails to account for the many 

other accidents and incidents occurring on airports.

Under an SMS and its Safety Assurance program, the FAA anticipates that a certificate 

holder would use all available data including past incident/accident findings, confidential hazard 

reports, runway incursion investigations, and wildlife strike reports to proactively analyze the 

safety risks for accidents and incidents which could occur on the airport. The certificate holder

would identify root causes, proactively identify hazards, and implement mitigations where 

appropriate. This holistic approach will help the certificate holder better understand and 

implement its role in applying mitigations or controls to prevent accidents before they occur.

We also anticipate airports employing a higher level of safety vigilance in the non-movement 

area. Since existing part 139 requirements do not apply to the non-movement area, the rule 

would extend formalized safety regulation to areas not previously regulated by the FAA. Based 

on comments to the NPRM, we’ve identified a failure of many certificate holders to take 

appropriate ownership or control over these areas that have experienced many accidents or 

incidents resulting in damage, injuries, and fatalities. The industry even acknowledges its lack of 

regulatory oversight, standardization, and control. An SMS will require the certificate holder to 

exert control over the area by establishing a confidential hazard reporting system, developing 

processes to proactively identify safety issues, and implementing processes to identify hazards, 

assess safety risks, and institute mitigations when appropriate.

Using this expanded rationale, the FAA canvased additional reporting sources to identify 

accidents and incidents where the certificate holder’s SMS processes or changes to airport 
45

environment could prevent a past accident or incident. The FAA also pooled accidents and 

incidents where we believe the certificate holder has some control to prevent the accident or 

incident from occurring, but lesser than other tenants like an air carrier or fixed base operator. In 

general, an airport operator’s actions will have less impact than actions required by an air carrier 

or aircraft manufacturer. For example, while a ramp accident caused by an improperly trained 

air carrier employee directly relates to an air carrier’s operations, the certificate holder has some 

control in the ramp area to mitigate such accidents including oversight and licensing of drivers 

having unescorted access to the airport. Similarly, if a certificate holder is aware of systemic 

incidents occurring in the airport environment, they can take action to prevent future incidents or 

accidents or share lessons learned with other tenants.

Source of Accident Data

The FAA’s Office of Accident Prevention, Investigation, and Analysis (AVP) and the 

Technical Center in Atlantic City provided the original pool of accident/incident data. We 

expect airports to evaluate and analyze a broader pool of events on the airport as part of their 

Safety Assurance and SRM activities. Therefore, we decided to include accidents and incidents 

from other publicly accessible databases including FAA’s Accident/Incident Data System 

(AIDS), NASA’s Aviation Safety Reporting System (ASRS), and the Runway Incursion 

Database. The FAA also decided to include the Wildlife Strike Database since strike reports also 

present a good source of data to help proactively identify new safety hazards and/or monitor 

existing wildlife hazard management controls.

The AIDS database contains incident data records for all categories of civil aviation. 

Incidents are events that do not meet the aircraft damage or personal injury thresholds contained 

in the NTSB definition of an accident. The database is publicly accessible through FAA’s 

Aviation Safety Information Analysis and Sharing (ASIAS) System webpage5.

ASRS is a voluntary, confidential, and non-punitive incident reporting system. Pilots, air 

traffic controllers, flight attendants, maintenance technicians, ground personnel, and others 

involved in aviation operations can support reports to ASRS when they are involved in, or 

 

5 www.asias.faa.gov
46

observe, an incident or situation in which they believe aviation safety was compromised. The 

database is publicly accessible through FAA’s ASIAS website. (Dates are provided by month 

and year instead of day, month, and year.)

FAA’s Office of Runway Safety is responsible for determining whether an occurrence at an 

airport is a runway incursion and/or surface incident. Incidents selected for analysis represent 

those events that resulted in fatality, injury, or aircraft damage. The database is publicly 

accessible through FAA’s ASIAS website.

Terms like airport, runway, taxiway, ramp, apron, and foreign object debris/damage were 

used to search the NTSB, AIDS, and ASRS databases. The FAA searched the Runway Incursion 

database using terms like injury and damage.

The FAA Wildlife Strike Database contains records of reported wildlife strikes since 1990. 

Strike reporting is voluntary. Reports are typically submitted by airlines, airports, pilots, and 

other sources. The original data pool included all reported strikes at certificated airports. The 

FAA then removed airports with a certain level of USDA presence since they likely already have 

continuous monitoring efforts in place. We also removed reports of singular events at 

certificated airports since a singular wildlife strike may not provide useful data for an airport to 

take action upon or aid in continuous monitoring.

The airport safety and SMS experts from the FAA’s Office of Airport Safety and Standards 

(AAS) analyzed the accidents and incidents for their applicability and assigned effectiveness 

ratings based on review of the applicable events. FAA executive leadership and management 

were briefed, provided examples of applicable accidents and incidents, and agreed to this 

approach since this proposal included many more benefits associated with events from other 

databases, not just NTSB which has been the norm in past rulemakings. AVP’s technical 

support of other rulemakings typically focuses on air carrier and aircraft expertise and looks only 

at NTSB accidents. Since the airport community is not well represented or reflective of an air 

carrier and aircraft focus and the majority of benefits for this proposal are from non-NTSB 

sources, AAS conducted the analysis for this rulemaking.

Methodology
47

AAS used a Joint Implementation Monitoring Data Analysis Team (JIMDAT)-like method 

because many of the issues in these accidents are not well defined in the probable cause or 

contributing factors statements. This methodology was developed jointly by the aviation 

industry and FAA. The JIMDAT-type scoring system is based on AAS evaluating each safety 

enhancement against each accident in the set, to determine how effective the enhancement would 

be at removing the condition if it puts the enhancement in place.

The effectiveness rating can be viewed qualitatively in terms in terms of “high”, “medium”, 

or “low” probability that the accident would have been prevented by the enhancement. 

Numerical values are assigned corresponding to each of these qualitative assessments based on 

the consensus collective expert judgment of AAS team members. The level and percentage of 

effectiveness criteria follows:

5- >0.9 effectiveness. The proposed requirement directly addresses the causal factors and 

would prevent the accident in the future.

4- 0.6 to 0.9 effectiveness—“High”. The proposed requirement directly addresses the 

majority of the causal factors and would probably prevent or is likely to reduce the risk of the 

respective accident, given the circumstances that prevailed.

3- 0.4 to 0.599 effectiveness—“Medium”. The proposed requirement directly addresses one 

of several causal factors and is likely to reduce the risk of the respective accident, given the 

circumstances that prevailed.

2- 0.2 to 0.399 effectiveness—“Low”. The proposed requirement indirectly addresses one 

of several causal factors and is likely reduce the risk of the respective accident, given the 

circumstances that prevailed.

1- <0.2 effectiveness. The proposed requirement is likely to have reduced the risk of the 

respective accident, given the circumstances that prevailed.

We chose the low end of the ranges for the effectiveness rating (i.e., 0.2 for “low”, 0.4 for 

“medium”, and 0.6 for “high”) because the baseline case implies that safety is gradually 

improving over time. SMS at its core is a management system and can only partially 

contribute to the prevention of accidents. Since this is a SNPRM, the FAA requests
48

comment from industry on our new effectiveness rating and the use of alternative accident 

and incident databases.

The following table shows the distribution of the effectiveness criteria for the different 

databases.

Scoring Count

Effectiveness 

Criteria Wildlife AIDS NTSB ASRS OSHA RI

> 0.9 0 0 0 0 0 0

0.6 to 0.9, "High" 0 0 0 0 0 0

0.4 to 0.599, 

"Medium" 0 239 83 42 8 2

0.2 to 0.399, 

"Low" 749 173 48 3 7 2

<0.2 0 0 0 0 0 0

749 412 131 45 15 4

Wildlife

As shown in the table, for the Wildlife database, the FAA believes that a 21 percent 

effectiveness reflects the certificate holder’s ability to prevent the accident or incident using its 

SMS.

SMS monitoring, root cause analysis, and proactive hazard identification and mitigation, if 

applied to an airport’s existing wildlife management program, would reduce the number of costly 

damaging wildlife strikes. Based on a previous study including results published in the annual 

report “Wildlife Strikes to Civil Aircraft in the United States,” the FAA concludes that between 

2001 and 2009 reported damaging wildlife strikes declined by 21 percent. The FAA attributes 

this decrease to increased vigilance through improved awareness of wildlife hazards and 

development of wildlife hazard assessments. The FAA believes that continuous monitoring 

using the elements of an SMS program would have similar effects in decreasing the number of 

damaging wildlife strikes. Monitoring allows timely and cost effective mitigation which would 

result in reducing or eliminating the attractiveness of natural and artificial habitats providing 

food, water, and cover for hazardous wildlife. It also provides essential data a certificate holder 

would use to conduct trend analysis, proactive risk assessment, and targeted mitigation. 

Therefore, the FAA concludes that integration of monitoring and risk assessment through the 
49

integration of wildlife activities and SMS programs would result in the reduction in damaging 

strikes. 

3. Results for each Database

Under an SMS and its Safety Assurance program, the FAA anticipates that a certificate 

holder would analyze the variety of accidents and incidents occurring on the airport, not just 

those investigated by the NTSB. The FAA canvased additional reporting sources to identify 

accidents and incidents where the certificate holder’s actions or the airport environment 

contributed to the accident or incident. The FAA also included accidents and incidents where the 

FAA believes the certificate holder has some control to prevent the accident or incident from 

occurring, but lesser than others like the air carrier or fixed base operator. Duplicate records were 

removed.

While the following discussion summarizes the quantified benefit results for each database, 

Appendix 4 has a more detailed analysis by database. These benefits are based on the 

effectiveness of preventing past accidents and incidents multiplied by the value of social benefits 

of reduced injuries, fatalities, and equipment as discussed earlier.

3.1. National Transportation Safety Board Aviation Accident/Incident Database (NTSB) 

Benefits over 10 Years

The NTSB Aviation Accident and Incident Data System contains information collected 

during an NTSB investigation of an accident or incident involving civil aircraft within the U.S., 

its territories and possessions, and in international waters. 6

Requiring SMS implementation at all part 139 certificated airports would yield an 

estimated $63.5 million ($38.7 million when discounted at seven percent and $50.9 million when 

discounted at three percent) in benefits. Limiting that scope to only Class I airports would yield 

about $62.7 million ($38.2 million when discounted at seven percent and $50.4 million when 

discounted at three percent) in benefits. International airports would yield an estimated $58.2

million ($35.5 million when discounted at seven percent and $46.7 million when discounted at 

three percent) in benefits. For Large, Medium, and Small hub airports and airports with more 

than 100,000 total annual operations, estimated benefits are about $59.0 million ($35.9 million

when discounted at seven percent and $47.3 million when discounted at three percent). Lastly,

 

6 http://www.asias.faa.gov/pls/apex/f?p=100:24:0::NO:::
50

for the preferred alternative, Large, Medium, and Small hub airports, airports with more than 

100,000 total annual operations, and international airports, estimated benefits are about $60.2

million ($36.6 million when discounted at seven percent and $48.3 million when discounted at 

three percent). 

3.2. FAA Wildlife Strike Database Benefits over 10 Years

Proactive identification and mitigation of wildlife hazards is essential for maintaining 

airport safety. Under SMS, a certificate holder would be required to conduct proactive hazard 

identification and mitigation in its movement and non-movement areas. Enhanced reporting 

through the airport’s hazard reporting system, data collection and analysis through Safety 

Assurance, and formalized risk assessment and SRM all contribute to a continuous monitoring 

program that can be used for proactive wildlife hazard identification and mitigation. Together, 

these actions supplement existing wildlife management practices and could lead to a decrease in 

harmful and damaging wildlife strikes at airports across the country.

Many airports with wildlife hazard management programs currently engage in some form 

of continuous monitoring. However, without a wildlife biologist on-site to analyze hazard data 

and implement mitigations, certificate holders are not able to quickly react to changes in wildlife 

hazards despite continuous monitoring. The tools available under an SMS, when combined with 

an airport’s wildlife hazard management program, would ensure a more rigorous and formal 

methodology to continuous monitoring that affords a data-driven and risk-based approach.

The connection between continuous monitoring of wildlife hazards and SMS is not a new 

concept. In fact, numerous airports that participated in the FAA’s SMS pilot studies 

incorporated proactive wildlife hazard identification and mitigation into their SMS programs. 

Through formalized SRM procedures, these airports identified wildlife hazards, measured the 

risks associated with the outcomes of those hazards, and took mitigation when appropriate. 

Additionally, some airports gathered and tracked wildlife metrics that would later be used in 

trend analysis and future SRM analyses.

Industry also noted the importance of wildlife management and SMS. In 2009, 

researchers with the U.S. Department of Agriculture’s (USDA) Wildlife Services published 

“Safety Management Systems: How Useful Will the FAA National Wildlife Strike Database 

(NWSD) Be?” The researchers proposed the use of the NWSD for prioritizing wildlife risks 

through SRM. The researchers also proposed the use of statistics in the database for 
51

benchmarking and evaluating each airport specific wildlife program, which would be consistent 

with the continuous monitoring and evaluation under Safety Assurance.

The Airports Cooperative Research Program (ACRP) recently published findings for its 

project titled “Applying an SMS Approach to Wildlife Hazard Management.” This report 

introduces and guides airports in the application of a risk-based approach to wildlife hazard 

management and provides additional steps for integrating SMS practices into existing wildlife 

programs.

Analysis of wildlife strike reports (either at the local or system level) provides invaluable, 

actionable information for airport operators. Collection and tracking of additional metrics such 

as wildlife sightings and incidents would further enhance this actionable information. Wildlife 

strike reports typically identify species and location of strikes at an airport (and therefore 

possible attractant locations or travel corridors), time of strike, seasonality of strike, and phase of 

flight when the strike occurred. A certificate holder could use this data to locate and mitigate 

hazardous species, reduce wildlife strikes by modifying aircraft arrival/departure paths and 

times, and provide updated wildlife notices to pilots. This information would aid in identifying 

wildlife attractants allowing for easy, targeted, and cost-efficient mitigation.

Certificate holders could also use these reporting networks and databases to assist in 

hazard analysis. For example, a certificate holder could query the NWSD to identify the number 

of strikes on its airfield or other regional airports over a specified period of time to better analyze 

trends. The database provides a key tool for prioritizing wildlife risks and objective benchmarks 

of the effectiveness of an airport’s wildlife mitigation program and Wildlife Hazard Management 

Plan (WHMP).

The FAA Wildlife Strike Database contains records of reported wildlife strikes since 

1990. Strike reporting is voluntary. Therefore, this database only represents the information we 

have received from airlines, airports, pilots, and other sources. 7

The FAA queried the NWSD for strikes reported between January 1, 2001 and February 

28, 2010. Of those reports collected within the ten-year period, the FAA removed all events 

occurring over 3000 feet above ground level or with no elevation reported. The FAA also 

removed all reports for airports receiving USDA services with labor hours totaling greater than 

 

7 http://wildlife.faa.gov/
52

or equal to 0.5 staff years. The FAA believes that airports receiving wildlife management 

services equal to or greater than 0.5 staff years already have continuous monitoring programs in 

place that include a more formalized, data-driven approach and therefore, would realize fewer 

benefits under SMS.

The FAA then removed all strike reports for airports reporting only a singular strike over 

the 10-year period. The FAA believes that airports that have experienced multiple strikes over 

time may benefit from continuous monitoring. Under SMS, multiple strike reports afford an 

airport additional data that can be used for proactive risk assessment and monitoring. Under 

SMS, continuous wildlife monitoring would allow an airport operator to identify changes in 

wildlife composition, numbers, attractants, and travel corridors. Continuous monitoring also 

would identify changes to the airport environment that could affect the presence of wildlife.

Under SMS, strikes or wildlife activity would be reported either through the airport’s

hazard reporting system or other existing sources (e.g., daily part 139 inspections, NWSD). The 

certificate holder would then use these reports for safety assurance processes such as 

investigations, trend analysis, or program evaluations. Many certificate holders would also 

identify thresholds associated with wildlife activity for triggering more formalized risk analysis 

under SRM. For example, a certificate holder could classify wildlife sightings or incidents under 

its SMS as hazards that would trigger formalized safety risk assessment under SRM. Similarly, a 

certificate holder could identify more definitive triggers such as strikes or activity involving 

zero-tolerance species and requiring immediate formalized risk analysis and mitigation. Data 

collected through reporting, as well as the NWSD, would assist the airport by incorporating 

quantitative analysis for risk assessment. Potential mitigations could include monitoring, review 

of the WHMP, and revision of the Wildlife Hazard Assessment (WHA).

