Office of Inspector General

Audit Report

FAA HAS NOT EFFECTIVELY IMPLEMENTED 

ITS WILDLIFE HAZARD MITIGATION 

PROGRAM

Federal Aviation Administration

Report Number: AV-2012-170

Date Issued: August 22, 2012
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FAA Has Not Effectively Implemented 

Its Wildlife Hazard Mitigation Program 

Federal Aviation Administration

Report No. AV-2012-170

Date: August 22, 2012

From: Jeffrey B. Guzzetti

Assistant Inspector General 

for Aviation and Special Program Audits

Reply to 

Attn. of: JA-10

To: Acting Federal Aviation Administrator

In January 2009, US Airways Flight 1549 struck a flock of Canada geese shortly 

after takeoff from LaGuardia Airport, forcing the flight crew to land the airplane 

in the Hudson River. More recently, on April 19, 2012, Air Force Two, with the 

Vice President on board, sustained a wildlife strike while approaching Santa 

Barbara Municipal Airport when birds hit the right side of the aircraft. The Vice 

President’s aircraft touched down safely, and all passengers were unharmed. 

However, in the immediate aftermath of both incidents, the risk of wildlife hazards 

at or near airports received increased attention, as did the Federal Aviation 

Administration’s (FAA) Wildlife Hazard Mitigation Program, which seeks to 

reduce the risk of wildlife hazards to aviation and serves an important role in 

FAA’s overall safety mission.

Wildlife strikes are not new threats to aviation safety. In the past 2 decades, 

wildlife strikes have steadily and dramatically increased, from 1,770 reported in 

1990 to 9,840 reported in 2011, a five-fold increase. The rise in strikes is due in 

part to increases in large bird populations. According to the U.S. Department of 

Agriculture (USDA), 13 of the 14 largest bird species have shown significant 

population increases. These include Canada geese, white and brown pelicans, 

sandhill cranes, wild turkeys, and bald eagles—all of which could cause 

catastrophic failure if ingested into an aircraft engine. Wildlife strikes have 

resulted in at least 24 deaths and 235 injuries in the United States, and since 1988, 

229 deaths worldwide. They also have caused nearly 600,000 hours of aircraft 

downtime and $625 million in damages annually. 
2

Given the rise in reported wildlife strikes and their safety implications, we initiated 

this audit to assess the effectiveness of FAA’s Wildlife Hazard Mitigation 

Program (Program). Specifically, we assessed FAA’s (1) oversight and 

enforcement of airports’ adherence to Program requirements; (2) policies and 

guidance for monitoring, reporting, and mitigating wildlife hazards; and 

(3) coordination with other Government agencies that have a role in mitigating 

wildlife hazards. 

We conducted this performance audit in accordance with generally accepted 

Government auditing standards. Exhibit A details our scope and methodology, and 

exhibit B lists organizations visited, contacted, and/or reviewed.

RESULTS IN BRIEF 

FAA’s oversight and enforcement activities are not sufficient to ensure airports 

fully adhere to Program requirements or effectively implement their wildlife 

hazard management plans. FAA has not developed robust inspection practices, and 

its inspectors do not have the technical expertise to effectively oversee the 

Program. Inspectors we spoke with mostly relied on interviews with airport 

personnel to determine compliance with regulatory requirements, rather than 

reviewing strike and airport records. Also, inspectors were not maintaining 

adequate records of their inspection activities. We randomly selected a sample of 

40 out of 209 airports and found that inspectors at 21 of the 40 airports did not 

know whether the airports’ assessments and plans had been FAA reviewed and 

approved or whether the airports were even required to conduct an assessment or 

develop a plan. FAA’s oversight is limited by a lack of wildlife hazard expertise 

among its airport inspectors. In addition, FAA did not always initiate enforcement 

actions against noncompliant airports. We identified 25 instances of airports’ 

noncompliance with Program requirements between fiscal years 2009 and 2011 at 

the 8 randomly selected airports we visited in which inspectors did not initiate 

enforcement actions.

FAA’s policies and guidance for monitoring, reporting, and mitigating wildlife 

hazards are mostly voluntary, thereby limiting their effectiveness. While FAA 

recommends wildlife strike reporting, it does not require it. Consequently, not all 

airports choose to report all their wildlife strikes. For example, one airport we 

visited reported 90 percent of strikes recorded in 2010 to FAA, while another 

airport reported only 11 percent. Also, FAA does not have policies and guidance 

for monitoring its progress toward meeting the Program’s goal of reducing 

wildlife hazards at or near airports. Industry and government experts have 

recommended using the rate of total strikes and/or damaging strikes as possible 

performance metrics; however, these metrics will not be useful until FAA 

improves the quantity and quality of the data reported to its strike database.
3

FAA has an effective process for coordinating with USDA Wildlife Services 

(WS), its main partner in wildlife hazard mitigation at or near airports. However, 

FAA’s coordination with other Government agencies that help mitigate wildlife 

hazards is not sufficient to effectively manage off-airport1 hazards and strikes. 

Despite a 2003 multi-agency Memorandum of Agreement (MOA) to coordinate 

with agencies such as U.S. Army Corps of Engineers (USACE), FAA did not 

establish notification procedures with all USACE district offices to learn of 

proposed or planned projects that could increase hazardous wildlife populations 

near airports.2 For example, when USACE proposed a bird nesting island project 

within 5 miles of two airports near Savannah, GA, a wildlife hazard assessment 

was not considered. Only when the project was nearly completed did FAA and the 

agencies involved in the project agree to initiate a wildlife hazard assessment, 

7 years after the project began.3

We are making a series of recommendations intended to improve on the 

management and oversight of the Program. 

In addition, FAA does not have procedures in 

place to assist airports in securing the necessary permits. As a result, FAA cannot 

ensure airports are fully implementing the mitigation strategies in the plans.

BACKGROUND 

FAA’s Program provides Federal assistance to airports for wildlife mitigation. 

From 1997 to 2011, FAA provided an estimated $458 million4

FAA manages the Program by requiring Class I through III Part 139 airports

to airports for 

projects to help assess and mitigate wildlife hazards, and the Agency estimates it 

will spend an additional $366 million over the next 20 years. 

5

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 FAA considers "off-airport" as an area up to 5 statute miles from an airport’s aircraft movement areas, loading 

ramps, or aircraft parking areas.

to 

conduct an assessment and, if required, develop and implement a plan. 

Specifically, Title 14 Code of Federal Regulations (CFR), Part 139.337, requires 

these airports to: 

2 Signatory agencies agreed to encourage their regional and local offices to develop interagency procedures to 

implement the 2003 MOA, including procedures that address the management of habitats that could attract 

hazardous wildlife at or near airports. Signatories include FAA; USDA WS; U.S. Fish and Wildlife Service (FWS), 

USACE, and the Environmental Protection Agency (EPA). 3 FAA only took this action because the airport commission managing both airports expressed concerns to FAA 

regarding hazardous wildlife movement near both airports’ runway approach. 4 Funds are administered through the Airport Improvement Program grant program. 5 There are a total of 549 Part 139 airports which comprise of Class I through IV airports. Federal regulations require 

451 Class I through III airports to comply with Part 139.337 requirements, including wildlife mitigation 

requirements. Airports serving all types of scheduled operations of air carrier aircraft designed for at least 31 

passenger seats (large air carrier aircraft) and any other type of air carrier operations are Class I airports. Class II 

airports are those airports that serve scheduled operations of small air carrier aircraft and unscheduled operations of 

large air carrier aircraft. Class III airports are those airports that serve only scheduled operations of small air carrier 

aircraft.
4

x Assess the risk and magnitude of wildlife hazards after experiencing a 

“triggering event,” such as multiple birds striking an aircraft, engine ingestion 

of birds, or substantial damage to aircraft from strikes. An assessment must be 

conducted by a qualified wildlife biologist or someone supervised by a 

qualified wildlife biologist.

x Create and implement a plan to mitigate wildlife hazards, if found necessary 

after an assessment, and to review those plans annually. 