The certificate holder could use this information to quickly and efficiently implement 

mitigation techniques. Continuous monitoring through Safety Assurance would enhance airport 

safety because the frequent hazard identification and mitigation should reduce the likelihood of 

wildlife strikes. Additionally, continual monitoring should decrease the time, effort, personnel 

hours, and money spent on mitigation because hazards would be identified before they pose a 

high risk. Reporting, analysis, and mitigation together compose a continuous monitoring 

program that should prevent similar wildlife strikes and could prevent other wildlife activities on 

the airport.
53

As noted in appendix table A.2, from 2001 to 2010 there were 563 minor aircraft 

damaged (valued at $2,300 to $3.7 million per aircraft), 185 substantial aircraft damaged (valued 

at $41,900 to $9.6 million per aircraft), and 1 destroyed aircraft valued at $322,400. The FAA 

assigned a 21 percent accident prevention probability to this database and delayed benefits to 

2018 since airports would have 2 years for implementation. Over the five alternatives, the cost 

avoidance of aircraft damage costs ranges from $189 million to $206 million. Out-of-service

costs are estimated at about $570,000 to $617,000.

Requiring SMS implementation at all part 139 certificated airports would yield an 

estimated $206.9 million ($126.0 million when discounted at seven percent and $166.1 million 

when discounted at three percent) in benefits. Limiting that scope to only Class I airports would 

yield about $195.1 million ($118.9 million when discounted at seven percent and $156.7 million 

when discounted at three percent) in benefits. International airports would yield an estimated 

$193.6 million ($117.9 million when discounted at seven percent and $155.4 million when 

discounted at three percent) in benefits. For Large, Medium, and Small hub airports and airports 

with more than 100,000 total annual operations, estimated benefits are about $189.8 million 

($115.6 million when discounted at seven percent and $152.4 million when discounted at three 

percent). Finally, for the preferred alternative, Large, Medium, and Small hub airports, airports 

with more than 100,000 total annual operations, and international airports, estimated benefits are 

about $200.5 million ($122.2 million when discounted at seven percent and $161.0 million when 

discounted at three percent). 

3.3. Aviation Accident/Incident Database (AIDS) Benefits over 10 Years

The AIDS database contains incident data records for all categories of civil aviation. 

Incidents are events that do not meet the aircraft damage or personal injury thresholds contained 

in the NTSB definition of an accident. 8 As noted in appendix table A.3, from 2000 to 2010 there 

were 21 minor injuries and 31 aircraft incurred substantial damage (valued at $41,900 to $9.6

million per aircraft) while 364 sustained minor damage (valued at $2,300 to $3.7 million per 

aircraft). The FAA assigned a 20 percent or 40 percent accident prevention probability to this 

database and delayed benefits to 2018 since airports would have 2 years for implementation. 

 

8 http://www.asias.faa.gov/pls/apex/f?p=100:12:0::NO:::
54

Over the five alternatives, the cost avoidances would include casualty costs ranging from 

$128,500 to $137,400; aircraft damage costs ranging from $70.2 million to $74.9 million; out-ofservice costs ranging from $138,600 to $141,400; and investigation costs ranging from $209,300

to $281,000. 

The FAA estimates that requiring SMS implementation at all part 139 certificated 

airports would yield an estimated $75.5 million ($46.0 million when discounted at seven percent

and $60.6 million when discounted at three percent) in benefits. Limiting that scope to only 

Class I airports would yield about $73.2 million ($44.6 million when discounted at seven percent 

and $58.7 million when discounted at three percent) in benefits. International airports would 

yield an estimated $72.7 million ($44.3 million when discounted at seven percent and $58.4 

million when discounted at three percent) in benefits. For Large, Medium, and Small hub 

airports and airports with more than 100,000 total annual operations estimated benefits are about 

$70.6 million ($43.0 million when discounted at seven percent and $56.7 million when 

discounted at three percent). Finally, for the preferred alternative, Large, Medium, and Small hub 

airports, airports with more than 100,000 total annual operations, and international airports, 

estimated benefits are about $73.4 million ($44.7 million when discounted at seven percent and 

$58.9 million when discounted at three percent). 

3.4. Aviation System Reporting System (ASRS) Benefits over 10 Years

 The ASRS is a voluntary, confidential, and non-punitive incident reporting system. Pilots, 

air traffic controllers, flight attendants, maintenance technicians, ground personnel, and others 

involved in aviation operations can submit reports to the ASRS when they are involved in, or 

observe, an incident or situation in which they believe aviation safety was compromised. 9

As noted in appendix table A.4, from 2001 to 2011 there were 2 injuries and 29 aircraft 

incurred damage (we assumed minor damage valued at $19,400 to $3.7 million per aircraft). The 

FAA assigned a 20 percent or 40 percent accident prevention probability to this database and 

delayed benefits to 2018 since airports would have 2 years for implementation. Over the five 

alternatives, the cost avoidances include: casualty costs of $13,300 (there were 45 accidents); 

 

9 http://www.asias.faa.gov/pls/apex/f?p=100:19:0::NO:::
55

aircraft damage costs, ranging from $9.8 million to $10.5 million; and out-of-service costs 

ranging from $8,600 to $9,300. 

The FAA estimates that requiring SMS implementation at all part 139 certificated 

airports would yield an estimated $10.5 million ($6.4 million when discounted at seven percent 

and $8.5 million when discounted at three percent) in benefits. Limiting that scope to only Class 

I airports would yield about $10.5 million ($6.4 million when discounted at seven percent and 

$8.4 million when discounted at three percent) in benefits. International airports would yield an 

estimated $9.8 million ($6.0 million when discounted at seven percent and $7.9 million when 

discounted at three percent) in benefits. For Large, Medium, and Small hub airports and airports 

with more than 100,000 total annual operations, estimated benefits are about $10.2 million ($6.2

million when discounted at seven percent and $8.2 million when discounted at three percent). 

Lastly, for the preferred alternative, Large, Medium, and Small hub airports, airports with more 

than 100,000 total annual operations, and international airports, estimated benefits are about 

$10.2 million ($6.2 million when discounted at seven percent and $8.2 million when discounted 

at three percent). 

3.5. Occupational Safety and Health Administration (OSHA) Benefits over 10 Years

OSHA’s Fatality and Catastrophe Investigation Summaries (also known as Accident 

Investigation Summaries) contain inspection reports developed after a fatality or catastrophe. 

Each summary provides descriptions of the incident, general events leading up to the incident, 

and causal factors. The database is searchable using various parameters including the standard 

industrial classification (SIC).

10

 The FAA pulled 10-years of reports from four SIC’s:

 4213 – Trucking, Except Local;

 4512 – Air Transportation, Scheduled;

 4513 – Air Courier Services; and,

 4581 – Airports, Flying Fields, and Airport Terminal Services.

The FAA reviewed each summary for relevance to the safety of aircraft/airport operations 

in the movement and non-movement areas of the airfield. All accidents used for this analysis 

represent operational safety issues.

 

10 https://www.osha.gov/pls/imis/accidentsearch.html
56

Requiring SMS implementation for any of the five alternatives would yield an estimated 

$26.6 million ($16.2 million present value) in benefits. There were 15 OSHA accidents that 

occurred at airports that were in all of the alternatives.

As noted in appendix table A.5, from 2001 to 2011 there were 11 fatalities and 4 minor 

injuries. The FAA assigned a 20 percent or 40 percent accident prevention probability to this 

database and delayed benefits to 2018 since airports have 2 years for implementation. Over the 

five alternatives, the cost avoidance of casualty costs would be $26.6 million (there were 15 

accidents). 

3.6. Runway Incursion (RI) Database Benefits over 10 Years

The FAA Office of Runway Safety is responsible for determining whether an occurrence 

at an airport is a runway incursion and/or surface incident. Only surface events at airports with 

an operating air traffic control tower are recorded and classified as runway incursions and 

surface incidents. 11 Incidents selected for this analysis represent those surface events resulting 

in fatality, injury, or aircraft damage.

As noted in appendix table A.6, from 2001 to 2011, there was 1 injury. The FAA 

assigned a 20 percent or 40 percent accident prevention probability to this database and delayed 

benefits to 2018 since airports would have 2 years for implementation. 

Requiring SMS implementation at all part 139 certificated airports would yield an 

estimated $7,000 ($4,200 when discounted at seven percent and $5,600 when discounted at three 

percent) in benefits. Limiting that scope to only Class I airports, or Large, Medium, and Small 

hub airports and airports with more than 100,000 total annual operations would yield an 

estimated $5,700 ($3,500 when discounted at seven percent and $4,600 when discounted at three 

percent) in benefits. International airports and the preferred alternative of Large, Medium, and 

Small hub airports and airports with more than 100,000 total annual operations and international 

airports would yield an estimated $6,600 ($4,000 when discounted at seven percent and $5,300 

when discounted at three percent) in benefits. 

 

11 http://www.asias.faa.gov/pls/apex/f?p=100:28:0::NO:28::
57

4. Sensitivity Analysis

The FAA considered a sensitivity analysis of the effects of using alternative VSL values 

as shown in the following 2 tables.

For the low alternative value of $5.2 million and the high alternative value of $13.0

million, the last three airport groups continue to show a positive difference between benefits and 

costs. 

Comparison of Costs and Benefits over 10 years using VSL of $5.2 Million

Low case All Class I International L, M, S and 

>100K ops

L, M, S, >100K 

ops, and 

International

Benefits $368,928,248 $354,045,556 $347,014,423 $342,397,895 $356,887,797

Costs $471,104,787 $341,021,606 $215,010,997 $163,760,850 $238,865,692

Net Benefits -$102,176,539 $13,023,950 $132,003,426 $178,637,045 $118,022,105

PV Benefits (7%) $224,747,677 $215,679,751 $211,396,148 $208,583,768 $217,411,924

PV Costs (7%) $307,842,595 $223,584,687 $141,796,001 $108,819,973 $157,496,312

PV Net Benefits (7%) -$83,094,918 -$7,904,936 $69,600,147 $99,763,795 $59,915,612

PV Benefits (3%) $296,227,774 $284,276,962 $278,631,200 $274,924,377 $286,559,525

PV Costs (3%) $389,440,320 $282,304,199 $178,432,284 $136,340,226 $198,211,977

PV Net Benefits (3%) -$83,094,918 -$7,904,936 $69,600,147 $99,763,795 $59,915,612

Comparison of Costs and Benefits over 10 years using VSL of $13.0 Million

High case All Class I International L, M, S and 

>100K ops

L, M, S, >100K 

ops, and 

International

Benefits $395,037,884 $380,140,485 $372,815,226 $367,897,225 $382,703,308

Costs $471,104,787 $341,021,606 $215,010,997 $163,760,850 $238,865,692

Net Benefits -$76,066,903 $39,118,879 $157,804,229 $204,136,375 $143,837,615

PV Benefits (7%) $240,598,566 $231,521,708 $227,059,553 $224,064,144 $233,084,256

PV Costs (7%) $307,842,595 $223,584,687 $141,796,001 $108,819,973 $157,496,312

PV Net Benefits (7%) -$67,244,029 $7,937,021 $85,263,552 $115,244,171 $75,587,944

PV Benefits (3%) $317,160,562 $305,197,956 $299,316,386 $295,367,867 $307,256,502

PV Costs (3%) $389,440,320 $282,304,199 $178,432,284 $136,340,226 $198,211,977

PV Net Benefits (3%) -$67,244,029 $7,937,021 $85,263,552 $115,244,171 $75,587,944
58

5. Benefit-Cost Comparison

The following table shows a comparison of benefits and costs (excluding benefits and

costs of mitigations) for each alternative:

Comparison of Costs and Benefits over 10 years (2014 Dollars)

Base Case All Class I International L, M, S and 

>100K ops

Preferred 

alternative: L, 

M, S, >100K 

ops, and 

International

Benefits $382,987,281 $368,096,671 $360,907,166 $356,128,301 $370,788,457

Costs $471,104,787 $341,021,606 $215,010,997 $163,760,850 $238,865,692

Net Benefits -$88,117,506 $27,075,065 $145,896,169 $192,367,451 $131,922,764

PV Benefits (7%) $233,282,770 $224,210,033 $219,830,291 $216,919,352 $225,850,869

PV Costs (7%) $307,842,595 $223,584,687 $141,796,001 $108,819,973 $157,496,312

PV Net Benefits (7%) -$74,559,825 $625,346 $78,034,290 $108,099,379 $68,354,557

PV Benefits (3%) $307,499,272 $295,542,114 $289,769,378 $285,932,407 $297,704,052

PV Costs (3%) $389,440,320 $282,304,199 $178,432,284 $136,340,226 $198,211,977

PV Net Benefits (3%) -$74,559,825 $625,346 $78,034,290 $108,099,379 $68,354,557

Mitigation Costs: Not quantified, estimates not included.

Given the range of mitigation actions possible, it is difficult to quantify potential benefits.

Although the preferred alternative is not the most cost beneficial alternative, it is the 

FAA’s preferred alternative for two reasons. First, these airports account for approximately 98% 

of all passenger enplanements in the U.S. While simply applying the proposed requirement to 

Large, Medium, and Small hub certificated airports would account for most of this traffic, many 

critical airports within the U.S. system would not be included and yet have over 100,000 aircraft 

operations. Therefore, to ensure that busy airports such as these are captured in this proposed 

requirement, the preferred alternative would include airports with more than 100,000 total annual 

operations. 

Second, the pool of airports characterized as Large, Medium, and Small hub airports, or 

certificated airports with more than 100,000 total annual operations is large, but still does not 

completely account for all certificated airports able to receive international traffic. In order to 

fully harmonize with the intent of international SMS standards, the FAA alternative includes 
59

certificated airports. The FAA also proposes all certificated airports hosting international 

operations meet the proposed requirement. The FAA preferred alternative has benefits of $370.8

million ($225.9 million when discounted at seven percent and $297.7 million when discounted at 

three percent), which exceed the estimated costs of $238.9 million ($157.5 million when 

discounted at seven percent and $198.2 million when discounted at three percent).

V. NPRM Comments and FAA Response

Comment:

Three certificate holders stated that the Initial Regulatory Evaluation did not account for 

the cost of attrition on training and training records and lost productivity during training. 

FAA Response: 

The FAA is not including an attrition rate in this analysis because the number of 

employees requiring training significantly decreased compared to the number covered by the 

NPRM’s proposed training requirements. Thus, there is no basis to determine an attrition rate for 

the estimated maximum 10 employees per airport. Additionally, concerning the lost productivity,

the training period is short enough to be of negligible impact on yearly productivity. 

Comment:

One certificate holder commented that the legal cost associated with discoverable 

material was not included in the cost of the rule. 

FAA Response: 

These legal costs were not included in the Initial Regulatory Evaluation as they are 

outside the scope of the proposal. We do not include this type of cost in the regulatory 

evaluation supporting the SNPRM for the same reason.

Comment:

Seven certificate holders disputed the labor rates. 

FAA Response: 

Labor rates were taken from the Bureau of Labor Statistics for aviation and are 

representative industry salaries.

Comment:

Several commenters stated that the FAA failed to include mitigation costs. 

FAA Response:
60

As discussed and acknowledged in both the SNPRM and this Regulatory Evaluation, the

estimated costs of this rule do not include the cost of mitigations that operators could incur as a 

result of conducting the risk analysis proposed in this rule. Given the range of mitigation actions 

possible, it is difficult to provide a quantitative estimate of both the costs and benefits of such 

mitigations. We anticipate that operators will only implement mitigations where benefits of 

doing so exceed the costs of the mitigations. In order for the estimated benefits to exceed the 

costs of the rule, the mitigation costs must be below $68.4 million over 10 years (discounted at 

7%). The FAA requests comment on this assumption, as well as data regarding costs and 

benefits associated with any mitigations implemented through a voluntary SMS program.

Comment:

One consultant stated that the benefits derived in the regulatory evaluation were for the 

airline industry and not necessarily the airports that are incurring the direct cost. 

FAA Response:

Based on OMB Circular A-4, the FAA is responsible for calculating the societal benefits 

of a regulation, which includes, but is not limited to, the benefits to airports. 

Under an SMS, an airport will have reporting, analysis, and communications systems that 

will enable it to influence not only actions directly related to airport operations but also events 

that may not be directly in their control but still in the airport environment. For example, while a 

ramp accident caused by an improperly trained air carrier directly relates to an air carrier’s 

operations, an airport has some control in the ramp area to defend against accidents like these 

including oversight and licensing of drivers with unescorted airfield access.

Similarly, if a certificate holder is aware of systemic incidents occurring in the airport 

environment, they may be able to take action to prevent future incidents or accidents or share 

lessons learned with other tenants. For example, if an airport operator becomes aware of a 

hazard in one tenants apron that has the potential to be a hazard in another tenants operating area, 

the airport will have tools in place under their SMS where these hazards would be reported, 

analyzed and communicated with other tenants.

Comment:

Six certificate holders and two trade associations stated that costs were underestimated. 

For example, one certificate holder stated that the cost of initial SMS planning, data collection, 
61

documentation, and implementation processes were underestimated. It estimated planning, data 

collection, documentation, and implementation to be no less than $400,000 for its airport and 

initial training costs expected to exceed $300,000. 

FAA Response:

The FAA used information from pilot study participants both before and after the Initial 

Regulatory Evaluation to estimate costs and could not validate the cost estimates provided above. 

Comment:

One trade association commented that this rule would have a cost on other industries such 

as carriers and maintenance companies in addition to a negative-cost benefit ratio in present 

value terms. 

FAA Response:

The proposed rule only directly impacts airports; however, the FAA did acknowledge a 

negative present value cost-benefit ratio for airports in the Initial Regulatory Evaluation. The 

preferred alternative in the SNPRM is cost beneficial.

Comment:

Another trade association mentioned that, with this range, benefits could be above or 

below costs. 

FAA Response:

The FAA acknowledges that benefits in the Initial Regulatory Evaluation could be above 

or below cost. The preferred alternative in the SNPRM is cost beneficial.

Comment:

One certificate holder disputes the minimal cost option under the guise that this is 

different than what was reported by the pilot study airports.

FAA Response:

In response to comments and lessons learned from the pilot studies, the SNPRM analysis 

revises costs to be consistent with the pilot study participant responses.

Comment:

One certificate holder stated that additional training would be required on the nonmovement areas, and this is an area that is not currently regulated by airports. Several 

commenters, including two certificate holders, were concerned that training all individuals with 
62

access to the airside on SMS and operational safety includes a larger number of non-airport 

employees that were not included in this analysis. 

FAA Response:

In response to comments and lessons learned from the pilot studies, the SNPRM modifies

the training requirement to a two-pronged approach to training: (i) comprehensive SMS training 

specific to individuals with direct SMS responsibilities; and, (ii), for the majority of staff, only

hazard awareness and reporting awareness orientation. Hazards can occur in the movement and 

the non-movement area, therefore the FAA believes there is value in hazard awareness 

orientation and reporting to support the proactive identification and mitigation of hazards. The

proposal includes a hazard awareness orientation for individuals accessing the non-movement 

areas which should minimize the burden on the certificate holder for providing this orientation.

Comment:

Several commenters disputed the time required for training. For example, one certificate 

holder stated that it believed 45 minutes per employee would be necessary to provide training 

and to ensure that the employee demonstrates acceptable levels of competency. 

FAA Response:

The training proposed in the SNPRM is only required for individuals with direct SMS 

responsibilities. That training is estimated to take 3 hours annually.

Comment:

Two certificate holders reported the need for additional staffing such as a program 

manager, an assistant program manager, an administrative assistant, or management and other 

staffing resources required from various levels of the organization. 

FAA Response:

The FAA reevaluated staffing requirements based on the FAA SMS Pilot Studies 

Technical Report May dated May 2011, which are discussed in the “Staffing Section” of this 

document.

Comment:

To compute the time required to update employee training records for the Paperwork 

Reduction Act analysis, the FAA estimated that there were 72,800 employees for all 562 

certificated airports (at the time of the NPRM). One certificate holder argued that the FAA 

“significantly underestimated the number of employees” and that the 72,800 employees “would 
63

translate to an average of 129 employees per airport.” The certificate holder further stated that 

its certificated airports alone had 67,000 individuals with access to the movement or nonmovement areas that would need to receive training.

FAA Response:

The FAA did not use the total number of employees at an airport in the SNPRM 

evaluation since only those airport employees with direct SMS responsibilities would require 

comprehensive SMS training. All other employees, which are the majority of the staff, only

require hazard awareness and reporting awareness orientation. 

Comment:

Four certificate holders stated that the FAA did not include the cost of hiring a consultant.

FAA Response:

The majority of airports hired consultants to develop their SMS and those costs, where 

applicable, are included in the development costs. However, for implementation and continuous 

monitoring, airports reported using existing staff or hiring new staff. Therefore, ongoing 

consultant costs were not included.

Comment:

One certificate holder stated that the FAA underestimated additional staffing for 

development and implementation of an SMS. 

FAA Response:

The FAA included the total cost reported by pilot study participants for development, 

implementation, and continuous operation of an SMS. This cost included staffing for all three 

stages. 

Comment:

Many commenters, including three certificate holders and two trade associations,

reported an additional burden on small airports that they believe was not included on the Initial 

Regulatory Evaluation.

FAA Response:

The FAA reevaluated the impact on airports by different groupings to assess the burden 

on smaller airports. Based on this analysis, the FAA changed the scope of the SNPRM to affect 

only Large, Medium, and Small hub airports, airports with more than 100,000 total annual 

operations, and airports accepting international traffic. This applicability still advances the 
64

FAA’s safety goals by targeting airports with over 98% of all passenger enplanements. Because 

the SNPRM limits the applicability of SMS requirements, many of the smaller airports are no 

longer included in the preferred alternative, thereby reducing the overall burden to smaller 

airports. The SNPRM further clarifies the scalability of SMS which the FAA believes mitigates 

the burden on smaller airports and is discussed in “Regulatory Flexibility Determination” section 

of the SNPRM.

Comment:

One certificate holder disputes the definition of a small airport by operation and class. 

FAA Response:

The FAA maintains that the number of operations and class help determine the size of an 

airport, which is discussed in the “Regulatory Flexibility Determination” section of the SNPRM.

For the purposes of this analysis, certain costs were also evaluated based on the size and

complexity of operations which ties to the scalability of the proposed requirements. The FAA 

categorized all Large, Medium, and Small hub airports as “large airports” in this analysis and all 

other certificated airports as “small airports.” 

Comment:

Two trade associations disputed the accidents selected for benefits. 

FAA Response:

The FAA reevaluated all accidents in response to comments. A detailed list of accidents 

and their possible SMS related mitigation are provided in Appendix 1. 

Comment:

One trade association disputed the FAA’s use of numerous accidents and incidents in 

calculating the benefits of airport SMS. In its comments, the association argued its point using 

three specific accidents:

1. NTSB Accident Number CHI04LA077: On February 24, 2004, a Saab-340B sustained 

substantial damage when it struck an unoccupied airplane while it was being pushed back 

for taxi at Detroit Metropolitan/Wayne County Airport. NTSB cited the probable cause 

as the tug operator’s failure to maintain visual lookout and follow procedures. 

Contributing factors included the nighttime conditions on the ramp.

2. NTSB Accident Number DCA05MA070: On June 7, 2005, a mobile belt baggage loader 

was driven under and struck an Embraer EMB-170 at Reagan National Airport. The 
65

driver of the baggage loader was fatally injured and the aircraft received minor damage. 

The NTSB determined the probable cause of the accident was the inexperience of the 

baggage loader driver.

3. NTSB Accident Number IAD05CA019: On November 29, 2004, the right winglet of an 

Embraer EMB-135BJ collided with a parked airplane while the crew taxied the aircraft to 

the ramp area at Cleveland-Hopkins International Airport. While standard operating 

procedures required a marshaller to assist the flight crew with parking, the flight crew 

taxied behind the parked airplane when a marshaller did not arrive. The accident report 

noted that there were no non-movement area boundary markings and that the ramp had 

been repaved 36 days prior to the accidents. With no markings present, there were no 

visual cues for taxiing along a designated path, and no edge markings or edge lighting to 

define the edge of the usable pavement. The NTSB noted the lack of ramp markings as a 

contributing factor in the accident.

FAA Response:

The FAA confirms that the three accidents identified by the association were included in 

the Initial Regulatory Evaluation. The FAA reviewed all of the accidents used in the Initial 

Regulatory Evaluation, including these three, to consider their applicability based on the revised 

proposal.

The association argued that NTSB Accident Number IAD05CA019 “involved decisions 

very, very far from the purview of an airport’s operator safety responsibilities.” While the FAA 

agrees that this accident is a direct result of the flight crew’s improper decision to taxi without a 

marshaller, the NTSB cited airport conditions as a contributing factor. Therefore, actions by the 

airport operator could have decreased the likelihood of the accident occurring.

Under SMS, changes in airport operations would trigger the certificate holder’s SRM 

processes to proactively identify hazards and put mitigations in place (See §§139.402(b)(1) and 

(2)). Repaving in the movement or non-movement area is a change in airport operations; it could 

disrupt existing procedures, signage, and markings. In this case, proactive analysis would likely 

identify pilot confusion as a potential hazard (See §139.402(b)(ii)) during the period between 

paving and painting. Potential mitigations to reduce the risk associated with pilot confusion 

include Notices to Airmen (NOTAMs), procedure changes, and temporary markings, signage, or 

lighting (See §139.402(b)(v)). The certificate holder’s Safety Promotion program would also 
66

help to better proactively communicate these actions and include tenants in airport changes (See 

§139.402(d)(5)). Additionally, under SMS, a certificate holder would investigate accidents and 

incidents under its Safety Assurance activities to identify hazards and gain lessons learned (See 

§139.402(c)(1)). Using this information, it would incorporate lessons learned into future 

operational changes.

The association argued that NTSB Accident Number CHI04LA077 “involved a pushback 

operator who failed to follow proper airline procedures and lost visual contact with the wing 

walker...clearly the airline had an adequate policy in place which is under the scope of the 

airline’s internal safety program, a policy that would not have fallen into the scope of a Part 139 

SMS.” The association also argued that NTSB Accident Number DCA05MA070 “involved the 

fatal injury of a belt loader operator...this accident might have been prevented through an 

airline’s SMS program, but we cannot see how it would have been addressed via an airport’s 

SMS program.” While the FAA agrees that the primary causes of these accidents lie with the 

airline, actions by the certificate holder in either accident could have decreased the likelihood of 

the accidents occurrence. Similarly, actions by the certificate holder in response to these 

accidents could decrease the likelihood of future accidents.

In CHI04LA077, the NTSB cited the dark night conditions on the ramp as a contributing 

factor to the accident. The certificate holder and/or airport owner has overarching responsibility 

for the ramp area. Under SMS, an accident such as this would be investigated using the 

certificate holder’s Safety Assurance processes to identify hazards and gain lessons learned (See 

§139.402(c)(1)). In this case, the certificate holder may decide that the hazards and risks 

associated with the dark area of the ramp can be mitigated through airport-initiated actions (e.g., 

lighting or limiting access during night hours). The certificate holder’s Safety Promotion 

program would also help it communicate these lessons learned and mitigations to other tenants 

engaged in similar activities in the ramp area therefore decreasing the likelihood of similar 

accidents (See §139.402(d)(5)). Airports will also establish hazard reporting systems (See 

§139.402(c)(2)) where individuals with access to the airfield will be able to report safety issues 

such as inoperable or missing lighting; where the certificate holder is able to take action before 

the accident even occurs.

In DCA05MA070, the certificate holder is responsible for maintaining access to its 

airfield environment (See §139.329). A certificate holder would usually institute driver 
67

credentialing, training programs, and rules and regulations to oversee access by tenants and 

airport employees. Again, a certificate holder’s Safety Assurance processes would trigger 

investigation and the identification of hazards to gain lessons learned (See §139.402(c)(1)). The 

certificate holder’s Safety Promotion program would help it communicate those lessons learned 

to other tenants engaged in similar activities on the airfield, potentially decreasing the likelihood 

of similar accidents (See §139.402(d)(5)).

Unlike the Initial Regulatory Evaluation where the FAA analyzed all of the applicable 

NTSB accidents in similar terms, the SNPRM acknowledges that there are accidents, like 

CHI04LA077 and DCA05MA070, where the certificate holder played a lesser role in the cause 

of the accident, or their actions could have added additional controls to mitigate the accident or 

decease the likelihood of the accidents occurrence. In these cases, the FAA is using a lower 

effectiveness to account for the benefit of SMS relative to the accident.

Another trade association also argued the FAA’s use of two accidents it says the agency 

used “to set the basis for establishing the SMS program on all part 139 airports.” The association 

references “the Pinnacle Airlines Flight 3701 and the Cessna 310R aircraft accidents.”

Since the association did not provide additional details regarding its cited accidents, the FAA 

believes the “Pinnacle Airlines Flight 3701” accident refers to NTSB Accident Number 

DCA05MA003. On October 14, 2004, Pinnacle Airlines Flight 3701, a Bombardier CL-600, 

crashed into a residential area approximately 2.5 miles south of Jefferson City Memorial Airport 

(JEF). The NTSB determined the probable cause based on multiple factors including the pilots’ 

unprofessional behavior, failure to prepare for emergency landing in a timely manner, and 

improper management of the double engine failure checklist.

The Initial Regulatory Evaluation did not include NTSB Accident Number 

DCA05MA003. It is not included in this analysis.

The FAA searched the NTSB aviation accident database to determine whether any of the 

accidents cited in the Initial Regulatory Evaluation included a “Cessna 310R”. Using the period 

between 1/1/2004 and 12/31/2008 and the search criteria of Make: Cessna and Model: 310R, the 

FAA was unable to match the query results with the list of NTSB accidents cited in the Initial 

Regulatory Evaluation. Therefore, the FAA is unable to respond to the association’s comment 

regarding the “Cessna 310R” aircraft accident.
68
69

Appendix 1: Accident History
70
71 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

1 1/5/2001 NC KCLT B-737-300 Minor 21%

2 1/5/2001 FL KMIA B-757-200 Substantial 21%

3 1/21/2001 OR KPDX MD-11 Substantial 21%

4 1/26/2001 FL KMCO B-767 Substantial 21%

5 2/21/2001 LA KMSY MD-88 Minor 21%

6 2/25/2001 OR KPDX B-737-700 Minor 21%

7 3/4/2001 FL KJAX B-737-500 Substantial 21%

8 3/9/2001 NC KCLT A-319 Minor 21%

9 3/20/2001 C O KALS C-340 Substantial 21%

10 3/26/2001 C A KSAN B-737-300 Minor 21%

11 4/10/2001 MA KHYA C-402 Minor 21%

12 4/13/2001 GA KATL A-320 Minor 21%

13 4/15/2001 MA KBOS EMB-135 Minor 21%

14 4/17/2001 AZ KPHX B-757-200 Minor 21%

15 4/19/2001 TX KHOU B-737-500 Substantial 21%

16 4/19/2001 TX KIAH B-737-300 Minor 21%

17 4/21/2001 OR KPDX MD-80 Minor 21%

18 4/26/2001 OH KCMH A-320 Minor 21%

19 4/26/2001 MI KDTW B-757-200 Substantial 21%

20 5/1/2001 AL KMOB MD-88 Minor 21%

21 5/3/2001 C A KSAN A-319 Substantial 21%

22 5/15/2001 WI KMSN C-500 Substantial 21%

23 5/16/2001 TX KAMA BE-1900 Minor 21%

24 5/16/2001 OH KDAY DC-10-10 Substantial 21%

25 6/5/2001 FL KRSW B-767-200 Minor 21%

26 6/9/2001 OH KDAY A-300 Substantial 21%

27 6/13/2001 FL KMCO B-737-200 Minor 21%

28 6/26/2001 OR KPDX B-757-200 Minor 21%

29 7/4/2001 FL KSFB C-172 Minor 21%

30 7/5/2001 AL KMOB MD-88 Minor 21%

31 7/12/2001 OR KPDX B-737-300 Minor 21%

32 7/15/2001 WV KMGW BE-1900 Substantial 21%

33 7/17/2001 LA KMSY B-737-400 Minor 21%

34 7/18/2001 NV KEKO B-737-200 Substantial 21%

35 7/18/2001 NH KMHT B-757-200 Substantial 21%

36 7/28/2001 C A KSJC B-757-200 Minor 21%

37 8/1/2001 TX KAUS B-727-200 Minor 21%

38 8/5/2001 FL KMCO B-737-200 Substantial 21%

39 8/15/2001 FL KSRQ B-727 Minor 21%

40 8/16/2001 NY KISP B-737-200 Substantial 21%

41 8/17/2001 NY KISP B-737-200 Minor 21%

42 8/18/2001 NY KALB B-737 Minor 21%

43 8/18/2001 RI KPVD CL-RJ100/200 Minor 21%

44 8/19/2001 C A KSBA C-172 Minor 21%

45 8/20/2001 NY KALB B-737-300 Substantial 21%

46 8/20/2001 NY KROC B-737-400 Minor 21%

47 8/23/2001 FL KDAB C-172 Minor 21%

48 8/25/2001 TX KAMA B-737 Minor 21%

49 9/5/2001 MA KBOS B-767-300 Minor 21%

50 9/5/2001 NY KELM C-172 Minor 21%

51 9/6/2001 MI KDTW A-320 Substantial 21%

52 9/8/2001 GA KSAV CL-RJ100/200 Minor 21%

53 9/9/2001 FL KMIA A-320 Minor 21%

54 9/10/2001 MA KBOS B-757-200 Minor 21%

55 9/25/2001 WI KMSN C-500 Minor 21%

56 10/6/2001 FL KSFB C-172 Substantial 21%

57 10/15/2001 FL KMCO CL-RJ100/200 Minor 21%

58 10/19/2001 KS KICT BE-300 KING Minor 21%

59 10/19/2001 FL KTPA A-320 Minor 21%

60 10/25/2001 FL KMCO MD-80 Minor 21%

61 10/27/2001 RI KPVD C-402 Minor 21%

62 10/29/2001 NY KBUF B-737-400 Substantial 21%

63 10/29/2001 SC KCAE C-172 Minor 21%

64 10/30/2001 LA KMSY B-737-300 Minor 21%

65 10/30/2001 RI KPVD A-319 Minor 21%

66 10/31/2001 NY KALB B-737-400 Minor 21%

Table A.2. Wildlife Strike History
72 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