FAA is in the process of amending its regulation to require that all certificated 

airports conduct wildlife hazard assessments—rather than just those airports that 

experience a “triggering event”—and to periodically update them. This 

amendment would result in requiring more than 500 Part 139 airports to conduct 

assessments over the next 5 years. FAA estimates these initiatives will cost 

$366 million in Airport Improvement Program (AIP) funds.

FAA is responsible for oversight and enforcement of airport compliance with 

wildlife hazard regulations, which it conducts through the Agency’s nine regional 

offices. The Agency employs a total of 35 airport certification safety inspectors, 

whose responsibilities include reviewing airports’ wildlife hazard assessments and 

plans as well as conducting many other non-wildlife related safety inspections. 

FAA coordinates with other government agencies, such as USDA WS, U.S. Fish 

and Wildlife Service, USACE, and the Environmental Protection Agency to 

mitigate wildlife hazards. In 2003, FAA signed a MOA with these Federal 

agencies to coordinate their missions more effectively to address current and 

future environmental conditions contributing to aircraft-wildlife strikes throughout 

the United States. These efforts are intended to minimize wildlife risks to aviation 

and human safety, while protecting the Nation’s environmental resources.

FAA’S OVERSIGHT AND ENFORCEMENT OF AIRPORT 

WILDLIFE MITIGATION EFFORTS ARE INSUFFICIENT

FAA’s oversight and enforcement activities are not sufficient to ensure that 

airports are fully adhering to wildlife hazard assessment and plan requirements or 

effectively implementing their plans to reduce strikes. As a result of these 

practices, FAA has missed instances of airports’ noncompliance with Program 

requirements. Additionally, FAA does not have assurance that wildlife biologists 

who conduct the required assessments for airports or the FAA inspectors6

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 6 There are a total of 35 airport inspectors in the 9 FAA regions. We interviewed 19 of 20 inspectors in the 4 randomly 

selected regions. The 19 inspectors oversaw the 40 airports’ programs we randomly selected for review. 

who 

review them have the qualifications and expertise needed in wildlife management.

Without sufficient oversight, enforcement, and wildlife hazard expertise, the 
5

extent to which airports are effectively implementing their plans remains 

unknown.

Oversight and Enforcement of Airports’ Compliance With Wildlife 

Hazard Mitigation Requirements Is Lacking

FAA did not sufficiently oversee whether airports complied with Program 

requirements. FAA regulations require that airports assess the magnitude of strike 

risks and if needed, monitor and mitigate wildlife hazards to reduce risk. However, 

FAA did not initiate efforts to identify noncompliant airports until after the 

January 2009 accident on the Hudson River. Following that accident, FAA 

identified 96 airports nationwide that had triggering events between 2004 and 

2009 but failed to complete the necessary assessments—revealing a significant 

gap in FAA’s oversight during this time period. 

FAA’s oversight remains limited due to its inadequate inspection practices. We 

found that, while the Eastern region7

x FAA’s documentation of Part 139 inspections

is outperforming the other three regions we 

visited (see exhibit C), all four regions’ inspection practices are not sufficient to 

ensure airports are meeting wildlife hazard regulatory requirements. For example:

8

x FAA missed opportunities to identify instances of noncompliance. The 

4 FAA regions we reviewed issued a total of 16 enforcement actions

was unreliable.

Documentation was generally limited to an inspection checklist on the 

regulatory requirements or an inspection closeout letter and did not capture 

how the inspectors determined compliance with each item on the checklist or 

the closeout letter. For example, all checklists or closeout letters we reviewed 

showed that inspectors concluded that the airports were “satisfactorily” 

implementing their plans. However, there was no documentation to support 

how the inspectors made this determination such as the questions asked, airport 

responses, or the documents reviewed. We also found that 30 inspection 

checklists and closeout letters (75 percent) were inaccurate. For example, we 

found four incidents where FAA inspectors indicated on their checklist that 

airports had a wildlife hazard assessment and/or plan when in fact our review 

determined that they did not have one.

9

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 7 In 2009 after the “Miracle on the Hudson” accident, Eastern Region revamped its wildlife program to improve 

oversight and enforcement of airports’ compliance with Program regulations, policies, and guidance. See Exhibit C 

for details.

between 

8 FAA Order 5280.5C requires that its airport safety inspectors conduct periodic certification inspections of airports to 

ensure they are safe and in compliance with Part 139 requirements. The inspections must be fully documented. FAA 

airport inspectors are required to inspect Part 139 Class I airports every 9 to 15 months and Class II and III airports 

every 18 months. 9 These actions included Letters of Correction as well as Letters of Investigation. A Letter of Correction is a 

notification to the violator documenting the agreed upon corrective action. A Letter of Investigation is a notification 

to the violator of a possible violation and to provide the violator an opportunity to discuss the violation.
6

FYs 2009 and 2011. Although the Eastern region issued 14 of these 

enforcement actions, we found an additional 25 instances of noncompliance 

that FAA did not identify at the 8 airports we visited in the 4 regions.10

x FAA does not verify that airports check the qualifications of wildlife 

biologists who conduct the required assessments. According to FAA 

regulations, only wildlife biologists who meet certain requirements may 

conduct wildlife hazard assessments. FAA officials stated that it is the 

responsibility of the airport authorities to review biologists’ qualifications prior 

to contracting for the assessment service. FAA inspectors added that most 

assessments were conducted by USDA biologists who were deemed qualified 

based on FAA’s MOU with USDA WS. However, 15 of the 40 airports in our 

sample utilized non-USDA biologists to conduct their assessments. In one 

case, an FAA inspector found that an airport’s submitted assessment was 

glaringly inadequate and subsequently determined that the poor assessment 

was conducted by an unqualified biologist. This resulted in the airport having 

to repeat the assessment, which took 5 years to complete and two contracts 

totaling approximately $143,000. Since FAA’s new rule will require an 

additional 506 airports

For 

example, three airports did not ensure all wildlife personnel completed the 

required annual training to carry out wildlife duties. FAA inspectors were not 

aware of these noncompliances because they did not verify these requirements 

against airport training records. The three regions asserted that they use 

informal counseling rather than enforcement actions. However, we found little 

evidence of inspectors using informal counseling to ensure airports comply 

with regulations, policies, or guidance.

11

FAA’s Oversight of Airports’ Assessments and Plans Is Limited

to comply with requirements to conduct and update 

their wildlife hazard assessments, there will be a greater demand for wildlife 

biologists and therefore potentially more airports that may use unqualified 

biologists.

FAA inspectors did not always ensure that airports’ wildlife hazard assessments 

and plans were adequate and met all regulatory requirements. Our review found 

that 27 of 35 airports12

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 10 These 4 regions oversee a total of 268 Class 1 through 3 airports. Federal regulations require these airports to comply 

with Part 139.337 requirements.

did not comply with at least 1 or more requirements for 

their assessments and plans. Yet, FAA’s inspection documentation indicated that 

the airports were compliant with all the assessment and plan regulatory 

requirements. Also, FAA inspectors did not effectively track assessments and 

plans for completion, review, and approval. In 21 of 40 airports we reviewed, we 

11 According to FAA, currently, only 46 airports have updated assessments. 12 A total of 35 of the 40 airports in our sample had a wildlife hazard assessment and/or plan. The remaining 5 airports 

are in the process of completing their assessment.
7

found that inspectors did not know whether the airports’ submitted assessments 

and plans had been FAA reviewed and approved or whether the airports were even 

required to conduct an assessment or develop a plan. In one instance, we found 

that FAA required an airport to develop a plan in 2003, but at the time of our 

review the airport had not yet developed it.

In addition to the assessments and plans not meeting the minimum regulatory 

requirements, FAA inspectors do not have the technical expertise to ensure that 

these documents are effective. According to FAA’s Wildlife Hazard Management 

Manual, wildlife hazard management requires expertise from a qualified wildlife 

biologist trained in wildlife damage management control. In addition, FAA 

guidance indicates that a wildlife biologist should review an airport’s plan to 

ensure it is adequate for addressing wildlife strikes. However, of the four FAA 

regions we visited, we found that only the Eastern region adhered to this guidance 

by staffing an inspector with wildlife biologist qualifications to review all 

assessments and plans. Moreover, 17 of 19 FAA inspectors that we spoke to 

disclosed that they only reviewed the assessments and plans for compliance with 

the minimum requirements, as opposed to evaluating the overall adequacy of the 

plans. The inspectors explained that because they were not wildlife biologists they 

did not have the technical expertise to conduct a more thorough review. Without 

sufficient wildlife hazard expertise, the extent to which airports assessment and 

plans are effective remains unknown. 

FAA’S POLICIES AND GUIDANCE FOR MONITORING, 

REPORTING, AND MITIGATING WILDLIFE HAZARDS ARE 

MOSTLY VOLUNTARY

Although FAA has issued 33 policy and guidance documents to airports and 

inspectors to manage its Program, most of these are voluntary, thereby limiting 

their effectiveness. Moreover, FAA has not developed performance metrics for 

measuring the effectiveness of its wildlife hazard mitigation activities. Industry 

experts have recommended using the rate of total strikes and/or damaging strikes 

to aircraft as possible performance metrics, but FAA cannot fully implement these 

suggestions until it improves the quantity and quality of the data reported to its 

strike database.

Most of FAA’s Policies and Guidance Are Voluntary

FAA’s primary guidance for the Program is the over 300-page document, 

“Wildlife Hazard Management at Airports: A Manual for Airport Personnel,” 

dated July 2005, which describes how to develop, implement, and evaluate a 

wildlife management program. However, this and most of FAA’s other policies 

and guidance only contain recommended—as opposed to mandatory—actions for 

airports, such as best practices for conducting required assessments or a suggested 
8

methodology to evaluate the effectiveness of their wildlife mitigation plans. As 

such, FAA does not have the means to ensure that airports are taking advantage of 

these best practices when they create and implement their required assessments 

and plans. Moreover, since these practices are voluntary, they may be 

implemented inconsistently at different airports. As a result, FAA cannot fully 

assess how effective its policies and guidance are at reducing the number and 

severity of wildlife strikes. 

Voluntary Policies and Guidance Result in Incomplete Strike 

Reporting and Data

Currently, FAA’s policies recommend but do not require that airports and pilots 

report all wildlife strikes to FAA’s strike database. In 2009, following an 

investigation of a fatal business jet accident resulting from a wildlife strike, NTSB 

recommended that FAA require airports and aircraft operators to report all wildlife 

strikes.13 In response to this recommendation, FAA commissioned a study in 

200914

However, because FAA’s database contains only voluntary reports, it provides an 

incomplete picture of the total number and severity of wildlife strikes that occur. 

For example, the 2009 study concluded that only 39 percent of actual strikes were 

reported and as many as 36 percent of the events involving wildlife in FAA’s 

Accident/Incident Data System (AIDS)

to analyze wildlife strike reporting rates because poor voluntary strike 

reporting hindered the proper evaluation of the problem. The study found that 

reporting rates were sufficient to identify national wildlife hazard trends and 

develop national policies. Therefore, FAA did not mandate strike reporting. 

Instead, FAA has recently increased its outreach and education efforts—such as 

developing awareness posters and conducting field visits and presentations—to 

encourage more voluntary reporting.

15

We also found that, because strike reporting is voluntary, airports varied in how 

frequently they chose to report strikes to FAA. According to our analysis, at one 

large airport, 90 percent of the airport’s recorded strikes were reported in FAA’s 

strike database while another medium airport reported only 11 percent of its 

strikes. Airport officials stated that they did not report all known strikes to the 

database because it was not a requirement.

database were not captured in its strike 

database. Similarly, at the 8 airports we visited, we found that 108 of 507 

(21 percent) strikes in airports’ internal strike logs were not reported to FAA’s 

strike database for 2010. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 13 In 1999, NTSB issued a similar recommendation after two serious Part 121 aircraft wildlife strikes. The 

recommendation was never implemented by the FAA. NTSB reissued the recommendation after a fatal business jet 

accident that occurred near Oklahoma City, Oklahoma on March 4, 2008. The NTSB’s investigation revealed that 

the jet impacted large birds during climb out, causing catastrophic structural damage and killing 5 people. 14 DOT/FAA/AR-09/65, Trends in Wildlife Strike Reporting, Part 1—Voluntary System 1990-2008, December 2009. 15 The AIDS database contains data records for general aviation and commercial air carrier incidents since 1978. 
9

Furthermore, the data that are reported to the database are often incomplete. For 

the 8 airports we visited, we found that 68 percent (346 of 507) of records in the 

strike database were missing one or more of the following key data fields: extent 

of damage, species of wildlife, phase of flight, altitude that the strike occurred, 

and/or effect on flight. For example, for one 2010 wildlife strike that involved 

$5.5 million in engine damage, the strike report was missing the altitude that the 

strike occurred. This missing data limits the ability of the data users16

Without full reporting and complete data on wildlife strikes, it is difficult to fully 

analyze the magnitude of safety issues, the nature of the problems, and the 

economic cost of wildlife strikes. FAA reported that “one of the biggest challenges 

that wildlife managers at airports face today is the lack of good data.”

to ascertain 

where the strike occurred and implement immediate measures to mitigate the risk 

of another strike.

17

FAA Lacks Performance Metrics To Measure Progress Toward Its 

Program Goal

For 

program management purposes, FAA is also unable to determine whether 

increases in strike reporting are due to increases in actual strikes or increased 

reporting. Conversely, FAA cannot determine whether decreases in strike 

reporting are a result of achieving its program goal or simply a lack of reporting. 

Even though the Program has been in place for more than 50 years, FAA does not 

have policies and guidance for monitoring its progress toward meeting the 

Program’s goal of reducing wildlife hazards at or near airports. FAA includes 

wildlife hazard mitigation as a core business target in its business plan18

In interviews, industry and government experts

and lists

goal-related activities, such as updating airport wildlife hazard guidance and 

identifying airports’ AIP funding needs. However, FAA’s plan does not identify 

any performance metrics for measuring the effectiveness of these target activities. 

The plan generally states that these goal-related activities will “reduce hazard to 

aircraft from bird strike.” Without performance metrics, FAA cannot assess 

whether it is achieving its Program goal. 

19

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 16 Users include airports, airlines, engine manufacturers, FAA, and other Federal agencies.

recommended using total and/or 

damaging strike rates as possible performance metrics for the Program. However, 

the author of the 2009 FAA commissioned study explained that the estimated 

39 percent reporting rate for FAA’s strike database would not be sufficient to 

support a performance metric. This is because performance metrics require more 

complete data—such as those acquired through mandatory reporting—whereas a 

17 Statement is from an article regarding airport safety in FAA’s "Safety Briefing" magazine, dated 

November/December 2011. 18 FY 2011 Office of Airports (ARP) Business Plan. 19 Industry and government experts include USDA wildlife biologists, FAA officials, and representatives from NTSB 

and Smithsonian Institute-Division of Birds.
10

smaller sample provided sufficient data for identifying nationwide trends. 

Therefore, FAA will not be able to effectively create, implement, or support these 

metrics until the Agency improves the quantity and quality of the strike data 

reported to the strike database. 

FAA’S COORDINATION WITH MOST GOVERNMENT AGENCIES 

ON WILDLIFE HAZARD MITIGATION IS LIMITED AND 

INFREQUENT 

While FAA works effectively with USDA WS, its main partner in wildlife hazard 

mitigation, FAA’s efforts to coordinate management of off-airport hazards and 

strikes with other Government agencies are limited and infrequent. These agencies 

play a supportive role in minimizing wildlife risks by managing wetland projects 

that could attract wildlife (see table 1 below). However, FAA inspectors are not 

always aware of issues contributing to wildlife hazards because they seldom reach 

out to these Government agencies. 

Table 1. 2003 Multi-Agency Memorandum of Agreement Roles and 

Responsibilities

FAA Effectively Coordinates With USDA WS

FAA Headquarters and regional offices coordinate effectively with USDA WS.