67 11/2/2001 RI KPVD B-757-200 Minor 21%

68 11/3/2001 OH KILN B-767-200 Minor 21%

69 11/3/2001 AR KLIT B-737-200 Minor 21%

70 11/7/2001 GA KCSG BE-300 KING Minor 21%

71 11/11/2001 WV KCRW BE-1900 Minor 21%

72 11/14/2001 FL KDAB MD-88 Minor 21%

73 11/15/2001 MS KJAN CL-RJ100/200 Minor 21%

74 11/26/2001 AZ KPHX B-737-300 Substantial 21%

75 11/27/2001 FL KSFB B-727-200 Minor 21%

76 12/3/2001 C A KSFO B-767-200 Substantial 21%

77 12/6/2001 MI KDTW B-737 Substantial 21%

78 12/6/2001 FL KTIX C-152 Minor 21%

79 12/8/2001 C A KSFO A-319 Minor 21%

80 12/17/2001 TN KBNA B-737-300 Minor 21%

81 12/29/2001 NV KLAS B-737-300 Minor 21%

82 1/3/2002 C A KSBA BE-300 KING Minor 21%

83 1/12/2002 FL KMCO MD-11 Minor 21%

84 1/29/2002 TX KAUS A-319 Substantial 21%

85 1/30/2002 FL KTPA A-320 Minor 21%

86 2/2/2002 C T KBDL EMB-145 Substantial 21%

87 2/2/2002 C A KSFO B-767-200 Minor 21%

88 2/5/2002 C A KSNA B-737-300 Minor 21%

89 2/8/2002 RI KPVD B-737 Minor 21%

90 2/9/2002 AZ KPHX A-320 Minor 21%

91 2/12/2002 TN KBNA B-757-200 Minor 21%

92 2/17/2002 FL KFLL B-727-200 Minor 21%

93 2/21/2002 AZ KPHX BE-1900 Substantial 21%

94 3/1/2002 LA KMSY A-319 Minor 21%

95 3/2/2002 FL KFLL B-727-200 Minor 21%

96 3/7/2002 C A KSFO A-319 Minor 21%

97 3/8/2002 SC KCAE CL-RJ100/200 Minor 21%

98 3/9/2002 C A KSFO B-757-200 Minor 21%

99 3/16/2002 FL KMCO A-320 Substantial 21%

100 3/23/2002 C A KBUR B-737-700 Minor 21%

101 3/29/2002 FL KDAB C-172 Minor 21%

102 4/2/2002 WA KGEG A-319 Minor 21%

103 4/7/2002 C A KSAN B-767-200 Minor 21%

104 4/11/2002 NV KLAS A-320 Minor 21%

105 4/16/2002 NV KLAS A-320 Minor 21%

106 4/21/2002 TX KSAT B-737-300 Substantial 21%

107 4/22/2002 VA KROA CL-RJ100/200 Minor 21%

108 4/23/2002 OR KPDX B-757-200 Minor 21%

109 4/26/2002 C A KLGB MD-82 Minor 21%

110 4/27/2002 FL KFLL CL-600 Minor 21%

111 4/30/2002 SD KFSD CL-RJ100/200 Minor 21%

112 5/7/2002 C A KSFO A-320 Minor 21%

113 5/8/2002 TX KDAL B-737-500 Minor 21%

114 5/9/2002 FL KDAB C-172 Minor 21%

115 5/16/2002 KY KLEX CL-RJ100/200 Minor 21%

116 5/23/2002 OR KPDX B-737 Minor 21%

117 5/26/2002 MI KDTW MD-80 Minor 21%

118 5/27/2002 TX KMAF B-737-200 Substantial 21%

119 5/31/2002 TN KBNA B-737-300 Substantial 21%

120 6/5/2002 TX KHOU B-737-200 Substantial 21%

121 6/6/2002 FL KSFB C-172 Minor 21%

122 6/9/2002 C A KSJC B-737-300 Substantial 21%

123 6/10/2002 FL KSRQ B-737-300 Minor 21%

124 6/20/2002 FL KTPA B-727-200 Minor 21%

125 6/22/2002 NC KRDU A-319 Substantial 21%

126 6/26/2002 NC KCLT A-319 Substantial 21%

127 6/28/2002 C A KSNA B-737-300 Substantial 21%

128 6/29/2002 C A KSNA B-737-300 Substantial 21%

129 7/4/2002 NV KEKO EMB-120 Minor 21%

130 7/5/2002 KS KICT B-727-200 Minor 21%

131 7/8/2002 OR KPDX B-737-500 Substantial 21%

132 7/10/2002 FL KSRQ B-737-300 Substantial 21%

Table A.2. Wildlife Strike History
73 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

133 7/18/2002 FL KMIA B-747-400 Minor 21%

134 7/27/2002 RI KPVD MD-88 Substantial 21%

135 7/31/2002 OH KCAK C-172 Minor 21%

136 8/2/2002 OR KPDX C-208 Minor 21%

137 8/5/2002 OR KPDX B-757-200 Substantial 21%

138 8/7/2002 C A KSFO B-757-200 Substantial 21%

139 8/21/2002 MA KBOS B-767-200 Minor 21%

140 8/24/2002 GA KATL BE-300 KING Minor 21%

141 8/24/2002 MA KBOS A-340 Minor 21%

142 8/27/2002 AZ KTUS B-737-300 Substantial 21%

143 9/3/2002 NY KSYR B-737-400 Minor 21%

144 9/7/2002 LA KMSY BE-1900 Minor 21%

145 9/7/2002 C A KSNA B-757-200 Minor 21%

146 9/7/2002 C A KSNA B-757-200 Substantial 21%

147 9/9/2002 GA KATL B-717-200 Minor 21%

148 9/9/2002 OH KCMH C-500 Minor 21%

149 9/13/2002 MI KDTW B-757-200 Minor 21%

150 9/13/2002 TX KHOU EMB-145 Minor 21%

151 9/14/2002 FL KPNS B-737-400 Minor 21%

152 9/19/2002 SD KFSD BE-200 KING Minor 21%

153 9/21/2002 LA KMSY B-737-300 Minor 21%

154 9/30/2002 MI KGRR B-737-300 Minor 21%

155 10/5/2002 SD KBKX BE-1900 Minor 21%

156 10/8/2002 FL KSFB C-172 Minor 21%

157 10/16/2002 NC KRDU B-737 Minor 21%

158 10/19/2002 MA KBOS B-767-200 Substantial 21%

159 10/19/2002 WA KMWH B-747-400 Substantial 21%

160 10/20/2002 FL KMIA A-319 Minor 21%

161 10/21/2002 NY KALB BE-1900 Minor 21%

162 10/27/2002 FL KFLL A-319 Substantial 21%

163 10/28/2002 ME KBGR EMB-135 Minor 21%

164 11/6/2002 MA KBOS B-737-200 Minor 21%

165 11/7/2002 TX KIAH A-319 Substantial 21%

166 11/12/2002 NM KABQ BE-1900 Minor 21%

167 11/12/2002 ND KBIS C-208 Minor 21%

168 11/12/2002 VA KROA EMB-120 Minor 21%

169 11/14/2002 FL KTPA B-767-400 Minor 21%

170 11/18/2002 NC KILM B-737-300 Substantial 21%

171 11/19/2002 TN KBNA B-737-300 Minor 21%

172 11/27/2002 NC KCLT A-320 Substantial 21%

173 12/30/2002 FL KTIX C-310 Minor 21%

174 1/2/2003 GA KATL B-767-300 Minor 21%

175 1/4/2003 FL KMCO A-320 Minor 21%

176 1/11/2003 KS KMHK A-320 Substantial 21%

177 1/15/2003 LA KMSY B-737-500 Substantial 21%

178 1/16/2003 C A KSFO A-320 Substantial 21%

179 1/27/2003 GA KMCN C-172 Minor 21%

180 2/1/2003 FL KMIA B-757-200 Substantial 21%

181 2/2/2003 C A KSFO B-747-400 Minor 21%

182 2/21/2003 TX KAUS B-737-500 Substantial 21%

183 3/14/2003 FL KTPA B-757-200 Minor 21%

184 3/20/2003 GA KATL MD-88 Minor 21%

185 3/24/2003 KS KICT C-208 Minor 21%

186 3/25/2003 TX KIAH B-737-300 Minor 21%

187 4/4/2003 FL KMCO BE-1900 Minor 21%

188 4/10/2003 TX KDAL B-727-200 Minor 21%

189 4/15/2003 C A KSFO B-737-300 Substantial 21%

190 4/19/2003 SD KBKX BE-1900 Minor 21%

191 4/22/2003 FL KMCO B-717-200 Minor 21%

192 4/23/2003 TX KAUS B-737-300 Substantial 21%

193 4/24/2003 C A KSJC A-319 Minor 21%

194 4/30/2003 TX KMAF B-737-300 Minor 21%

195 5/1/2003 AZ KPHX B-737-200 Minor 21%

196 5/12/2003 FL KFLL B-737-200 Substantial 21%

197 5/14/2003 FL KEYW BE-1900 Minor 21%

198 5/21/2003 FL KMIA MD-80 Minor 21%

Table A.2. Wildlife Strike History
74 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

199 6/1/2003 OR KPDX B-737-300 Minor 21%

200 6/13/2003 VA KPHF B-717-200 Minor 21%

201 6/17/2003 FL KMCO B-737-300 Substantial 21%

202 6/21/2003 MA KBOS B-737-200 Minor 21%

203 6/23/2003 MA KBOS B-737-300 Substantial 21%

204 6/27/2003 WA KMWH B-747 Minor 21%

205 7/5/2003 MI KDTW A-319 Minor 21%

206 7/8/2003 MI KDTW A-320 Substantial 21%

207 7/9/2003 GA KAHN C-152 Minor 21%

208 7/14/2003 TX KHOU B-737-300 Substantial 21%

209 7/17/2003 FL KSFB C-500 Substantial 21%

210 7/21/2003 MI KLAN CL-RJ100/200 Minor 21%

211 7/21/2003 GA KSAV B-737-800 Minor 21%

212 7/24/2003 TX KDAL B-737-300 Minor 21%

213 7/28/2003 LA KMSY MD-83 Minor 21%

214 8/5/2003 WI KGRB EMB-145 Minor 21%

215 8/19/2003 FL KPNS MD-88 Minor 21%

216 8/26/2003 GA KATL CL-RJ100/200 Substantial 21%

217 9/4/2003 FL KRSW B-717-200 Minor 21%

218 9/6/2003 WY KJAC B-737 Substantial 21%

219 9/12/2003 ND KBIS CL-RJ100/200 Minor 21%

220 9/26/2003 TX KAMA CL-RJ700 Minor 21%

221 9/29/2003 LA KMSY B-737-500 Minor 21%

222 9/29/2003 OR KPDX MD-80 Minor 21%

223 9/30/2003 FL KMIA B-737-800 Minor 21%

224 9/30/2003 NY KROC B-737-300 Substantial 21%

225 10/5/2003 C A KBUR B-737-400 Minor 21%

226 10/6/2003 WV KMGW BE-1900 Substantial 21%

227 10/11/2003 GA KATL B-717-200 Minor 21%

228 10/17/2003 LA KBTR C-152 Minor 21%

229 10/22/2003 TX KDAL B-737 Substantial 21%

230 10/22/2003 NY KSYR B-757-200 Minor 21%

231 10/25/2003 TX KAUS B-737-500 Minor 21%

232 10/28/2003 ND KBIS CL-RJ100/200 Minor 21%

233 11/1/2003 TN KBNA EMB-145 Substantial 21%

234 11/10/2003 C A KSFO A-319 Minor 21%

235 11/11/2003 MI KFNT B-717-200 Minor 21%

236 11/15/2003 FL KMCO B-717-200 Minor 21%

237 11/23/2003 TX KHOU B-737-300 Minor 21%

238 11/23/2003 AZ KPHX B-737-300 Substantial 21%

239 11/26/2003 TX KAUS B-737-700 Minor 21%

240 11/27/2003 OH KCAK CL-RJ100/200 Minor 21%

241 11/27/2003 FL KFLL B-757-200 Minor 21%

242 11/29/2003 MI KDTW DC-10-10 Substantial 21%

243 12/16/2003 TX KAMA C-172 Minor 21%

244 1/4/2004 TX KDAL BE-200 KING Minor 21%

245 1/5/2004 C A KOXR EMB-120 Minor 21%

246 1/28/2004 FL KJAX BE-1900 Minor 21%

247 1/30/2004 OR KPDX B-737-400 Substantial 21%

248 2/17/2004 OR KPDX B-757-200 Substantial 21%

249 3/1/2004 C A KSFO B-747-400 Substantial 21%

250 3/2/2004 GA KATL B-717-200 Minor 21%

251 3/2/2004 LA KMSY EMB-145 Minor 21%

252 3/8/2004 LA KMSY B-737-300 Substantial 21%

253 3/17/2004 FL KEYW C-208 Minor 21%

254 3/17/2004 RI KPVD A-319 Substantial 21%

255 3/18/2004 FL KMCO B-737-300 Minor 21%

256 3/23/2004 MI KDTW CL-RJ100/200 Minor 21%

257 4/15/2004 OR KPDX A-319 Substantial 21%

258 4/17/2004 TN KBNA MD-88 Minor 21%

259 4/25/2004 C A KBUR B-737-700 Minor 21%

260 4/25/2004 TX KSAT B-737-200 Minor 21%

261 4/28/2004 FL KDAB C-172 Minor 21%

262 5/8/2004 TN KBNA EMB-145 Minor 21%

263 5/12/2004 TX KAMA B-737-300 Substantial 21%

264 5/17/2004 FL KMCO B-737-300 Minor 21%

Table A.2. Wildlife Strike History
75 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