FAA formalized its relationship with USDA WS through a multi-agency MOA21

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 20 Depredation involves the hazing, capturing, or removal of protected species for health and human safety.

executed in 2003, in response to a NTSB safety recommendation. Per this 2003 

MOA and a 2005 Memorandum of Understanding (MOU), USDA WS provides 

professional wildlife expertise, training, and technical support to airports. In 

21 The MOA recognized each agency’s role in controlling current and future environmental conditions that could 

prevent wildlife strikes.

Agency Expertise Role in Wildlife

Federal Aviation 

Administration (FAA)

Provide leadership in airport design 

planning that mitigates risk from 

aircraft-wildlife strikes.

To initiate coordination with signatory 

agencies to review project proposals 

and evaluate alternative solutions.

U.S. Department of 

Agriculture Wildlife 

Services (USDA WS)

Provide expertise necessary to 

determine the wildlife strike risk 

of various land uses.

To provide wildlife services 

(e.g., depredation20

U.S. Fish and Wildlife 

Service (FWS)

, training, on-call 

biologist) at airports whenever 

requested.

Protect and manage wildlife and their 

habitats, including migratory birds 

and wetlands.

To issue depredation permits 

for wildlife management.

U.S. Army Corps of 

Engineers (USACE)

Protect and manage jurisdictional 

wetlands and their associated wildlife.

To issue permits related to the fill of 

wetlands.

U.S. Environmental 

Protection Agency 

(EPA)

Protect environmental resources. To review and comment on certain 

permits related to the fill of wetlands.
11

addition, USDA WS’s relationship with Federal, State, and local agencies 

provides an avenue that FAA and airports can use to coordinate wildlife hazard 

reduction efforts. 

FAA Headquarters and USDA officials meet several times a month to discuss a 

variety of wildlife issues, such as wildlife policy and guidance updates, wildlife 

strike conferences, and mitigation strategies. In addition, FAA regional offices 

contact USDA WS field offices for technical support on wildlife issues at specific 

airports. Also, FAA regional and USDA field officials meet together annually to 

discuss emerging wildlife issues and annual wildlife training for airport personnel. 

Interagency Coordination With Other Agencies Is Limited

Despite the 2003 MOA, FAA’s coordination with other agencies is limited. All 

four FAA regions we visited did not regularly coordinate with local FWS, 

USACE, and EPA offices. Only 1 of the 16 local district offices22

FAA’s Eastern region was the only region to establish a notification procedure 

with local USACE districts to identify proposed wetland projects that could 

increase wildlife hazards within a 5-mile radius of airports. The remaining three 

regions we visited had not established such procedures. FAA’s lack of notification 

procedures with USACE in the Southern region resulted in a late wildlife hazard 

assessment near two airports near Savannah, GA. USACE did not notify the 

appropriate FAA officials of a proposed bird nesting island project within 5 miles 

of the airports. It was not until the project was nearly completed in 2007—7 years 

after the project was initiated—that the appropriate FAA office was notified of the 

project’s potential risk to aviation safety. The local airport commission expressed 

concerns that the island could cause hazardous wildlife movement near both 

airports’ runway approach. Subsequently, FAA initiated an assessment in 2008 to 

determine the risk and magnitude of wildlife hazards posed by the project. The 

assessment concluded that the activities of gulls and pelicans—the species of most 

concern to local air traffic—should be frequently monitored.

we interviewed 

scheduled and met biannually with FAA to discuss projects or activities that could 

attract wildlife at or near airports. 

FAA Does Not Coordinate With Agencies To Resolve Permit Issues

FAA does not coordinate with other agencies to ensure airports obtain the proper 

permits (e.g., depredation permits or protected species harassment permits) in a 

timely fashion to fully execute their approved wildlife hazard mitigation plans. 

Obtaining permits from Federal, State, and/or local agencies is often necessary 

before airports can carry out plans to mitigate wildlife hazards for their airports. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 22 The 16 local district offices are responsible for the 8 out of 40 airports that we randomly selected for site visits. 
12

Yet, airports often experience lengthy delays between when they apply for and 

when they receive these permits from the permitting agencies. 

As a result of these delays, some airports may be experiencing higher strike risks. 

For example, one airport identified an immediate hazard (a Ferruginous hawk) 

interfering with air operations and applied for a State depredation permit. The 

airport contacted the State agency several times to inquire about the status of the 

permit. However, the State agency delayed responding to the inquiry, which meant 

that the airport was unable to carry out mitigation procedures. Nine months later, 

the same hawk struck a passenger aircraft, causing $3.2 million in damages. Only 

after the airport again contacted the State agency to notify it of the strike and 

follow up on the permit request did the agency respond and issue the permit.

Airport officials we interviewed said they did not notify FAA for assistance when 

they experienced bureaucratic roadblocks to obtaining permits because they did 

not think FAA could assist. While it is true that FAA has no regulatory authority 

over permitting agencies, FAA airport inspectors could reach out to USDA WS to 

assist airports in coordinating with Federal, State, and local agencies on permit 

issues. However, FAA does not have procedures in place to facilitate this 

coordination with State and local agencies. 

CONCLUSION

Increases in the populations of hazardous wildlife species continue to challenge 

airports’ ability to provide a safe operating environment. While FAA is in the 

process of addressing some gaps in its Wildlife Hazard Mitigation Program, 

further steps are needed to ensure FAA meets its Program goal of reducing 

wildlife hazards at or near airports. In particular, it is imperative that FAA 

improve its management processes by improving oversight and enforcement of 

Program regulations, making strike reporting mandatory, establishing performance 

metrics, and strengthening coordination with other governmental agencies. 

Otherwise, the Agency will not be able to ensure that the $366 million in increased 

Program spending over the next 20 years will be used effectively to track and 

analyze trends in wildlife strikes, identify potential new hazards, and mitigate their 

risk.

RECOMMENDATIONS

We recommend that FAA:

1. Require FAA airport inspectors to adhere to Order 5280.5c Airport 

Certification Program Handbook, specifically to:
13

a. Verify that airports are fully implementing and evaluating their wildlife 

hazard management plans, and document the basis for compliance 

determinations with each inspection checklist item and the records 

reviewed for verification, as well as documenting airports’ noncompliance 

with regulations, policies, and guidance and actions airports took to correct 

them; and

b. Verify airports had obtained timely permits to effectively implement their 

wildlife hazard management plans.

2. Establish procedures to verify that airports check biologist qualifications prior 

to airports hiring them to conduct wildlife hazard assessments.

3. As regional airport inspector vacancies become available, staff those positions 

with inspectors with expertise in wildlife damage management and require 

those inspectors oversee the program to specifically:

a. Review and approve wildlife hazard assessments and management plans;

b. Track the review and approval process to ensure airports complete all 

requirements; and

c. Monitor wildlife strikes and, if needed, require airports to reassess their 

wildlife hazard management plans.

4. Require that airports, as part of their wildlife hazard management plans, 

maintain reports of all wildlife strikes and submit the reports quarterly to FAA 

for review. 

5. Require inspectors to verify that airports’ quarterly wildlife strike reports 

contain key data fields, such as extent of damage, species of wildlife, phase of 

flight, altitude that the strike occurred, and effect on flight; and to contact the 

airports with any incomplete or missing data to obtain the information, if 

available.

6. Reconcile the airports’ quarterly reports with FAA’s National Wildlife Strike 

Database and ensure any missing strikes are entered into the database.

7. Develop and implement performance metrics to measure the effectiveness of 

FAA’s target activities in achieving the Program goal of reducing wildlife 

hazards at or near airports. 

8. At a minimum, conduct annual outreach meetings with other government 

agencies to discuss the Memorandum of Agreement, permitting issues, and 

any projects or activities that may attract wildlife at or near airports.
14

9. Establish notification procedures with other government agencies to notify 

FAA of project proposals that may increase hazardous wildlife populations 

within a 5-mile radius of airports.