265 5/23/2004 MA KBOS B-737-800 Minor 21%

266 5/25/2004 NM KABQ B-737-300 Minor 21%

267 5/28/2004 OH KDAY CL-RJ100/200 Minor 21%

268 5/29/2004 C A KSFO A-320 Minor 21%

269 5/30/2004 TX KHOU B-737 Minor 21%

270 6/1/2004 AL KBFM A-319 Substantial 21%

271 6/8/2004 C A KOXR EMB-120 Minor 21%

272 6/14/2004 WA KMWH B-747-1/200 Minor 21%

273 6/19/2004 FL KMIA B-757-200 Substantial 21%

274 6/20/2004 ID KBOI CL-RJ100/200 Minor 21%

275 6/25/2004 MA KBOS B-737-400 Minor 21%

276 6/27/2004 NY KBUF A-319 Substantial 21%

277 7/13/2004 NY KSYR B-737-300 Minor 21%

278 7/14/2004 C A KSFO B-737-500 Substantial 21%

279 7/16/2004 C O KALS BE-1900 Minor 21%

280 7/17/2004 NC KRDU CL-RJ100/200 Minor 21%

281 7/22/2004 MA KBOS EMB-135 Minor 21%

282 7/23/2004 LA KMSY A-319 Substantial 21%

283 8/3/2004 LA KMSY B-737-300 Minor 21%

284 8/9/2004 OR KEUG C-152 Minor 21%

285 8/12/2004 MA KBOS A-320 Substantial 21%

286 8/12/2004 MI KFNT B-727-100 Substantial 21%

287 8/21/2004 FL KMIA B-747-400 Minor 21%

288 8/27/2004 OR KPDX C-500 Minor 21%

289 8/29/2004 MI KFNT B-717-200 Minor 21%

290 8/31/2004 GA KAHN BE-1900 Minor 21%

291 9/4/2004 TN KBNA MD-82 Minor 21%

292 9/8/2004 NC KCLT EMB-145 Minor 21%

293 9/9/2004 MI KGRR A-320 Minor 21%

294 9/14/2004 OH KDAY C-172 Minor 21%

295 9/15/2004 MA KBOS B-777-200 Minor 21%

296 9/16/2004 TX KSAT A-300 Substantial 21%

297 9/18/2004 NY KALB B-737-300 Substantial 21%

298 9/27/2004 NY KALB B-737-300 Minor 21%

299 9/28/2004 FL KMCO CL-RJ100/200 Minor 21%

300 9/29/2004 OH KILN B-767-200 Substantial 21%

301 9/30/2004 TX KIAH A-318 Substantial 21%

302 10/19/2004 MI KFNT CL-RJ100/200 Substantial 21%

303 10/21/2004 C A KBUR A-300 Substantial 21%

304 11/1/2004 MA KBOS B-757-200 Substantial 21%

305 11/3/2004 TX KAUS B-737-800 Minor 21%

306 11/8/2004 FL KMCO B-757-300 Minor 21%

307 11/13/2004 MA KACK C-402 Minor 21%

308 11/13/2004 FL KJAX B-737-300 Minor 21%

309 11/15/2004 TX KAMA EMB-135 Minor 21%

310 11/19/2004 C A KSFO B-757-200 Substantial 21%

311 11/20/2004 MA KACK C-402 Minor 21%

312 11/21/2004 C A KSFO MD-80 Minor 21%

313 11/25/2004 GA KATL B-737-200 Minor 21%

314 11/29/2004 MA KBOS B-737-800 Substantial 21%

315 12/6/2004 MI KFNT CL-RJ100/200 Minor 21%

316 12/7/2004 MA KBOS MD-80 Minor 21%

317 12/15/2004 FL KMIA B-757-200 Minor 21%

318 12/17/2004 FL KMIA B-747-400 Substantial 21%

319 12/24/2004 C A KSFO A-320 Minor 21%

320 1/4/2005 LA KMSY MD-88 Minor 21%

321 1/4/2005 FL KTPA B-757-200 Minor 21%

322 1/14/2005 SC KMYR C-208 Minor 21%

323 1/23/2005 FL KTPA MD-83 Minor 21%

324 2/5/2005 FL KMCO A-320 Minor 21%

325 2/22/2005 FL KMCO B-757-200 Minor 21%

326 2/25/2005 WV KCRW BE-1900 Minor 21%

327 2/27/2005 FL KMCO B-737-300 Substantial 21%

328 3/1/2005 TX KAUS B-737-700 Substantial 21%

329 3/4/2005 C A KSJC B-757-200 Substantial 21%

330 3/14/2005 NC KCLT B-737-300 Minor 21%

Table A.2. Wildlife Strike History
76 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

331 3/24/2005 FL KRSW B-757-200 Minor 21%

332 3/25/2005 GA KATL MD-88 Minor 21%

333 4/6/2005 MA KBOS CL-600 Minor 21%

334 4/9/2005 FL KRSW A-320 Substantial 21%

335 4/9/2005 FL KRSW B-737-800 Minor 21%

336 4/29/2005 MI KDTW B-757-200 Substantial 21%

337 5/1/2005 FL KRSW B-757-200 Substantial 21%

338 5/3/2005 OR KPDX A-300 Minor 21%

339 5/8/2005 TX KHRL B-737-500 Substantial 21%

340 5/13/2005 FL KMCO A-320 Substantial 21%

341 5/17/2005 C A KSFO A-340 Substantial 21%

342 5/17/2005 FL KTPA B-757-200 Minor 21%

343 5/26/2005 AZ KPRC C-172 Minor 21%

344 6/2/2005 FL KTPA B-737-300 Substantial 21%

345 6/7/2005 NY KALB EMB-145 Minor 21%

346 6/13/2005 TX KIAH B-737-500 Minor 21%

347 6/15/2005 FL KMIA B-737-800 Minor 21%

348 6/17/2005 FL KFLL ATR-72 Minor 21%

349 6/24/2005 C A KBUR B-737-300 Minor 21%

350 6/24/2005 FL KMCO B-757-200 Substantial 21%

351 6/27/2005 AZ KPHX B-737-300 Substantial 21%

352 6/28/2005 WA KMWH B-747-400 Minor 21%

353 7/10/2005 WY KJAC A-319 Minor 21%

354 7/12/2005 TX KHOU B-737-500 Substantial 21%

355 7/20/2005 FL KMCO B-717-200 Minor 21%

356 7/23/2005 FL KMCO B-737-300 Substantial 21%

357 7/27/2005 MT KMSO C-177 Minor 21%

358 7/29/2005 TX KAUS B-737-300 Minor 21%

359 8/1/2005 WA KMWH B-777-200 Minor 21%

360 8/9/2005 OR KPDX B-737-700 Minor 21%

361 8/15/2005 KY KLEX EMB-135 Minor 21%

362 8/19/2005 NC KCLT CL-RJ700 Minor 21%

363 9/11/2005 NV KLAS A-319 Minor 21%

364 9/13/2005 FL KPNS CL-RJ100/200 Substantial 21%

365 9/14/2005 MI KFNT C-172 Minor 21%

366 9/14/2005 C T KGON EMB-135 Minor 21%

367 9/15/2005 TX KAFW DC-10-10 Substantial 21%

368 9/17/2005 NC KILM B-737-300 Minor 21%

369 9/17/2005 FL KMIA B-737-800 Minor 21%

370 9/18/2005 MI KDTW A-319 Minor 21%

371 9/19/2005 TX KIAH EMB-145 Substantial 21%

372 9/23/2005 LA KMSY A-320 Minor 21%

373 9/26/2005 FL KMIA A-300 Minor 21%

374 9/28/2005 C A KSAN B-737 Minor 21%

375 10/6/2005 MT KHLN A-319 Minor 21%

376 10/7/2005 GA KATL MD-88 Minor 21%

377 10/7/2005 FL KJAX C-172 Minor 21%

378 10/8/2005 C T KBDL B-737-700 Minor 21%

379 10/9/2005 C T KBDL B-737-200 Minor 21%

380 10/13/2005 TX KAFW DC-10-10 Substantial 21%

381 10/13/2005 NC KCLT EMB-145 Minor 21%

382 10/23/2005 MA KBOS B-757-200 Minor 21%

383 10/23/2005 MS KJAN C-172 Minor 21%

384 10/26/2005 TX KMAF EMB-145 Minor 21%

385 11/3/2005 OR KPDX A-300 Substantial 21%

386 11/9/2005 TN KBNA B-737 Substantial 21%

387 11/11/2005 SC KCAE EMB-145 Minor 21%

388 11/17/2005 FL KMCO EMB-135 Minor 21%

389 11/22/2005 FL KJAX A-320 Substantial 21%

390 11/23/2005 NC KCLT B-737-400 Minor 21%

391 12/9/2005 FL KRSW B-757-200 Minor 21%

392 12/19/2005 FL KMCO B-737-300 Minor 21%

393 12/19/2005 FL KMCO B-737-300 Substantial 21%

394 12/22/2005 C A KSFO MD-80 Minor 21%

395 12/24/2005 FL KFLL MD-80 Substantial 21%

396 12/26/2005 FL KMCO B-757-200 Substantial 21%

Table A.2. Wildlife Strike History
77 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

397 12/28/2005 OR KPDX DC-10-10 Substantial 21%

398 1/7/2006 OR KPDX B-757-200 Substantial 21%

399 1/27/2006 MA KACK C-402 Minor 21%

400 2/3/2006 C T KGON BE-1900 Substantial 21%

401 3/2/2006 TX KSAT MD-80 Minor 21%

402 3/7/2006 OR KPDX B-757-200 Minor 21%

403 3/12/2006 FL KJAX B-717-200 Minor 21%

404 3/17/2006 FL KSRQ B-737-400 Substantial 21%

405 3/21/2006 AZ KPRC C-172 Minor 21%

406 3/22/2006 FL KMCO EMB-145 Substantial 21%

407 3/22/2006 C A KSJC EMB-135 Minor 21%

408 3/28/2006 MA KBOS B-757-200 Minor 21%

409 3/29/2006 C T KBDL B-757-200 Minor 21%

410 3/31/2006 FL KJAX CL-RJ700 Minor 21%

411 4/5/2006 FL KMCO B-737-300 Minor 21%

412 4/12/2006 TX KHOU BE-200 KING Minor 21%

413 4/15/2006 MI KDTW CL-RJ100/200 Substantial 21%

414 4/24/2006 NH KMHT B-737-300 Minor 21%

415 4/25/2006 VA KPHF B-717-200 Minor 21%

416 5/6/2006 OR KPDX A-319 Substantial 21%

417 5/19/2006 FL KMCO B-757-200 Minor 21%

418 5/23/2006 FL KRSW B-757-200 Minor 21%

419 5/27/2006 NY KELM CL-RJ100/200 Substantial 21%

420 6/26/2006 FL KFLL MD-88 Substantial 21%

421 6/29/2006 FL KTLH EMB-145 Minor 21%

422 6/30/2006 NY KISP B-737-700 Substantial 21%

423 7/9/2006 NY KALB B-737-700 Substantial 21%

424 7/22/2006 GA KATL MD-88 Minor 21%

425 7/22/2006 FL KMCO B-737-300 Minor 21%

426 7/23/2006 WA KGEG B-737-800 Minor 21%

427 7/25/2006 WA KGEG B-737-400 Minor 21%

428 7/26/2006 FL KMCO B-737 Minor 21%

429 7/27/2006 FL KMCO ATR-72 Minor 21%

430 7/31/2006 MI KDTW A-319 Minor 21%

431 7/31/2006 C A KSFO CL-RJ100/200 Minor 21%

432 8/12/2006 OH KCAK EMB-145 Minor 21%

433 8/12/2006 GA KSAV B-717-200 Minor 21%

434 8/15/2006 FL KPNS CL-RJ700 Minor 21%

435 8/29/2006 IL KPIA CL-RJ100/200 Minor 21%

436 9/3/2006 LA KMSY B-737-500 Minor 21%

437 9/6/2006 GA KATL B-757-200 Substantial 21%

438 9/6/2006 IL KPIA B-727 Minor 21%

439 9/13/2006 NY KROC A-320 Minor 21%

440 9/16/2006 TX KDAL B-737-400 Minor 21%

441 9/17/2006 C A KSFO B-757-200 Minor 21%

442 9/20/2006 TX KHOU EMB-145 Minor 21%

443 9/22/2006 LA KMSY EMB-145 Minor 21%

444 9/26/2006 FL KMCO B-737-700 Minor 21%

445 9/30/2006 SC KMYR CL-RJ100/200 Minor 21%

446 10/1/2006 FL KRSW A-320 Minor 21%

447 10/4/2006 KS KICT CL-RJ100/200 Minor 21%

448 10/4/2006 C A KSJC A-320 Minor 21%

449 10/5/2006 NY KALB EMB-145 Minor 21%

450 10/6/2006 TN KBNA B-737-700 Minor 21%

451 10/6/2006 IL KPIA B-727-100 Minor 21%

452 10/14/2006 FL KFLL DC-10-10 Minor 21%

453 10/20/2006 C T KBDL MD-88 Minor 21%

454 10/21/2006 FL KMIA B-747-400 Substantial 21%

455 10/29/2006 C A KSJC EMB-135 Minor 21%

456 11/1/2006 C A KSFO B-767-300 Substantial 21%

457 11/2/2006 SC KCAE B-757-200 Substantial 21%

458 11/2/2006 FL KEYW BE-1900 Minor 21%

459 11/3/2006 MT KMSO A-320 Minor 21%

460 11/9/2006 VA KPHF EMB-145 Minor 21%

461 11/11/2006 MI KDTW A-319 Minor 21%

462 11/11/2006 FL KMCO B-737-300 Minor 21%

Table A.2. Wildlife Strike History
78 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

463 11/15/2006 SD KFSD B-727-200 Minor 21%

464 11/20/2006 NH KMHT CL-RJ100/200 Minor 21%

465 11/24/2006 FL KMCO B-767-400 Minor 21%

466 11/27/2006 FL KMCO B-737-700 Substantial 21%

467 11/30/2006 NC KRDU B-737-800 Minor 21%

468 12/4/2006 FL KDAB C-172 Minor 21%

469 12/5/2006 GA KATL MD-80 Substantial 21%

470 12/12/2006 C A KOXR EMB-120 Minor 21%

471 12/18/2006 VA KPHF B-717-200 Minor 21%

472 12/25/2006 FL KJAX CL-RJ100/200 Minor 21%

473 12/25/2006 FL KMCO A-320 Minor 21%

474 12/25/2006 IL KMLI EMB-145 Substantial 21%

475 12/25/2006 VA KPHF CL-RJ100/200 Minor 21%

476 12/26/2006 C A KLGB A-320 Substantial 21%

477 1/7/2007 LA KMSY B-737-400 Substantial 21%

478 1/11/2007 GA KSAV B-717-200 Minor 21%

479 1/12/2007 FL KMCO A-320 Minor 21%

480 1/14/2007 FL KMCO B-717-200 Minor 21%

481 1/14/2007 FL KMCO B-737-300 Minor 21%

482 1/26/2007 ID KBOI B-737-700 Minor 21%

483 1/27/2007 FL KSFB C-172 Destroyed 21%

484 1/28/2007 C A KSJC B-737-300 Substantial 21%

485 1/29/2007 FL KMCO B-737-700 Minor 21%

486 2/4/2007 TX KIAH EMB-145 Minor 21%

487 2/5/2007 AZ KPRC C-172 Minor 21%

488 2/13/2007 AL KBFM B-727-200 Minor 21%

489 2/20/2007 FL KMCO B-717-200 Minor 21%

490 2/28/2007 MA KBOS A-319 Minor 21%

491 2/28/2007 VA KPHF B-717-200 Minor 21%

492 3/3/2007 FL KRSW CL-RJ700 Minor 21%

493 3/9/2007 OH KILN B-767-200 Minor 21%

494 3/11/2007 FL KMIA B-777-200 Substantial 21%

495 3/22/2007 FL KMCO B-737-300 Minor 21%

496 3/23/2007 MI KGRR CL-RJ100/200 Minor 21%

497 3/26/2007 NY KBUF B-717-200 Minor 21%

498 3/27/2007 GA KATL B-757-200 Minor 21%

499 3/28/2007 MA KBOS A-319 Minor 21%

500 3/31/2007 OR KPDX B-737-400 Minor 21%

501 3/31/2007 FL KRSW B-717-200 Minor 21%

502 4/3/2007 FL KDAB BE-200 KING Minor 21%

503 4/3/2007 NY KSWF A-320 Minor 21%

504 4/7/2007 WA KMWH B-747-400 Substantial 21%

505 4/27/2007 NM KABQ MD-82 Minor 21%

506 4/27/2007 FL KTPA B-737-700 Minor 21%

507 5/8/2007 TX KAFW BE-300 KING Substantial 21%

508 5/20/2007 MA KBOS A-319 Minor 21%

509 5/21/2007 RI KPVD A-320 Minor 21%

510 5/29/2007 FL KMIA B-757-200 Minor 21%

511 6/16/2007 FL KMCO B-737-700 Minor 21%

512 6/17/2007 FL KMCO B-717-200 Minor 21%

513 6/23/2007 NC KILM B-737-300 Minor 21%

514 6/24/2007 LA KSHV EMB-135 Minor 21%

515 7/1/2007 FL KRSW B-737-500 Minor 21%

516 7/2/2007 GA KCSG C-172 Minor 21%

517 7/4/2007 FL KRSW MD-88 Substantial 21%

518 7/10/2007 C A KSFO EMB-120 Minor 21%

519 7/19/2007 TX KELP DC-10-10 Substantial 21%

520 7/26/2007 FL KMCO A-320 Minor 21%

521 7/28/2007 MI KDTW A-321 Minor 21%

522 7/30/2007 MN KDLH A-319 Minor 21%

523 8/1/2007 TX KELP B-737-300 Minor 21%

524 8/9/2007 NY KROC A-300 Substantial 21%

525 8/10/2007 MA KHYA C-402 Minor 21%

526 8/17/2007 OH KCMH CL-RJ700 Substantial 21%

527 8/23/2007 FL KMCO C-310 Minor 21%

528 8/24/2007 MI KGRR A-320 Minor 21%

Table A.2. Wildlife Strike History
79 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

529 8/26/2007 FL KPNS EMB-135 Minor 21%

530 8/28/2007 LA KMSY B-737-700 Minor 21%

531 9/1/2007 C A KSJC B-737-300 Minor 21%

532 9/3/2007 C A KSFO A-320 Substantial 21%

533 9/9/2007 C A KSFO A-319 Minor 21%

534 9/12/2007 MT KHLN C-172 Substantial 21%

535 9/13/2007 TX KAUS B-737-700 Minor 21%

536 9/14/2007 OR KPDX B-737 Minor 21%

537 9/15/2007 MI KDTW A-321 Minor 21%

538 9/15/2007 NY KROC B-737-700 Minor 21%

539 9/16/2007 ME KBGR EMB-135 Minor 21%

540 9/17/2007 OH KCMH A-319 Minor 21%

541 9/22/2007 MS KJAN MD-88 Minor 21%

542 9/26/2007 OR KEUG CL-RJ100/200 Minor 21%

543 9/26/2007 IL KMLI BE-200 KING Substantial 21%

544 9/27/2007 TX KAUS B-737-500 Minor 21%

545 9/27/2007 NY KIAG B-727-200 Minor 21%

546 9/28/2007 NY KBUF EMB-145 Minor 21%

547 9/29/2007 SC KMYR A-319 Substantial 21%

548 9/29/2007 TX KSAT B-737-500 Minor 21%

549 10/4/2007 OR KPDX B-757-200 Minor 21%

550 10/4/2007 C A KSJC B-737-300 Minor 21%

551 10/5/2007 KS KICT EMB-135 Minor 21%

552 10/6/2007 TX KIAH EMB-145 Minor 21%

553 10/7/2007 MA KBOS B-747-400 Minor 21%

554 10/9/2007 GA KATL B-737-700 Minor 21%

555 10/11/2007 GA KMCN C-500 Substantial 21%

556 10/13/2007 GA KATL B-737-700 Substantial 21%

557 10/14/2007 FL KFLL B-737-800 Minor 21%

558 10/14/2007 KY KLEX C-172 Minor 21%

559 10/14/2007 FL KRSW B-737-300 Minor 21%

560 10/23/2007 FL KRSW ATR-72 Substantial 21%

561 10/29/2007 FL KDAB MD-88 Substantial 21%

562 10/29/2007 FL KMCO B-737-300 Minor 21%

563 11/4/2007 C A KSAN B-737-700 Minor 21%

564 11/7/2007 GA KSAV EMB-145 Minor 21%

565 11/7/2007 NY KSWF A-320 Substantial 21%

566 11/11/2007 MI KDTW B-737-300 Minor 21%

567 11/12/2007 NH KMHT EMB-145 Minor 21%

568 11/19/2007 PA KABE CL-600 Minor 21%

569 12/3/2007 MI KGRR C-208 Minor 21%

570 12/4/2007 OR KPDX B-737 Minor 21%

571 12/6/2007 FL KMCO MD-88 Minor 21%

572 12/18/2007 TX KAMA EMB-145 Minor 21%

573 12/23/2007 C A KSBA CL-RJ100/200 Minor 21%

574 12/30/2007 ID KBOI B-737-300 Minor 21%

575 1/6/2008 GA KATL B-737-700 Minor 21%

576 1/11/2008 AR KLIT B-737-500 Minor 21%

577 2/6/2008 TX KAUS B-737-300 Minor 21%

578 2/7/2008 MI KDTW A-318 Minor 21%

579 2/18/2008 TX KAUS MD-88 Substantial 21%

580 2/20/2008 FL KMCO B-737-700 Minor 21%

581 2/20/2008 FL KTPA B-757-200 Minor 21%

582 2/23/2008 FL KJAX CL-RJ100/200 Minor 21%

583 2/26/2008 WA KMWH B-777-200 Minor 21%

584 3/3/2008 NY KSYR B-757-200 Minor 21%

585 3/10/2008 TX KDAL B-737-300 Substantial 21%

586 3/13/2008 OR KPDX EMB-120 Minor 21%

587 3/15/2008 TX KDAL B-737-700 Minor 21%

588 3/20/2008 FL KMCO B-757-200 Substantial 21%

589 3/21/2008 TX KAFW A-300 Minor 21%

590 3/21/2008 TX KAFW A-300 Minor 21%

591 3/30/2008 C T KBDL B-737-700 Minor 21%

592 4/9/2008 GA KSAV C-172 Minor 21%

593 4/24/2008 TX KAFW DC-10-10 Minor 21%

594 4/26/2008 FL KMCO A-320 Minor 21%

Table A.2. Wildlife Strike History
80 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

595 5/12/2008 FL KSRQ B-757-200 Substantial 21%

596 5/15/2008 GA KATL B-757-200 Minor 21%

597 5/30/2008 TX KHRL B-737-300 Minor 21%

598 6/11/2008 TX KSAT B-757-200 Minor 21%

599 6/16/2008 LA KMSY A-320 Minor 21%

600 6/17/2008 FL KMIA B-737-800 Minor 21%

601 7/8/2008 NY KISP B-737-700 Minor 21%

602 7/12/2008 NY KISP B-737-700 Minor 21%

603 7/14/2008 VA KROA CL-RJ100/200 Minor 21%

604 7/15/2008 TX KHOU B-737-300 Minor 21%

605 7/16/2008 FL KMIA B-757-200 Minor 21%

606 7/22/2008 C A KSFO A-319 Minor 21%

607 7/24/2008 FL KMIA EMB-135 Minor 21%

608 7/27/2008 GA KSAV CL-RJ700 Minor 21%

609 7/29/2008 NY KSWF EMB-190 Minor 21%

610 8/5/2008 GA KATL MD-88 Substantial 21%

611 8/6/2008 FL KSRQ CL-RJ100/200 Minor 21%

612 8/7/2008 MN KDLH A-319 Minor 21%

613 8/8/2008 FL KTPA B-737-300 Substantial 21%

614 8/9/2008 C T KBDL B-737-700 Minor 21%

615 8/10/2008 FL KRSW B-737-300 Minor 21%

616 8/11/2008 IL KMLI CL-RJ100/200 Minor 21%

617 8/24/2008 C A KSFO B-747-400 Minor 21%

618 9/2/2008 FL KMIA B-767-300 Minor 21%

619 9/11/2008 GA KATL MD-88 Substantial 21%

620 9/15/2008 NY KALB EMB-190 Minor 21%

621 9/19/2008 FL KMCO A-320 Minor 21%

622 9/21/2008 FL KMCO B-767-300 Substantial 21%

623 9/28/2008 OH KCMH B-737-700 Minor 21%

624 9/30/2008 FL KMCO B-737-800 Minor 21%

625 10/6/2008 FL KFLL A-319 Substantial 21%

626 10/6/2008 LA KSHV CL-RJ700 Substantial 21%

627 10/7/2008 OR KPDX B-737-700 Substantial 21%

628 10/10/2008 OR KPDX CL-RJ100/200 Minor 21%

629 10/12/2008 FL KMCO B-737-700 Minor 21%

630 10/17/2008 NY KSYR EMB-170 Minor 21%

631 10/17/2008 FL KTPA BE-1900 Minor 21%

632 10/23/2008 C T KBDL B-737-500 Minor 21%

633 10/27/2008 FL KMIA A-300 Minor 21%

634 11/4/2008 FL KMCO B-737-300 Minor 21%

635 11/10/2008 GA KATL CL-RJ100/200 Minor 21%

636 11/14/2008 AR KLIT A-319 Minor 21%

637 11/16/2008 TX KELP B-737-500 Minor 21%

638 11/17/2008 FL KMIA B-737-800 Minor 21%

639 11/21/2008 NY KIAG BE-200 KING Minor 21%

640 11/25/2008 MA KBOS A-320 Substantial 21%

641 11/30/2008 FL KMCO B-737-300 Minor 21%

642 11/30/2008 FL KMCO B-767-300 Substantial 21%

643 12/2/2008 FL KMCO A-320 Minor 21%

644 12/6/2008 LA KMSY A-320 Substantial 21%

645 12/9/2008 C T KBDL B-737-800 Minor 21%

646 12/19/2008 MA KBOS B-737-700 Minor 21%

647 12/22/2008 C A KSNA B-737-700 Minor 21%

648 12/25/2008 FL KMCO A-320 Minor 21%

649 12/30/2008 FL KEYW CL-RJ700 Minor 21%

650 1/4/2009 C A KLGB EMB-190 Minor 21%

651 1/24/2009 FL KMCO A-320 Substantial 21%

652 1/29/2009 FL KMCO A-300 Minor 21%

653 2/4/2009 KS KMHK BE-1900 Minor 21%

654 2/16/2009 FL KFLL C-402 Minor 21%

655 2/16/2009 C A KSJC B-757-200 Substantial 21%

656 2/17/2009 SC KMYR EMB-190 Minor 21%

657 2/20/2009 FL KRSW MD-82 Minor 21%

658 2/24/2009 TX KSAT B-757-200 Minor 21%

659 2/25/2009 C A KSFO CL-RJ700 Minor 21%

660 2/28/2009 FL KMCO A-321 Minor 21%

Table A.2. Wildlife Strike History
81 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

661 3/16/2009 LA KMSY B-757-200 Substantial 21%

662 3/16/2009 WA KMWH B-777-300 Minor 21%

663 3/17/2009 FL KMCO B-737-700 Minor 21%

664 3/19/2009 FL KRSW B-737-700 Minor 21%

665 3/22/2009 MI KGRR A-310 Substantial 21%

666 3/23/2009 FL KSRQ MD-88 Minor 21%

667 4/6/2009 FL KSFB MD-83 Minor 21%

668 4/9/2009 TX KAUS EMB-190 Minor 21%

669 4/17/2009 TN KBNA EMB-145 Minor 21%

670 4/17/2009 FL KMIA B-767-300 Minor 21%

671 4/24/2009 FL KMCO B-737-300 Minor 21%

672 4/25/2009 FL KRSW B-717-200 Minor 21%

673 4/29/2009 AZ KTUS B-737-700 Minor 21%

674 5/2/2009 MA KACK C-402 Minor 21%

675 5/11/2009 OH KCMH MD-82 Minor 21%

676 5/12/2009 NV KLAS B-737-800 Minor 21%

677 5/23/2009 FL KMCO B-737-700 Minor 21%

678 5/26/2009 GA KATL B-737-700 Minor 21%

679 5/26/2009 MS KJAN CL-RJ100/200 Minor 21%

680 5/26/2009 NY KSYR A-320 Minor 21%

681 5/27/2009 NY KSYR A-320 Minor 21%

682 6/4/2009 TN KBNA B-737-300 Substantial 21%

683 6/8/2009 FL KRSW MD-83 Minor 21%

684 6/16/2009 C A KSNA EMB-135 Minor 21%

685 6/21/2009 FL KMCO EMB-190 Minor 21%

686 6/27/2009 LA KBTR CL-RJ100/200 Minor 21%

687 6/29/2009 VA KPHF B-717-200 Minor 21%

688 7/5/2009 GA KATL B-757-200 Minor 21%

689 7/10/2009 OH KCMH EMB-170 Substantial 21%

690 7/11/2009 TN KBNA B-737-300 Minor 21%

691 7/14/2009 IL KMLI CL-RJ100/200 Minor 21%

692 7/17/2009 NC KCLT B-737-400 Minor 21%

693 7/19/2009 FL KTLH C-172 Minor 21%

694 7/21/2009 FL KSRQ MD-88 Minor 21%

695 7/22/2009 FL KMCO EMB-190 Minor 21%

696 7/22/2009 FL KMCO B-747-400 Minor 21%

697 8/1/2009 NY KSYR A-319 Minor 21%

698 8/2/2009 WA KGEG B-737-700 Minor 21%

699 8/5/2009 C A KSBA CL-RJ100/200 Minor 21%

700 8/12/2009 NC KCLT CL-RJ100/200 Minor 21%

701 8/12/2009 FL KFLL B-737-700 Minor 21%

702 8/13/2009 TX KIAH EMB-170 Minor 21%

703 8/17/2009 NC KCLT EMB-170 Substantial 21%

704 8/21/2009 KY KLEX CL-RJ100/200 Minor 21%

705 8/24/2009 NM KABQ A-319 Minor 21%

706 8/27/2009 TX KIAH B-737-900 Minor 21%

707 9/1/2009 NH KMHT EMB-170 Minor 21%

708 9/2/2009 MA KBOS MD-88 Minor 21%

709 9/4/2009 TX KSAT B-737-700 Substantial 21%

710 9/8/2009 GA KMCN C-208 Minor 21%

711 9/9/2009 NH KMHT B-737-300 Minor 21%

712 9/15/2009 TN KBNA EMB-170 Substantial 21%

713 9/16/2009 AZ KPHX B-737-700 Minor 21%

714 9/20/2009 OH KDAY CL-RJ100/200 Substantial 21%

715 9/20/2009 KY KLEX CL-RJ100/200 Minor 21%

716 9/25/2009 C A KSFO A-320 Minor 21%

717 9/27/2009 FL KMIA ATR-72 Minor 21%

718 9/28/2009 FL KMIA MD-88 Substantial 21%

719 9/30/2009 MI KLAN CL-RJ100/200 Minor 21%

720 10/6/2009 MI KDTW B-757-200 Substantial 21%

721 10/8/2009 OR KEUG MD-83 Minor 21%

722 10/11/2009 NY KROC MD-88 Substantial 21%

723 10/13/2009 FL KFLL A-320 Minor 21%

724 10/16/2009 FL KSFB C-172 Minor 21%

725 10/19/2009 MA KBOS A-319 Minor 21%

726 10/21/2009 IL KPIA A-300 Minor 21%

Table A.2. Wildlife Strike History
82 Count Date State Airport ID Aircraft AC Damage

Accident 

Prevention 

Probability

727 10/21/2009 FL KTPA A-320 Minor 21%

728 10/22/2009 FL KDAB C-172 Minor 21%

729 10/23/2009 MI KFNT B-737-700 Minor 21%

730 10/27/2009 FL KMCO B-737-700 Minor 21%

731 10/28/2009 PA KABE A-319 Minor 21%

732 10/28/2009 WI KGRB CL-RJ100/200 Minor 21%

733 10/29/2009 FL KMIA B-767-300 Minor 21%

734 11/2/2009 WI KMSN CL-600 Minor 21%

735 11/28/2009 MA KBOS MD-88 Minor 21%

736 11/29/2009 GA KATL MD-88 Minor 21%

737 12/3/2009 SD KFSD C-402 Minor 21%

738 12/9/2009 C A KLGB A-320 Minor 21%

739 12/13/2009 OR KEUG CL-RJ100/200 Substantial 21%

740 12/19/2009 TX KHRL B-737-500 Minor 21%

741 1/1/2010 FL KMCO A-320 Substantial 21%

742 1/31/2010 NC KRDU EMB-170 Minor 21%

743 2/11/2010 C A KSBA ATR-42 Minor 21%

744 2/13/2010 FL KSFB C-172 Minor 21%

745 2/15/2010 FL KFLL A-321 Minor 21%

746 2/15/2010 FL KTPA B-757-200 Minor 21%

747 2/16/2010 NC KCLT A-321 Minor 21%

748 2/28/2010 FL KMCO B-757-200 Substantial 21%

749 2/28/2010 FL KMCO A-320 Minor 21%

Table A.2. Wildlife Strike History
83
84
85
86
87
88
89
90

ASRS data is only recorded by month and year. 
91

Count Event ID Date Airport ID Injuries Accident Prevention 

Probability

1 VGLTLUK02002 06/30/02 LUK No 40%

2 VNMTPDX03001 01/28/03 PDX Yes 20%

3 VEATEWR04004 06/17/04 EWR No 40%

4 RDGT08E001 08/03/08 RDG No 20%

Table A.6. RI Accident History
92

Appendix 2: Aircraft Values

Economic Values Category Market Value 

US $ Millions

Two-Engine Narrow Body 24.20

Two-Engine Wide Body 73.84

Three Engine Narrow Body 2.25

Three Engine Wide Body 3.28

Four Engine Wide Body 66.16

Regional Jet 70 to 100 Seats 18.46

Regional Jet Under 70 Seats 10.05

Rotorcraft turbine <6,000 lbs. 6.37

Turbojet/Turbofan airplanes >12,500 lbs. And <65,000 lbs. 22.72

Turbojet/Turbofan airplanes >65,000 lbs. 5.65

Turbojet/Turbofan two-engine airplanes <12,000 lbs. 0.63

Turboprop airplanes 1 to 9 seats one-engine 2.23

Turboprop airplanes 10 to 19 seats 1.44

Turboprop with 20 Seats or more 6.13

Piston engine airplanes 1 to 3 seats (<200hp) 0.05

Piston engine airplanes 1 to 3 seats (>200hp) 0.45

Piston engine airplanes 4 to 9 seats one-engine (<200hp) 0.32

Piston engine airplanes 4 to 9 seats one-engine (>200hp) 0.36

Piston engine airplanes 4 to 9 seats two-engine 0.39

Table 1-1: Estimated Market Values of Air Carrier Aircraft ($2014)

Table 1-1 above was developed by APO to update the 2003 values from Table 5-1 of 

Economic Values for Evaluation of FAA Investment and Regulatory Decisions. The U.S. fleet 

and aircraft values we used were current as of winter 2011 and were updated to 2014 using the 

GDP deflator.