10. Develop and implement procedures to coordinate with State and local 

agencies to assist airports with permitting issues.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided a draft of this report to FAA on June 21, 2012, and received its 

response on July 30, 2012. FAA’s response is included in its entirety as an 

appendix to this report. In its response, FAA concurred with recommendations 1, 

2, 7, 8, 9, and 10; partially concurred with recommendations 3, 4, and 5; and did 

not concur with recommendation 6. 

FAA’s planned actions for recommendations 1, 2, 7, 9, and 10, were responsive 

and included reasonable timeframes.

For recommendation 3, FAA noted that it will provide all FAA airport inspectors 

wildlife damage and mitigation training instead of staffing each FAA region with 

an inspector with expertise in wildlife damage management. FAA’s proposed 

alternative approach meets the intent of our recommendation. However, this 

recommendation will remain open pending receipt of the following 

documentation:

x timeline to implement the wildlife training,

x wildlife training curriculum outlining the training plan for FAA inspectors to 

assess the adequacy and effectiveness of the wildlife hazard assessments and 

management plans, and

x guidance and procedures for FAA inspectors to track the status of the review 

and approval process of the wildlife hazard assessments and management

plans.

For recommendations 4, 5, and 6, FAA respectively noted that it will add language 

in AC 150/5200-33B to require airport operators to keep records of wildlife 

strikes, conduct outreach and training with the aviation community to ensure key 

data fields are entered into the strike database, and urge national reporting of 

wildlife strikes. In addition, FAA will continue to perform spot checks of airports’ 

strike records during annual inspections. While these initiatives will likely 

encourage more strike reporting, they do not ensure that the strike database will be

complete (i.e., key data fields are populated such as species of wildlife and phase 

of flight). Furthermore, with FAA’s agreement to develop a performance metric, it 

is even more critical that FAA improves the quantity and quality of its wildlife 
15

strike data. Renowned wildlife biologist and author of FAA-commissioned study 

on wildlife strike reporting,

23 Dr. Richard Dolbeer, noted that a performance 

metric requires more complete data (i.e., populating key data fields). The manager 

of FAA’s Airport Safety and Operations Division is quoted as saying “Wildlife 

strikes are probably the most pressing issue we face in the airports world,” and 

observed that the lack of good data is one of the biggest challenges that wildlife 

managers at airports face.24

For recommendation 8, FAA suggested we close this recommendation because it 

is conducting annual meetings and coordinating with appropriate Federal and State 

agencies during environmental assessments of airport projects. With the exception 

of USDA, we found that 15 of the 16 local district offices (FWS, USACE, and 

EPA) did not annually meet with FAA to discuss the Memorandum of Agreement, 

permitting issues, and any projects or activities that may attract wildlife at or near 

airports. Accordingly, we request that FAA provide documentation to verify that 

the Agency’s actions meet the intent of this recommendation—specifically that 

FAA is conducting annual outreach meetings with other agencies to discuss the 

Memorandum of Agreement, permitting issues, and any projects or activities that 

may attract wildlife at or near airports.

In our opinion, FAA is missing an opportunity to fully 

address one of its biggest challenges by not meeting the full intent of these 

recommendations. Accordingly, we request that the Agency reconsider its 

position.

ACTION REQUIRED

We consider recommendations 1, 2, 7, 9, and 10 resolved but open pending the 

completion of the actions planned. We also consider recommendations 3 and 8 

resolved but open pending receipt of supporting documentation of FAA’s actions 

taken. For recommendations 4, 5, and 6, we request that FAA reconsider its 

position. In accordance with Department of Transportation Order 8000.1C, we 

request that FAA provide us this additional information within 30 days.

We appreciate the courtesies and cooperation of FAA staff during this audit. If you 

have any questions concerning this report, please contact me at (202) 366-0500 or 

Scott Macey, Program Director, at (415) 744-3090.

#

cc: DOT Audit Liaison, M-1

FAA Audit Liaison, AAE-100 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 23 DOT/FAA/AR-09/65, Trends in Wildlife Strike Reporting, Part 1—Voluntary System 1990-2008, December 2009. 24 FAA Safety Briefing, “Splat: The Story of Snarge, ‘Accidental’ Meetings Between Airplanes and Wildlife,” 

November/December 2011.
16

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted this audit in accordance with generally accepted Government 

auditing standards between March 2011 and June 2012. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our audit objectives. 

As part of our review, we randomly selected four out of nine FAA regions to visit. 

We randomly selected 40 airports’ programs (10 per region) to review and 

8 airports (2 per region) to visit from a universe of 209 Part 139 airports that had 

wildlife strike reports from CYs 2008 through 2010 in the four randomly selected 

regions.

To evaluate the effectiveness of FAA’s Wildlife Hazard Mitigation Program, we: 

x Analyzed FAA’s current polices, guidance, and processes.

x Interviewed FAA officials responsible for Program oversight and enforcement 

at Headquarters and selected regions.

x Reviewed FAA records of inspection and enforcement activities for selected 

airports.

x Interviewed airport personnel responsible for wildlife management at selected 

airports. 

x Reviewed wildlife hazard assessments, management plans, training records, 

permits, annual evaluations, and strike records at selected airports. 

x Analyzed 2010 strike reports in FAA’s National Wildlife Strike Database for 

selected airports.

x Interviewed representatives from other government agencies (USDA WS, 

FWS, USACE, and EPA) at 27 Headquarters and local district offices. We 

also interviewed representatives from National Transportation Safety Board, 

National Wildlife Research Center, Smithsonian Feather Identification Lab, 

Embry-Riddle Aeronautical University, and trade associations.

Exhibit B lists 64 organizations we visited, contacted, and/or reviewed.
17

Exhibit B. Organizations Visited, Contacted, and/or Reviewed

EXHIBIT B. ORGANIZATIONS VISITED, CONTACTED, AND/OR

REVIEWED

FAA

Airport Safety & Standards

Airport Planning and Programming & Airports Financial Assistance

Planning & Environmental Division 

Office of the Chief of Counsel

San Francisco Airport District Office 

FAA Randomly Selected Regions

Western-Pacific Region Airports Division

Southern Region Airports Division

Eastern Region Airports Division

Northwest Mountain Region Airports Division

Randomly Selected Airports

Los Angeles International Airport

San Francisco International Airport

Oakland International Airport

Sacramento International Airport

Tucson International Airport

Monterey Regional Airport

Redding Municipal Airport

Flagstaff Pulliam Airport

Sonoma County Airport

Santa Barbara Municipal Airport

John F. Kennedy International Airport

Ronald Reagan Washington National Airport

Washington Dulles International Airport

Philadelphia International Airport

Baltimore Washington International Airport

Dutchess County Airport

Norfolk International Airport

Stewart International Airport

Syracuse Hancock International Airport

Albany International Airport

Hartsfield-Jackson Atlanta International Airport

Palm Beach International Airport

Tampa International Airport

Southwest International Florida Airport

Memphis International Airport

Savannah/Hilton Head International Airport
18

Exhibit B. Organizations Visited, Contacted, and/or Reviewed

Coastal Carolina Regional Airport

Fayetteville Regional Airport

McGhee Tyson Airport

Wilmington International Airport

Portland International Airport

Seattle-Tacoma International Airport

Salt Lake City International Airport

Denver International Airport

Durango La Plata Airport

Rogue Valley International-Medford Airport

Fort Collins Airport

Aspen/Pitkin County Airport

Missoula International Airport

Tri-Cities Airport (Washington)

NTSB

Office of Safety Recommendation & Advocacy

Investigations

Government Affairs

Government Agencies

USDA Office of the Inspector General

U.S. Department of Agriculture, Animal and Plant Health Inspection Service 

U.S. Fish and Wildlife Service 

U.S. Army Corps of Engineers 

Environmental Protection Agency

Smithsonian Feather Identification Lab

Trade Associations

Airlines for America

Airports Council International 

Air Line Pilots Association 

National Air Traffic Controllers Association

Stakeholders

USDA National Wildlife Research Center

Embry-Riddle Aeronautical University
19

Exhibit C. FAA’s Eastern Region Wildlife Program Initiatives Put Forth Following 

the Miracle on the Hudson

EXHIBIT C. FAA’S EASTERN REGION WILDLIFE PROGRAM 

INITIATIVES PUT FORTH FOLLOWING THE MIRACLE ON THE 

HUDSON

In 2009, following the “Miracle on the Hudson” accident, FAA’s Eastern region 

was the only region (out of four) in our review that revamped its wildlife program 

by implementing the following initiatives to improve oversight and enforcement of 

airports’ compliance with Program regulations, policies, and guidance:

x Hired an airport inspector with wildlife biologist qualifications in September 

2009 to oversee the program and review all airports’ assessments and plans.