Replacement values for air carriers were derived from proprietary databases developed 

by the Airliner Price Guide1and Aircraft Bluebook Price Digest2. Both provided the market 

values for each airplane model by year of manufacture. 

 

1 Airliner Price Guide, 568 Waterloo Road, Suite 102, Warrenton, VA 20186.

2 Aircraft Bluebook Price Digest, 9800 Metcalf Avenue, Overland Park, KS 66212.
93

The updated summary of values for passenger and all cargo air carrier aircraft are shown 

in Table 1-1. The first column shows the airplane group. The second column shows the 2011

market value values. 
94

Appendix 3: Airport Groupings

Since the FAA chose to analyze various alternatives based on classifications not defined 

in current part 139 (e.g., hubs or international status instead of AOC class), it relied on the best 

currently available information to develop the list of affected airports under each combination. 

To identify those airports classified as Large, Medium, or Small hubs, the FAA relied on the 

2011-2015 NPIAS, current at the time of this analysis. The FAA’s use of the term hub airport is 

different from that of airlines, which use it denote an airport with significant connecting traffic 

by one or more carriers. The FAA defines large hubs as those airports that each account for 1 

percent or more of total U.S. passenger enplanements. Medium hubs are defined in statute as 

airports that each account for between 0.25 percent and 1 percent of total U.S. passenger 

enplanements. Small hubs are defined as airports that enplane 0.05 percent to 0.25 percent of 

total U.S. passenger enplanements.

Similarly, the FAA relied on annual operations data reported by airport through FAA 

Form 5010-1, Airport Master Record to obtain those airports with over 100,000 operations. The 

FAA relied on data obtained from the CBP and Title 19 CFR §§ 101.3, 122.13, 122.14, and 

122.15, to identify certificated airports authorized to accept international traffic.
95 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

1

Grand Canyon 

West 1G4 X

2 Lehigh Valley Int'l ABE X X X X

3 Abilene Reg ABI X

4

Albuquerque Int'l 

Sunport

ABQ X X X X

5 Aberdeen Reg ABR X

6 SW Georgia Reg ABY X

7 Nantucket Mem ACK X X

8 Waco Reg ACT X

9

Arcata ACV X X

10 Atlantic City Int'l ACY X X X X

11 Adak ADK X

12 Kodiak ADQ X

13 Alexandria Int'l AEX X

14 Fort Worth Alliance AFW X X

15 Bush Fld AGS X

16 Athens/Ben Epps AHN

17 Alliance Muni AIA

18 King Salmon AKN X

19 Albany Co ALB X X X X

20 St. Louis Reg ALN

21 Waterloo Regional ALO X

22

San Luis Valley 

Reg/Bergm ALS

23 Walla Walla Reg ALW X

24 Amarillo Int'l AMA X X X

25 Anniston Metro ANB

Table A.7. Airport Groupings
96 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

26 Anchorage Int'l ANC X X X X

27 Anderson Co AND

28 Altoona-Blair Co AOO X

29 Naples Muni APF X X

30 Alpena Co Reg APN X X

31 Acadiana Reg ARA

32 Watertown Int'l ART X X

33

Aspen-Pitkin Co 

Sardy

ASE X

34 Hartsfield Atlanta Int'lATL X X X X

35 Outagamie Co ATW X

36 Watertown Muni ATY X

37 Austin Bergstrom Intl AUS X X X X

38 Ashville Int'l AVL X

39

WilkesBarre/Scranton 

Int'l

AVP X X

40

Kalamazoo/Btl 

Crk Int'l

AZO X X

41 Barnes Muni BAF X

42 Columbus Muni BAK

43 Branson BBG X

44 Bradley Int'l BDL X X X X

45 Sikorsky Mem BDR X

46 Laurence Hanscom FldBED X X X

47 Bethel BET X X

48 Bradford Reg BFD X

49 Western Nebraska RegBFF

50 Boeing Fld BFI X X

51 Meadows Fld BFL X X X

Table A.7. Airport Groupings
97 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

52 Mobile Downtown BFM X

53

Greater 

Binghamton/E A 

Link Fld

BGM X X

54 Bangor Int'l BGR X X

55

Hancock Co-Bar 

Harbor

BHB X

56 Birmingham Int'l BHM X X X X

57 Billings Logan Int'l BIL X X

58 Bismark Muni BIS X X

59

Rocky Mountain 

Metropolitan 

Airport

BJC X X

60

Bemidji-Beltrami 

Co

BJI X

61 Burke Lakefront BKL X

62 Raleigh Co Mem BKW X

63 Brookings Muni BKX

64 Bellingham Int'l BLI X X

65

Scott 

AFB/Midamerica BLV X X

66 Monroe Co BMG

67

Central Illinois Reg BMI X

68 Nashville Int'l BNA X X X X

69 Boise Air Term BOI X X X X

70 Logan Int'l BOS X X X X

71

Jefferson Co BPT X X

72 Brunswick Golden IslesBQK X X

73 Rafael Hernandez BQN X X

74

Brainerd-Crow 

Wing Reg

BRD X

75

Brownsville/South 

Padre Island

BRO X X

76

Wiley Post-Will 

Rogers Mem

BRW X

77 W K Kellogg BTL X

Table A.7. Airport Groupings
98 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

78 Bert Mooney BTM X X

79

Baton Rouge 

Metro-Ryan

BTR X X X

80 Burlington Int'l BTV X X X

81 Buffalo Niagara Int'l BUF X X X X

82 Bob Hope BUR X X X

83

Bowling Green/

Warren Co Reg 

BWG

84

BaltimoreWashington Int'l

BWI X X X X

85 Gallatin Fld BZN X X

86 Columbia Metro CAE X X X

87 Akron-Canton Reg CAK X X X

88 Buchanan Fld CCR

89 Cold Bay CDB X X

90 Cedar City Muni CDC

91 Chadron Muni CDR

92

Merle K 

(Mudhole) Smith CDV X

93 Jack McNamara Fld CEC

94

Westover 

AFB/Metro CEF X X

95 Cortez Muni CEZ

96 Cape Girardeau Reg CGI

97 Lovell Fld CHA X X

98

CharlottesvilleAlbemarle

CHO X

99 Charleston International CHS X X X X

100 Chico Muni CIC

101 The Eastern Iowa Airport CID X X

102 Chippewa Co Int'l CIU X X

103

Harrison/Marion 

Reg

CKB X

Table A.7. Airport Groupings
99 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

104

ClevelandHopkins Int'l

CLE X X X X

105 Easterwood Fld CLL X

106

Charlotte/Douglas 

Int'l

CLT X X X X

107 Port Columbus Int'l CMH X X X X

108 University of Illinois CMI X

109 Houghton Co Mem CMX X

110

Cavern City Air 

Term

CNM

111 Canyonlands Field CNY

112 Yellowstone Reg COD X

113 Coeur D'Alene COE X

114 Colorado Springs Muni COS X X X X

115 Columbia Reg COU X

116 Natrona Co Int'l CPR X X

117 St. Louis Downtown CPS

118 Corpus Christi Int'l CRP X X X

119 McClellan-Palomar CRQ X X X

120 Yeager CRW X X

121 Columbus Metro CSG X

122

Cincinnati/North 

Kentucky Int'l CVG X X X X

123 Clovis Municipal CVN

124 Central Wisconsin CWA X

125 Chennault Int'l CWF X

126 Cheyenne CYS X

127 Daytona Beach Int'l DAB X X X

128 Dallas Love Fld DAL X X X X

129 Cox Dayton Int'l DAY X X X X

Table A.7. Airport Groupings
100 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

130 Dubuque Reg DBQ X

131

Ronald Regan 

Washington 

National

DCA X X X X

132 Dodge City Reg DDC

133 Decatur DEC X

134 Denver Int'l DEN X X X X

135

Dallas/Ft Worth Int'lDFW X X X X

136 Red Dog DGG

137 Dothan DHN X

138 Dickinson Muni DIK

139 Dillingham DLG X

140 Duluth Int'l DLH X X

141 Dover Civil Air Terminal DOV X X

142 Durango-LaPlata Co DRO X

143 Del Rio Int'l DRT X X

144 Des Moines Int'l DSM X X X

145

Detroit Metro 

Wayne Co

DTW X X X X

146

Du Bois-Jefferson 

Co

DUJ

147 Unalaska DUT X X

148 Devils Lake Muni DVL X

149 Kearney Regional EAR

150 Pangborn Mem EAT X

151 Chippewa Valley Reg EAU X

152

Northwest Florida 

Beaches Int'l ECP X

153 Ellington Fld EFD X X

154 Eagle Co Reg EGE X X

155 Elko Muni EKO X

Table A.7. Airport Groupings
101 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

156 Elmira/Corning Reg ELM X X

157 El Paso Int'l ELP X X X

158 Yelland Fld ELY

159 Kenai Muni ENA X

160 Wendover ENV X

161

Erie Int'l/

Tom Ridge Fld

ERI X X

162 Delta Co ESC X

163 Mahlon Sweet Fld EUG X

164 Evansville Reg EVV X

165 Craven Co Reg EWN X

166 Newark Liberty Int'l EWR X X X X

167 Key West Int'l EYW X X

168 Fairbanks Int'l FAI X X X X

169 Fitiuta FAQ

170 Hector Int'l FAR X X

171 Fresno Yosemite Int'l FAT X X X X

172

Fayetteville 

Reg/Grannis Fl FAY X

173

Fort HuachucaSierra Vista FHU X

174 Venango Reg FKL

175 Flagstaff Pulliam FLG X

176

Fort 

Lauderdale/Holly

wood Int'l

FLL X X X X

177 Florence Reg FLO X

178 Four Corners Reg FMN

179

Ft 

Collins/Loveland 

Muni

FNL X X

180 Bishop Int'l FNT X X X

181 Ft. Dodge Reg FOD

Table A.7. Airport Groupings
102 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

182 Forbes Fld FOE

183 Republic FRG X X

184 Joe Foss Fld FSD X X

185 Fort Smith Reg FSM X

186

Fort Worth 

Meacham Int'l

FTW X

187 Fort Wayne Int'l FWA X X

188 Drake Fld FYV

189 Great Bend Muni GBD

190 Galbraith Lake GBH

191 Gillette-Campbell Co GCC

192 Garden City Reg GCK X

193

Grand Canyon 

National Park

GCN X X

194 Dawson ComMuni GDV

195 Spokane Int'l GEG X X X

196 Grand Forks Int'l GFK X X X

197 Floyd Bennett Mem GFL X

198 Gregg Co GGG X

199

Wokal 

Fld/Glasgow Int'l GGW

200 Walker Fld GJT X

201 Greenville Regl GLH X

202 Gainesville Reg GNV X

203 Groton-New London GON X

204 Glacier Park Int'l GPI X X

205 Gulfport-Biloxi Reg GPT X X X

Table A.7. Airport Groupings
103 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

206 Austin Straubel Int'l GRB X X X

207 Central Nebraska RegGRI X

208 Killeen/Ft.Hood Reg GRK X

209 Rota Island GRO X X

210 Kent Co Int'l GRR X X X

211 Saipan Int'l GSN X X X

212 Piedmont-GreensboroGSO X X X

213

GreenvilleSpartanburg

GSP X X X

214 Gustavus GST X

215 Great Falls Int'l GTF X X

216 Golden Triangle Reg GTR X

217 Gunnison Co GUC X

218 Guam Int'l GUM X X X

219 Donaldson Ctr GYH

220 Gary/Chicago GYY X

221 Yampa Valley HDN X

222

Natches-Adams 

County

HEZ

223 Hagerstown Reg HGR

224 Chisholm-Hibbing HIB X

225 Hickory Municipal HKY X

226 Helena Reg HLN X X

227 Honolulu Int'l HNL X X X X

228 Homer HOM X

229 Huron Reg HON

230 Memorial Fld HOT

231 William Hobby HOU X X X X

232 Westchester Co HPN X X X X

Table A.7. Airport Groupings
104 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

233 Valley Int'l HRL X X X

234 Stennis Int'l HSA X

235 Huntsville Int'l HSV X X X

236

Tri-State/Milton J 

Ferguson Fld

HTS X X

237

Terr Haute Int'lHulman Fld

HUF

238 Hutchinson Muni HUT

239 Tweed-New Haven HVN X X

240 Havre City-Co HVR

241

Hilton Head HXD X

242 Barnstable Muni HYA X X X

243 Hays Regional HYS

244 Washington Dulles Int'l IAD X X X X

245 Niagara Falls Int'l IAG X X

246 Bush IntercontinentalIAH X X X X

247

Wichita 

Mid-Continent

ICT X X X X

248 Fanning Fld IDA X

249

Laughlin/Bullhead 

Int'l

IFP X

250 Kingman IGM

251 New Castle Co ILG X X

252 Wilmington Int'l ILM X X X

253 Airborne Airpark ILN

254

Ford IMT X

255 Indianapolis Int'l IND X X X X

Table A.7. Airport Groupings
105 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

256 Falls Int'l INL X X

257 Smith Reynolds INT X X

258 Imperial County IPL

259 Williamsport Reg IPT X

260 Kirksville Reg IRK

261 Sloulin Fld. Int'l ISN X

262 Kinston Reg Jetport ISO X

263 Long Island MacArthurISP X X X X

264 Ithaca Tompkins Reg ITH X

265 Hilo Int'l ITO X X X

266 Phoenix-Mesa GatewayIWA X X X

267 Gogebic-Iron Co IWD X

268 Inyokern IYK

269 Jackson Hole JAC X

270 Jackson Int'l JAN X X X

271 Jacksonville Int'l JAX X X X

272 JFK Int'l JFK X X X X

273 Kapalua JHM X

274

Chautauqua 

Co/Jamestown JHW X

275 Joplin Reg JLN X

276 Jamestown Muni JMS X

277 Juneau Int'l JNU X X X

278 Concord Regional JQF

279

John Murtha 

JohnstownCambria CoJST X

280 Rock Co JVL

281 Kona Int'l at KeaholeKOA X X X X

Table A.7. Airport Groupings
106 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

282 Ketchikan Int'l KTN X X

283 Purdue University LAF

284 Lakeland Linder Reg LAL

285 Capital City LAN X X

286 Laramie Reg LAR

287 McCarran Int'l LAS X X X X

288 Lawton-Ft Still Reg LAW X

289 Los Angeles Int'l LAX X X X X

290 Lubbock Int'l LBB X X X

291 Arnold Palmer Reg LBE X

292 North Platte Reg LBF

293 Liberal Mid-America Reg LBL

294 Brazoria County Airport LBX

295 Lake Charles Reg LCH X X

296 Rickenbacker Int'l LCK X X

297 Blue Grass LEX X X X

298 Lafayette Reg LFT X X

299 La Guardia LGA X X X X

300

Long Beach/

Daugherty Fld

LGB X X X

301 Logan-Cache LGU

302 Lihue LIH X X X X

303 Adams Fld LIT X X X

304 Klamath Falls Int'l LMT X

305 Lincoln LNK X

306 Lancaster LNS

307 Lanai LNY X

308 Laredo Int'l LRD X X

309 Las Cruces Int'l LRU

Table A.7. Airport Groupings
107 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