x Developed a process to monitor wildlife strikes and if needed, require airports 

to obtain a wildlife biologist to conduct a site visit to reassess their plans. 

x Drafted and issued additional guidance to airports to ensure airports were 

adequately evaluating the effectiveness of their plans. 

x Conducted airport risk analyses and initiated a plan to target greater oversight 

and enforcement of airports with the highest strike risk based on the number 

of passenger enplanements, flight operations, and damaging strike rates.

x Levied enforcement actions to ensure airports complied with regulatory 

requirements and conducted annual evaluation of plans.

x Established a notification procedure with USACE districts to identify 

proposed wetland projects that could increase wildlife hazards at airports.

The other three regions in our review did not follow Eastern region’s footsteps by 

incorporating any of these initiatives in their program management. 

In addition, having a wildlife biologist on staff has significantly improved Eastern 

region’s quality of assessment and plan reviews. For example, in the Eastern 

region we found numerous correspondences between FAA biologist and the 

airports requiring changes in monitoring and mitigation strategies to fully address 

current wildlife hazards. Additionally, we found 14 enforcement actions 

identifying 20 program problems related to annual evaluations of the plans, 

training of airport personnel involved in wildlife hazard management, increasing 

wildlife management personnel, and revising and updating the plans. These 

correspondences and enforcement actions supported a critical and comprehensive 

review of airports’ plans beyond the minimum regulatory requirements and a 

proactive oversight and enforcement of program effectiveness.
20

Exhibit D. Major Contributors to This Report

EXHIBIT D. MAJOR CONTRIBUTORS TO THIS REPORT 

Name Title 

Scott Macey Program Director 

Kim P. Tieu Project Manager 

Amitra Mamdouhi Team Leader

Joyce Koivunen Team Leader 

Alfredo Atregenio Auditor

Thomas Shanahan Analyst 

Petra Swartzlander Senior Statistician

Megha Joshipura Statistician

Andrea Nossaman Senior Writer

Audre Azuolas Writer-Editor
APPENDIX. AGENCY COMMENTS

Appendix. Agency Comments

21

Federal Aviation

Administration

Memorandum

Date: July 30, 2012

To: Jeffrey B. Guzzetti, Director, Assistant Inspector General for Aviation

and Special Program Audits

From: H. Clayton Foushee, Director of Audit and Evaluation, AAE-1

Subject: FAA Response to the Office of Inspector General (OIG) Draft Report on 

Wildlife Hazard Mitigation Program

FAA has devoted considerable effort to improving the outcomes from its work with 

airports and the aviation industry to reduce wildlife related hazards to aviation, which is 

an important component of airport safety management systems. It has achieved results as 

demonstrated in key measures of effectiveness. Specifically, while wildlife strikes have 

increased, as described in the OIG draft report, the percentage of significant strikes, in 

which multiple strikes occur simultaneously or in which an air carrier experiences a 

damaging collisions has decreased markedly, from 20 percent of total reported strikes in 

1990, to 9 percent in 2010. This improvement has occurred thanks to the combined 

efforts of FAA, wildlife experts, airports, and the increased availability of information 

and forums for exchanging information on effective mitigation actions.

Risk factors involved with wildlife strikes have grown markedly over the time period 

covered by the report due to growing encroachment into natural habitats and significant 

growth in wildlife populations. For example, the North American non-migratory Canada 

Goose population increased about 4 fold from 1 million birds in 1990 to over 3.5 million 

in 2011. Success stories in the Nation’s environmental stewardship can also have 

unintended consequences, at times affecting the hazard levels. For example, about 90 

percent of all bird strikes in the U.S. are by species federally protected under the 

Migratory Bird Treaty Act. The FAA is working hard with its aviation industry partners 

to identify effective and creative means to reduce the threat of wildlife strikes to aviation 

safety

FAA is taking a comprehensive approach to reduce the threat of wildlife strikes on 

aircraft through enhanced requirements and guidance, training, outreach, and continued 
Appendix. Agency Comments

22

data collection, analysis and research. The following highlights FAA efforts and 

accomplishments in each of these areas.

FAA Providing Enhanced Requirements and Guidance

FAA is developing a Notice of Proposed Rulemaking that includes broader requirements 

for airports to conduct wildlife hazard assessments regardless of whether they have 

experienced “triggering” events. To encourage airports to not wait for a rule change, 

FAA issued a Certification Alert on June 11, 2009 reminding airports of the increasing 

risk from bird strikes. This alert advised airports to be proactive and conduct a wildlife 

hazard assessment so that the nature and extent of any wildlife hazards to aircraft 

operations at a particular airport are fully understood. Finally, the Certification Alert 

stated that the FAA would make AIP funds available to assist with the wildlife hazard 

assessment. This initiative recognizes that wildlife risks impact general aviation airports 

as well as commercial service airports.

FAA is also working to ensure that airports understand the types of qualifications needed 

to conduct credible wildlife assessments. On January 31, 2012, FAA published an 

updated Advisory Circular (AC) 150/5200-36A, Qualifications for Wildlife Biologist 

Conducting Wildlife Hazard Assessments and Training Curriculums for Airport 

Personnel Involved in Controlling Wildlife Hazards on Airports. This AC clarifies 

qualification requirements of wildlife biologists who can do wildlife hazard assessments 

or mitigation plans.

FAA Enhanced Wildlife Hazard Mitigation Training

FAA has enhanced the training requirements for airport certification and inspection 

specialists to include a focus on wildlife hazard mitigation. Specifically, annual recurrent 

certification training for FAA airport certification safety inspectors must include wildlife 

hazard training. FAA is further augmenting the training with more specialized and in 

depth training for each region. For example, FAA conducted a two day wildlife training 

course for regional staff from the New England, Eastern and Southern Regions. 

Attendance included the regional airport inspectors and program managers. Training was 

focused on improving the capability for reviewing Wildlife Hazard Assessments or a 

Wildlife Hazard Management Plan. The FAA is planning additional training sessions for 

the remaining regions and will make this training mandatory for all the regional staff with 

responsibility for reviewing the airport assessments and mitigation plans.

FAA Outreach is Regional, National and International 

FAA is constantly working to raise awareness and build relationships with all the 

stakeholders to address the aviation safety hazards posed by wildlife. FAA routinely 

conducts outreach sessions at numerous national and state airport conferences and other 

aviation events nationwide to encourage bird strike reporting. The agency has also met 

with aviation associations including the American Association of Airport Executives, 

Airports Council International North America, the National Association of State Aviation 
Appendix. Agency Comments

23

Officials, and the Airline Pilots Association to brief them on the importance of their 

members reporting bird strikes. Internally, wildlife hazard mitigation experts have met 

with Commercial Aviation Safety Team (CAST) on the agency’s program for wildlife 

hazard mitigation and the need to increase strike reporting. Wildlife hazard mitigation is 

now routinely on the CAST meeting agenda.

FAA does have established processes for working with other government entities to 

review proposed projects near or on airports that might be wildlife attractants, including 

proposed landfills, expansion of wetlands, or other reclamation projects. FAA’s two 

headquarters’ wildlife biologists are available to provide expert advice to the regional 

personnel reviewing the projects. FAA also has a close working relationship with the 

U.S. Department of Agriculture’s Wildlife Services that has a large number of wildlife 

biologists that FAA can and does call upon for expert analysis.

FAA has also established relationships with domestic and international stakeholder 

organizations intended to help focus outreach and address wildlife hazard mitigation. For 

example, FAA signed a Memorandum of Understanding (MOU) with the Bird Strike 

Committee USA (BSC-USA) to improve cooperation with the FAA. The BSC-USA is 

comprised of wildlife biologists and other experts concerned about mitigating wildlife 

hazards to aviation. The MOU formalizes the FAA relation with the committee and 

allows the agency to draw upon the committee’s expertise to improve the wildlife 

program. Internationally, FAA initiated a program in coordination with the International 

Air Transport Association, International Civil Aviation Organization, and Latin 

American and Caribbean Air Transport Association to conduct wildlife hazard 

assessments at key airports in Latin America. These airports are served by U.S. carriers 

and visited by U.S. travelers. The first assessments were conducted in June 2012 in 

Panama and Ecuador.

Data, Analysis, and Research Will Further Improve Aviation Safety

FAA is conducting varied data gathering and analytical activities that will better inform 

mitigation efforts and help to identify creative and useful actions that will further mitigate 

wildlife hazards. In order to improve the availability of bird strike data, FAA updated the 

national wildlife strike database and made it available to the public. Additionally, the 

FAA has developed software to allow for the easy reporting of bird strikes via smart 

phones and has published and distributed wildlife posters for posting in pilot lounges and 

related airport facilities nationwide to encourage bird strike reporting. FAA is also 

continuing its funding of the Smithsonian Institution’s Feather Identification Lab to 

identify bird species from remains collected from bird strikes. Airports can mail remains 

to the lab and receive notice of bird species identification at no cost. Knowing the bird 

species involved in bird strikes helps airports improve their wildlife mitigation activities

FAA recently published two reports through the FAA sponsored Airport Cooperative 

Research Program (A Guidebook for Addressing Aircraft/Wildlife Hazards at General 

Aviation Airports and Bird Harassment, Repellent, and Deterrent Techniques for Use On 

and Near Airports) to help general aviation airports manage wildlife hazards. These 
Appendix. Agency Comments

24

reports were distributed to general aviation airports nationwide and provided airport 

managers with practical guidance to manage wildlife risks. 

FAA has also made considerable progress in the area of using radar to potentially provide 

real time warning systems for pilots about bird activity at or near an airport. FAA has 

already evaluated commercially available bird radar systems and published AC 

150/5220-25, Airport Avian Radar Systems, on November 23, 2010. This AC provides 

bird radar performance specifications that airports may use to competitively procure bird 

radars to help manage their wildlife mitigation programs by tracking daily and seasonal 

bird migration movements and identifying roosting areas. In addition, the FAA 

determined bird radar systems to be eligible for AIP funding. This determination also 

established several associated requirements, including that the airport must have a 

complete and approved wildlife hazard management plan and an ongoing bird harassment 

plan in place, along with provisions in the Airport Certification Manual (for airports 

certificated under title 14 CFR, part 139) to operate and maintain the system, as well as 

requirements to analyze the incoming data, tracking the data, and acting on the data 

trends. While these systems may be useful for some airports, FAA has initiated new bird 

radar research intended to evaluate the feasibility of using bird radar in the air traffic 

control tower. 

Independent Confirmation of Voluntary Bird Strike Reporting 

FAA has obtained independent confirmation that voluntary bird strike reporting provides 

a sufficient data set for determining national trends and hazard levels. The National 

Transportation Safety Board (NTSB) recommended mandatory strike reporting in issuing 

Recommendation A-09-75 after investigating the fatal accident in which a Cessna 500 

crashed after hitting a flock of large birds after takeoff from Wiley Post Airport in 

Oklahoma on March 4, 2008. The agency provided a detailed formal response to NTSB 

Recommendation A-09-75 on December 23, 2009, based upon an FAA-funded study of 

bird strike data and trends conducted by Dr. Richard Dolbeer, an internationally 

recognized authority on the subject. The FAA also met with the NTSB on March 10, 

2010 to discuss the agency’s response to the recommendation. 

The Dolbeer study concluded that the current level of voluntary strike reporting is 

sufficient for determining national aircraft strike trends, determining the hazard level of 

wildlife species involved in aircraft strikes, and for providing a scientific foundation for 

FAA policies and guidance regarding the mitigation of risk from wildlife strikes. This 

report can be found at: http://www.airporttech.tc.faa.gov/safety/downloads/09-65.pdf. 

The FAA is also committed to continuing education /outreach programs to encourage 

improved strike reporting. 

The NTSB formally responded to the FAA on May 27, 2010 and concluded that the 

current reporting rates are adequate, based upon their independent analysis of the FAAfunded study. Further, the NTSB determined that the conduct of this study, in 

conjunction with the FAA outreach/education programs for targeted segments of the 

aviation community, constituted an acceptable alternate response to the recommendation. 
Appendix. Agency Comments

25

NTSB categorized the FAA response to recommendation A-09-75 for mandatory strike 

reporting as, “Open -- Acceptable Alternate Response,” (attachment 1). Given the 

adequacy of the current wildlife strike database, the FAA cannot justify a rule-making 

project requiring mandatory reporting.

Overall, the challenges facing aviation with regard to wildlife hazard mitigation, requires 

creative approaches. These may vary from location to location, encompassing unique 

challenges associated with individual airports, and focus on the need for aviation safety, 

while simultaneously respecting the many species with which we share this planet. 

While the OIG report focuses on matters relating to consistency and records 

management, it is important to recognize the unique challenges faced by individual 

airports and work with them to identify the creative approaches that will enable FAA and 

the airports to effectively contend with these challenges.

RECOMMENDATIONS AND RESPONSES

Recommendation 1: Require FAA airport inspectors to adhere to Order 5280.5C, 

Airport Certification Program Handbook, specifically to:

a. Verify that airports are fully implementing and evaluating their wildlife hazard 

management plans and document the basis for compliance determinations with each 

inspection checklist item and the records reviewed for verification, as well as 

documenting airports’ noncompliance with regulations, policies, and guidance and 

actions airports took to correct them; and

b. Verify airports had obtained timely permits to effectively implement their wildlife 

hazard management plans.

FAA Response: Concur. The FAA agrees that airport inspectors could improve upon 

the wildlife hazard portion of the annual airport safety inspections, and the agency will 

address these areas in all training sessions on wildlife and airport inspections. 

Typically, inspectors sample the airport’s documentation and records. If they do not find 

discrepancies or reasons to increase the sample size, inspectors can determine that the 

airport is in compliance for that particular section of Part 139. Inspectors do not 

document reasons for compliance in each area, but do compile documentation to support 

findings of noncompliance. 

The FAA agrees that airport inspectors should verify that airports have obtained timely 

permits to effectively implement their wildlife hazard management plans and will include 

this requirement in the wildlife checklists that are being developed for airport inspectors 

by November 30, 2012.

Recommendation 2: Establish procedures to verify that airports check biologist 

qualifications prior to airports hiring them to conduct wildlife hazard assessment.
Appendix. Agency Comments

26

FAA Response: Concur. On January 31, 2012, the FAA issued AC 150/5200-36A that 

lists in detail the minimum qualifications of wildlife biologists to conduct and prepare 

airport wildlife hazard assessments and management plans. It is the responsibility of 

airports to obtain sufficient evidence during the proposal process, demonstrating that the 

selected biologists meets the qualification requirements provided for in the AC. The 

FAA will issue formal guidance by January 31, 2013 that requires airport operators to 

maintain documentation on the qualifications of biologists retained for the conduct of 

wildlife assessments and mitigation plans. These records must be made available for 

airport inspector review during the annual inspection. 

Recommendation 3: As regional airport inspector vacancies become available, staff 

those positions with inspectors with expertise in wildlife damage management and 

require those inspectors who oversee the programs to specifically:

a. Review and approve wildlife hazard assessments and management plans;

b. Track the review and approval process to ensure airports complete all requirements; 

and,

c. Monitor and wildlife strikes and, if needed, require airports to reassess their wildlife 

hazard management plans.