310 La Crosse Muni LSE X

311 Cincinnati Muni LUK X

312 Greenbrier Valley LWB X

313

Lewiston-Nez 

Perce Co

LWS X

314 Lewistown Muni LWT

315

Lynchburg 

Reg/Preston Glenn 

Fld

LYH X

316 Midland Int'l MAF X X X

317

Manistee CoBlacker

MBL X

318 MBS Int'l MBS X X

319

Merced 

Regional/MacRea

dy Field

MCE

320 Kansas City Int'l MCI X X X X

321 Mc Cook Ben Nelson Reg MCK

322 Middle Georgia Reg MCN X

323 Orlando Int'l MCO X X X X

324 Mason City Muni MCW X

325

Southern Ilinois MDH

326 Harrisburg Int'l MDT X X X

327 Chicago Midway MDW X X X X

328 Henderson Fld MDY

329 Key Fld MEI X

330 Memphis Int'l MEM X X X X

331 Mansfield Lahm MuniMFD

332 Mc Allen Miller Int'l MFE X X X

333 Rogue Valley Int'l MFR X

334 Dannelly Fld MGM X

Table A.7. Airport Groupings
108 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

335

Morgantown 

Muni

MGW X

336 Manhattan Reg MHK X

337 Manchester MHT X X X

338 Miami Int'l MIA X X X X

339 Delaware Co MIE

340

Charles B Wheeler 

Downtown MKC X

341 General Mitchell Int'lMKE X X X X

342 Muskegon Co MKG X

343 Molokai MKK X

344 McKellar-Sipes Reg MKL X

345 Melbourne Reg MLB X X X

346 Quad City Int'l MLI X X X

347 Frank Wiley Fld. MLS

348 Monroe Reg MLU X

349 Mammoth Yosemite MMH X

350 Mobile Reg MOB X X X

351

Modesto City/

Harry Sham

MOD X

352 Minot Int'l MOT X X

353 Smyrna MQY

354 Monterey Peninsula MRY X X

355

Muscle Shoals 

Reg

MSL X

356 Dane Co Reg MSN X X

357 Missoula Int'l MSO X

358

Minneapolis-St 

Paul Int'l

MSP X X X X

359

Massena Int'l -

Richards Fld

MSS X

360 Sullivan Co Int'l MSV

Table A.7. Airport Groupings
109 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

361 New Orleans Int'l MSY X X X X

362 Marathon MTH X

363 Montrose Reg MTJ X

364

Coles Co Mem MTO

365 Mount Vernon MVN

366 Marthas Vineyard MVY X

367 Wiliamson Co Reg MWA

368 Grant Co MWH X

369 Myrtle Beach Jetport MYR X X X

370 Millington Regional Jetport NQA

371

Yuma MCAS-Yuma 

Intl NYL X X X

372 Albert J Ellis OAJ X X

373 Metro Oakland Int'l OAK X X X X

374 Ocala International OCF

375 Ogden-Hinckley OGD X

376 Kahului OGG X X X X

377 Ogdensburg Int'l OGS X

378 Will Rogers World OKC X X X X

379 LM Clayton OLF

380 Eppley Airfield OMA X X X X

381 Nome OME X X

382 Newport Muni ONP

383 Ontario Int'l ONT X X

384 Chicago O'Hare Int'l ORD X X X X

385 Norfolk Int'l ORF X X X

386 Worcester Reg ORH X X

Table A.7. Airport Groupings
110 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

387 Ohio State UniversityOSU

388 North Bend Muni OTH X

389 Ralph Wien Mem OTZ X

390

OwensboroDavies Co

OWB

391 Oxnard OXR

392 Snohomish Co PAE X X

393 Barkley Reg PAH X

394 Plattsburgh Int'l PBG X X

395

West Palm Beach Int'lPBI X X X X

396 Eastern Oregon Reg PDT

397 Portland Int'l PDX X X X X

398 Page Muni PGA

399 Charlotte Co PGD X

400 Pitt-Greenville PGV X

401

Newport 

News/Williamsbu

rg Int'l

PHF X X X X

402 Philadelphia Int'l PHL X X X X

403

Phoenix Sky 

Harbor Int'l

PHX X X X X

404 Greater Peoria Reg PIA X X

405

HattiesburgLaurel Reg

PIB X

406

St. 

Petersburg/Clear

water Int'l

PIE X X X

407 Pocatello Reg PIH

408 Pierre Reg PIR X

409 Pittsburgh Int'l PIT X X X X

410 Mid-Ohio Valley Reg PKB X

Table A.7. Airport Groupings
111 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

411

Pellston Reg Arpt 

of Emmet

PLN X

412 Pensacola Reg PNS X X X X

413 Dutchess Co POU

414 Prospect Creek PPC

415 Pago Pago Int'l PPG X

416 No. Maine Reg PQI X X

417 Ernest Love Fld PRC X X

418 Tri-Cities PSC X

419 Mercedita PSE X X

420

Petersburg James 

Johnson

PSG X

421 Pease Int'l TradeportPSM X X

422 Palm Springs Reg PSP X X X

423 Oakland Co Int'l PTK X X

424 Pueblo Muni PUB X

425

Pullman/Moscow 

Reg

PUW X

426 Theodore Francis Green State PVD X X X

427 Provo Muni PVU X X

428 Portland Int'l JetportPWM X X X

429 Rapid City Reg RAP X

430 Redding Muni RDD X

431

Reading Reg/C A 

Spatz Fld

RDG

432 Roberts Fld RDM X

433 Raleigh-Durham Int'l RDU X X X X

434 Greater Rockford RFD X X

435 Rhinelander-Oneida CoRHI X

436 Richmond Int'l RIC X X X X

437 Riverton Reg RIW

Table A.7. Airport Groupings
112 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

438

Rock SpringsSweetwater

RKS

439 Griffiss Airpark RME X

440 Reno/Tahoe Int'l RNO X X X

441

Roanoke 

Reg/Woodrum Fld ROA X X

442 Greater Rochester Int'lROC X X X X

443 Roswell Intern'l Air CtrROW X X

444 Rochester Int'l RST X X

445 SW Florida Int'l RSW X X X X

446 Rutland State RUT

447 Rocky Mount-WilsonRWI

448 Santa Fe Muni SAF X

449 San Diego Int'l SAN X X X X

450 San Antonio Int'l SAT X X X X

451 Savannah Int'l SAV X X X X

452 Sawyer Int'l SAW X

453 Santa Barbara Muni SBA X X X

454

San Bernardino Int'l SBD

455 South Bend Reg SBN X

456 San Luis Obispo Co SBP X

457

Salisbury-Ocean 

City Wicomico 

Reg

SBY X

458 Deadhorse SCC X

459 Stockton Metro SCK X

460 Standiford Field SDF X X X X

461

Sidney-Richland 

Muni

SDY

462 Seattle-Tacoma Int'l SEA X X X X

463 Orlando Sanford SFB X X X X

Table A.7. Airport Groupings
113 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

464 San Francisco Int'l SFO X X X X

465

SpringfieldBranson National

SGF X X X

466

SpringfieldBeckley Muni

SGH

467 St. Augustine SGJ X X X

468

Shenandoah 

Valley Reg SHD X

469 Sheridan Co SHR

470 Shreveport Reg SHV X X

471

Sitka Rocky 

Gutierrez

SIT X X

472 San Jose Int'l SJC X X X X

473 Mathis Fld SJT X

474

Luis Munoz Marin 

Int'l

SJU X X X X

475 Salt Lake City Int'l SLC X X X X

476 McNary Fld SLE

477 Adirondack Reg SLK X

478 Salina Muni SLN

479 Sacramento Int'l SMF X X X X

480 Santa Maria Pub SMX X

481

John WayneOrange Co

SNA X X X

482 Moore Co SOP

483 Show Low Muni SOW

484 Abraham Lincoln MemSPI X

485 Shepard AFB/Wichita Falls SPS X X

486

Sarasota/Bradent

on Int'l

SRQ X X X X

487 Sierra Blanca Reg SRR

488 St Cloud Reg STC X

489 Rosecrans Mem STJ

Table A.7. Airport Groupings
114 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

490

Lambert-St Louis 

Int'l

STL X X X X

491

Charles M. SchulzSonoma Co

STS X

492 Cyril E King STT X X X

493 Henry E Rohlsen STX X X

494

Friedman Mem SUN X

495 Spirit of St Louis SUS X X

496 Sioux Gateway SUX X

497 Grant Co SVC

498 Stewart Int'l SWF X X X

499 Stillwater Muni SWO

500 Syracuse Hancock Int'lSYR X X X

501 Tuscaloosa Muni TCL

502 Teterboro TEB X X

503 Telluride Reg TEX X

504 Space Center ExecutiveTIX X

505 Tallahassee Reg TLH X X

506 West Tinian TNI X

507 Toledo Express TOL X X

508 Tampa Int'l TPA X X X X

509

Tri-City Municipal TRI X X

510 Trenton Mercer TTN X X

511 Tulsa Int'l TUL X X X X

512 Tupelo Muni TUP X

513 Tucson Int'l TUS X X X X

514 Cherry Capital TVC X

515

Thief River Falls Reg TVF X

Table A.7. Airport Groupings
115 Count Airport Name Airport 

Ident.

Large Hub Medium 

Hub

Small Hub >100 K Ops International Class I

516

Lake Tahoe TVL

517 Magic Valley Reg TWF X

518

Texarkana RegWebb Fld

TXK X

519 Tyler Pounds Fld TYR X

520 McGhee Tyson TYS X X X X

521 Quincy Reg UIN

522 University Park UNV X

523 University-Oxford UOX

524 Tunica UTA X

525 Victoria Reg VCT X

526 Southern Calif. Logistics VCV

527 Valdez VDZ X X

528 Vernal Airport VEL

529 North Las Vegas VGT X

530 Visalia Muni VIS

531 Valdosta Reg VLD X

532 Eglin Air Force Base VPS X X

533 Porter Co Muni VPZ

534

Antonio Rivera 

Rodrigues VQS X X

535 Vero Beach Muni VRB X

536 Wrangell WRG X X

537 Worland Muni WRL

538

Yellowstone WYS

539

Northwest 

Arkansas

XNA X X

540 Yankutat YAK X

541 Willow Run YIP X

542 Yakima Air Term YKM X

543

YoungstownWarren Reg YNG X

544 Ofu Z08

Total 2 9 3 7 7 2 128 240 388

Table A.7. Airport Groupings
116

Appendix 4: Benefits
117
118

FAA Wildlife Strike Database, Wildlife 
119

Aviation Accident/Incident Database, AIDS
120

Aviation Safety Reporting System, ASRS
121

Occupational Safety and Health Administration, OSHA
122

Runway Incursion Database, RI
123

Appendix 5: Pilot Study Participant Breakout

Pilot Study Participants by Part 139 AOC Class

Class I Class II Class III Class IV

First and Second 

Study

20 3 2 6

Proof of Concept 2 0 0 1

Implementation 

Study

11 1 0 2

Pilot Study Participants by NPIAS Category

Large 

Hub

Medium 

Hub

Small 

Hub

Non-Hub Commercial 

Service

Reliever General 

Aviation

First and 

Second Study

5 6 4 9 1 4 2

Proof of 

Concept

1 0 0 1 0 1 0

Implementation 

Study

3 4 1 4 0 1 1

Pilot Study Participants by International Categorization

International Not International

First and Second Study 20 11

Proof of Concept 1 2

Implementation Study 8 6
124

Appendix 6: Compilation of Pilot Study Documentation

Publications

Airports Cooperative Research Program. (2009). ACRP Report 1, Safety Management Systems for 

Airports, Volume 2: Guidebook. Washington, DC: Transportation Research Board.

Airports Cooperative Research Program. (2012). ACRP Synthesis 37, Lessons Learned from Airport Safety 

Management Systems Pilot Studies. Washington, DC: Transportation Research Board.

Airports Cooperative Research Program. (2014). ACRP Synthesis 58, Safety Reporting Systems at 

Airports. Washington, DC: Transportation Research Board.

Airports Cooperative Research Program. (2015). ACRP Report 131, A Guidebook for Safety Risk 

Management for Airports. Washington, DC: Transportation Research Board.

Airports Cooperative Research Program. (2013). Legal Issues Related to Developing Safety 

Management Systems and Safety Risk Management at U.S. Airports, Legal Research Digest 19. 

Washington, DC: Transportation Research Board.

Federal Aviation Administration. (2008). Airport SMS Pilot Project 1 Findings. Presentation to the 

AAAE/MITRE/ACI-NA Safety Management System for Airports Conference, available at 

http://www.faa.gov/airports/airport_safety/safety_management_systems/external/pilot_studies/medi

a/1st_sms_pilot_present.pdf.

Federal Aviation Administration. (2011). Report on Airport Safety Management Systems (SMS) Pilot 

Studies, available at 

http://www.faa.gov/airports/airport_safety/safety_management_systems/media/smsPilotTechReport

May2011.pdf.

Federal Aviation Administration. (2012). Part 139 Safety Management System (SMS) Implementation 

Study: November 2011 Roundtable Meeting Summary, available at 

http://www.faa.gov/airports/airport_safety/safety_management_systems/external/pilot_studies/medi

a/part139SMSImplementationStudyRoundtable.pdf.

Individual Airport SMS Documents

Available at 

http://www.faa.gov/airports/airport_safety/safety_management_systems/external/pilot_studies/docu

mentation/

Austin-Bergstrom Intl, TX – Statement of Work, Gap Analysis, Draft SMS Manual, SMS Manual, SRM 

Training Presentation, SRM Decision Report Template

Baltimore-Washington Intl, MD – SMS Manual
125

Boeing Field, WA – SMS Manual

Cheyenne Regional, WY – Draft Risk Matrix Definition, Draft Risk Analysis and Assessment Guidance, 

SRM Process, November 2011 SMS Implementation Study Roundtable Meeting Presentation

Concord Regional, NC – SMS Implementation Plan, Gap Analysis, Draft SMS Manual, SMS Manual, 

Management Commitment (Safety Policy)

Dallas-Fort Worth Intl, TX – Statement of Work, November 2011 SMS Implementation Study Roundtable 

Meeting Presentation

Detroit Metro-Wayne County, MI – Gap Analysis, SMS Manual

Dubuque Regional, IA – SMS Manual Volume 1, SMS Manual Volume 2, November 2011 SMS 

Implementation Study Roundtable Meeting Presentation

Fort Worth Alliance, TX – Gap Analysis

Hartsfield-Jackson Atlanta Intl, GA –Implementation Study Findings, Implementation Pilot Study Final 

Report

Indianapolis Intl, IN – November 2011 SMS Implementation Study Roundtable Meeting Presentation

Jacksonville Intl, FL – Gap Analysis, Implementation Study, SMS Manual, November 2011 SMS 

Implementation Study Roundtable Meeting Presentation

Kona Intl at Keahole, HI – Gap Analysis, SMS Management Plan, SMS Manual

Ohio State University Airport, OH – November 2011 SMS Implementation Study Roundtable Meeting 

Presentation

Pittsburgh Intl, PA – November 2011 SMS Implementation Study Roundtable Meeting Presentation

Sacramento Intl, CA – Gap Analysis, Gap Analysis Matrix, Injury and Illness Prevention Plan

San Antonio Intl, TX – November 2011 SMS Implementation Study Roundtable Meeting Presentation

Santa Maria Public, CA – Gap Analysis, SMS Draft Management Plan, SMS Manual

Seattle-Tacoma Intl, WA – Assurance Plan, Data Collection and System Review, Minimum Standards, 

Non-Punitive Program and Legal Authority, SMS Roles and Responsibilities, Safety Policy Guide, SelfInspection Program, Training and Orientation, November 2011 SMS Implementation Study Roundtable 

Meeting Presentation

South Bend Regional, IN – Monthly Progress Reports, Safety Risk Assessment Report, Safety Risk 

Assessment Documentation, November 2011 SMS Implementation Study Roundtable Meeting 

Presentation
126

Southern Illinois, IL – Gap Analysis, Risk Matrix, SMS Manual, Safety Risk Assessment, November 2011 

SMS Implementation Study Roundtable Meeting Presentation

Talladega Municipal, AL – Gap Analysis, SMS Manual

Tallahassee Regional, FL – November 2011 SMS Implementation Study Roundtable Meeting 

Presentation

Toledo Express, OH – November 2011 SMS Implementation Study Roundtable Meeting Presentation