FAA Response: Concur in part. The FAA hires airport inspectors based upon the 

necessary expertise in a number of core airport safety areas, and wildlife experience is 

just one of many requisite skillsets. However, the agency intends to provide wildlife 

damage and mitigation training to all airport inspectors, which will adequately qualify 

them to oversee these programs. 

All airport inspectors are capable of tracking the review and approval process, and they 

are also capable of checking the national bird strike database, which is standard 

procedure prior to conducting an annual airport safety inspection. In addition, if regional 

airport oversight personnel encounter a particularly complex wildlife hazard issue, they 

can, and routinely do, request assistance from the staff biologist at FAA headquarters or 

from the Department of Agriculture Wildlife Services biologists.

Recommendation 4: Require that airports, as part of their wildlife hazard management 

plans, maintain reports of all wildlife strikes and submit the reports quarterly to FAA for 

review.

FAA Response: Concur in part. The FAA will add language in the upcoming revision 

of AC 150/5200-33B, “Hazardous Wildlife Attractants on or Near Airports,” by 

November 2012 that will require airport operators to keep records of wildlife strikes. The 

records will be provided for the FAA inspectors’ reviews during the annual airport 

inspections. This is consistent with how the FAA reviews other airport records, such as 

training records for firefighters. Therefore, the FAA does not believe that requiring 

airports to submit quarterly wildlife strike reports to FAA is necessary.
Appendix. Agency Comments

27

Recommendation 5: Require inspectors to verify airports’ quarterly wildlife strike 

reports contain key data fields, such as extent of damage, species of bird, phase of flight, 

altitude that the strike occurred, and effect on flight; and to contact the airports with any 

incomplete or missing data to obtain the information, if available.

FAA Response: Concur in part. While FAA agrees that data accuracy is important, as 

discussed in response to the prior recommendation, FAA does not believe that creating 

and enforcing a quarterly reporting requirement is an effective or efficient use of 

resources. FAA would prefer to use its resources addressing the issues directly rather 

than creating new paperwork requirements for its inspection workforce. Instead, FAA 

will address issues relating to missing data fields in strike reports through outreach and 

training through continuing interactions with the aviation community at national and state 

conferences

Recommendation 6: Reconcile the airports’ quarterly reports with FAA’s National 

Wildlife Strike Data Base and ensure any missing strikes are entered into the database.

FAA Response: Non-concur. FAA does not agree that quarterly reporting and 

reconciliation is effective or efficient. FAA inspectors will continue to spot check airport 

strike records during its annual inspection and compare them to strikes reported in FAA’s 

National Wildlife Strike database and encourage airports to correct any missing reports. 

However, creating a records reconciliation requirement is not based on any apparent 

analysis of cost, benefit, or assessment of relative priority for reducing wildlife risk 

mitigation. FAA will also continue to urge local tracking and national reporting.

Recommendation 7: Develop and implement performance metrics to measure the 

effectiveness of FAA’s target activities in achieving the Program goal of reducing 

wildlife hazards at or near airports.

FAA Response: Concur. The FAA is developing additional metrics to monitor the 

efficacy of its wildlife program that include the number of wildlife hazard assessments 

initiated and the ratio between the numbers of strikes with significant damage compared 

to total reported strikes. This measure differs from the total number of strikes reported 

and is a better indicator of the operational significance of the problem. The agency’s 

improved metrics will be presented in the “Wildlife Strikes to Civil Aircraft in the United 

States 1990 to 2011” report to be published by October 30, 2012. 

Recommendation 8: At a minimum, conduct annual outreach meetings with other 

Government agencies to discuss the Memorandum of Agreement, permitting issues, and 

any projects or activities that may attract wildlife at or near airports.

FAA Response: Concur. The FAA conducts annual meetings and coordinates with 

appropriate Federal and state agencies during environmental assessments of airport 

projects, to include consideration of wetlands and other potential wildlife attractants. 

Accordingly, the FAA requests that this recommendation be closed.
Appendix. Agency Comments

28

Recommendation 9: Establish notification procedures with other government agencies 

to notify FAA of project proposals that may increase hazardous wildlife populations 

within a 5-mile radius of airports.

FAA Response: Concur. The FAA already has a notification process and does receive 

notification of many projects from other government agencies that may impact wildlife 

hazards to airports. The FAA will review the notification process to determine if it can 

be improved. This review will be completed by January 31, 2013.

Recommendation 10: Develop and implement procedures to coordinate with State and 

local agencies to assist airports with permitting issues.

FAA Response: Concur. The FAA will develop and implement procedures to assist 

airport sponsors to facilitate timely issuance of permits. FAA will issue this guidance by 

January 30, 2013. 
Appendix. Agency Comments

29

Attachment 1

Safety Recommendation History for A-09-075 FAA 

Response Date:

12/23/2009 

From:

Addressee 

Response:

Letter Mail Controlled 1/7/2010 3:59:43 PM MC# 2100009: - From J. Randolph 

Babbitt, Administrator: The FAA agrees with the benefit of increased reporting, 

and after the US Airways Flight 1549 incident that resulted in the emergency 

landing in the Hudson River, FAA initiated a review of its National Wildlife 

database. We improved the usability of the bird-strike Web site, made it more 

user friendly, and made it publically available. We also initiated a research study 

to determine the current level of strike reporting and whether that level of 

reporting was sufficient to determine strike trends and develop national policy. A 

study was conducted and we have enclosed a draft copy for your information. Dr. 

Richard Dolbeer found through the study, that strike reporting has increased 

significantly from his well-publicized level of 20 percent, that had been 

documented in a few limited studies from the 1990s. His current analysis 

indicates that 39 percent of actual wildlife strikes are reported at part 139 

airports. The data also verifies stabilization in reporting damaging strikes since 

2000. We believe this important trend is a result of the increased data that is 

being used by biologists involved with more professionally run wildlife hazard 

programs at part 139 airports. Dr. Dolbeer also concludes that this level of strike 

reporting (39 percent) is sufficient to analyze national strike trends and develop 

national wildlife hazard mitigation policies, which is one of the main purposes of 

having a national strike database. We believe the current level of reporting of 39 

percent is statistically valid and sufficient to analyze strike trends and develop 

national mitigation policies. Accordingly, we do not believe it is necessary to 

impose mandatory strike reporting. Although the overall level of reporting is 

adequate, there are areas where improvements in strike reporting can be 

achieved (i.e., NIPIAS/ GA airports, part 139 airports, and air carriers). The FAA 

has initiated measures to increase strike reporting by: Improved 

education/outreach with the National Associate of State Aviation Officials, Aircraft 

Owners and Pilots Association, Airport Council International-North America, Air 

Transport Association of America, National Business Aviation Association, Inc., 

American Association of Airport Executives, air carriers, part 139 airports, and 

NPIAS/GA airports; and Expanding and improving procedures to transfer data 

from FAA and industry databases to the national database. 

Response Date:

5/27/2010 

From:

NTSB 

Response:

On March 10, 2010, staff from the FAA and the NTSB met to discuss this 

recommendation in detail. An FAA-funded study, performed by Dr. Richard 

Dolbeer, evaluated whether the current level of strike reporting in the NWSD was 

sufficient for determining strike trends and developing national mitigation policy. 

The study concluded that the current level of reporting, which is higher than the 

level the NTSB found, is sufficient; therefore, the FAA does not plan to take the 

action recommended. However, based on Dr. Dolbeer’s recent study, the FAA 

plans to make improvements to reporting through an education/outreach program 

with a number of aviation organizations. This recommendation was based on the

findings of an earlier study by Dr. Dolbeer; in his more recent study, Dr. Dolbeer 

evaluated whether the reporting problems identified in his earlier study continued 

to limit the applicability of the NWSD. The fact that Dr. Dolbeer himself concluded 

that current reporting rates are adequate is significant. The conduct of this study, 

in combination with the outreach/education program for targeted segments of the 

aviation community, constitutes an acceptable alternative response to this 

recommendation. Accordingly, pending improvements in wildlife strike reporting 

by the segments of the aviation community identified by the FAA, Safety 

Recommendation A-09-75 is classified OPEN -- ACCEPTABLE ALTERNATE 

RESPONSE.