ACTIONS TAKEN AND NEEDED TO IMPROVE 

FAA’S RUNWAY SAFETY AREA PROGRAM 

Federal Aviation Administration 

Report Number: AV-2009-039 

Date Issued: March 3, 2009 
U.S. Department of 

 Memorandum

Transportation 

Office of the Secretary 

of Transportation 

Office of Inspector General 

Subject: ACTION: Actions Taken and Needed To 

Improve FAA’s Runway Safety Area Program 

Federal Aviation Administration 

Report Number AV-2009-039 

Date: March 3, 2009 

From: Lou E. Dixon 

Assistant Inspector General for Aviation 

 and Special Program Audits 

Reply to 

Attn. of: JA-10 

To: Acting Federal Aviation Administrator 

This report presents the results of our audit of the Federal Aviation 

Administration’s (FAA) Runway Safety Area (RSA) program. An RSA is a 

rectangular space around a runway that provides critical safety margins for landing 

and departing aircraft, thereby helping to minimize the risk to aircraft and 

passengers from flights that undershoot, overrun, or veer off a runway. 

Over the last 10 years, 75 aircraft have overrun or veered off the Nation’s 

runways, resulting in nearly 200 injuries and 12 fatalities. In February 2005, 

14 people were injured after an aircraft overran a runway at Teterboro Airport in 

New Jersey. Ten months later, another aircraft skidded off a runway while 

landing in icy conditions at Chicago’s Midway Airport. The aircraft finally 

stopped in a public street—killing 1 person and injuring 4 persons in a car and 

another 18 on board the aircraft. In November 2005, Congress, in consultation 

with FAA, mandated that all Part 139 airport1

 sponsors enhance passenger safety 

by improving their RSAs by 2015 and that FAA report annually on its progress 

toward improving RSAs. 

Our audit objectives were to (1) assess airport sponsors’ and FAA’s progress and 

challenges, if any, in fulfilling the congressional RSA mandate and (2) evaluate 

the effectiveness of FAA’s process for identifying, prioritizing, and funding 

needed RSA improvements. We conducted the audit from November 2007 

through November 2008 in accordance with generally accepted Government

 

1

 “Part 139” airports conduct commercial passenger flight operations and must comply with standards contained in 

14 CFR § 139 (2005). 
2

Auditing Standards prescribed by the Comptroller General of the United States. 

Exhibit A details our audit scope and methodology, and exhibit B lists the sites 

visited or contacted. 

BACKGROUND 

To reduce the risks associated with aircraft undershooting, overrunning, or veering 

off runways, in 1988, FAA established the current standards for RSAs.2

 

According to these standards, RSAs must be cleared, drained, and capable of 

supporting the weight of commercial aircraft. They must also meet dimensional 

requirements, typically 1,000 feet by 500 feet at each runway end and 250 feet 

from the runway centerline (see figure 1). 

Figure 1. RSA Dimensional Standards 

1,000 feet 

250 feet

10

500 feet

28

RSA Surrounding a Runway 

If an RSA cannot meet dimensional standards, FAA allows airport sponsors to 

improve RSAs through alternative means, such as declared distances (i.e., 

declaring the usable runway length to be less than the actual runway length) or an 

Engineered Material Arresting System (EMAS).3

 Moreover, if improving an RSA 

costs more than an equivalent EMAS installation,4

 FAA may declare the RSA 

impracticable to improve. In such cases, FAA works with the airport sponsor to 

improve the RSA as much as possible (e.g., installing a partial EMAS). However, 

in about 2 percent of cases, improvements are so expensive that FAA does not 

require any further action. 

In addition, RSAs must be free of objects, such as approach lighting systems 

(ALS), instrument landing systems (ILS), and other navigational aids (NAVAIDs), 

unless these objects need to be in the RSA to operate properly. If objects cannot 

be removed from the RSA, they must be frangible (i.e., designed to break away 

when hit by a plane) at a height of 3 inches or less from the ground. 

 

2

 14 CFR I39.309 “Safety Areas.” 

3

 An EMAS is comprised of porous concrete that can absorb the weight of an aircraft, allowing it to slow or stop. 

According to FAA, a 600-foot EMAS is equivalent to a 1,000-foot RSA. 4

 According to FAA, the maximum improvement costs range between $7 million and $33 million depending on 

aircraft size and local construction costs. 
 3

After a fatal 1999 crash at Little Rock Airport in Arkansas, in which an aircraft 

overran the runway while attempting to land in bad weather, FAA established the 

RSA Program to identify and address RSAs needing improvement. The program 

allowed those improvements to begin at any time, rather than wait until a major 

runway project was initiated. At that time, FAA identified a universe of 

1,024 RSAs needing improvement at commercial service airports and designated 

317 of these as priorities because they posed the greatest risk to passengers during 

an overrun accident. The number of priority RSAs increased to 454 by 2008 due 

to new technology and policy changes. FAA also developed a schedule to upgrade 

these priority RSAs by the 2015 congressional deadline. Despite this effort, after 

an overrun at Burbank Airport in California, the National Transportation Safety 

Board (NTSB) recommended in 2003 that FAA require all Part 139 airports to 

upgrade RSAs that could, with feasible improvement, be made to meet standards. 

FAA and airport sponsor efforts to improve RSAs have resulted in tangible 

aviation safety enhancements across the Nation. For example, RSA improvements 

helped prevent significant damage and injuries during a June 2007 runway overrun 

at Santa Barbara Municipal Airport in California. In addition, EMAS have proved 

effective in stopping aircraft during several overrun incidents since 1999, 

including three at John F. Kennedy International and one at Chicago O’Hare 

International. 

RESULTS IN BRIEF 

Overall, we found that FAA and airport sponsors have made significant progress 

since 2000—with the Agency reporting that 327 of 454 priority RSAs (more than 

70 percent) have been improved. Nevertheless, challenges still remain in bringing 

the remaining RSAs up to standards, especially at 11 of the 30 largest airports.5

 

These 11 airports handle over one-fourth of the Nation’s passenger traffic and face 

major man-made, natural, environmental, and legal challenges that may prevent 

them from achieving needed RSA improvements by the 2015 congressional 

deadline. 

We also found that FAA was generally effective in identifying, prioritizing, and 

funding needed RSA improvements, with two major exceptions: NAVAIDs and 

data quality. Specifically, non-compliant NAVAIDs, some of which pose 

significant safety risks, remained in over 40 percent (67 of 163) of the RSAs we 

reviewed. Moreover, inaccurate, incomplete, or outdated data have hampered 

FAA’s ability to track and report on RSA improvements. In particular, FAA’s 

annual report to Congress, which was based on these data, was too general and did 

not provide sufficient detail for decision makers. The report also overstated the 

 

5

 FAA defines large hub airports as those airports that each account for at least 1 percent of all U.S. passenger 

enplanements. 
 4

number of RSAs meeting full standards, especially those RSAs containing noncompliant NAVAIDs. 

Until these challenges and problems are addressed, aircraft will remain vulnerable 

to damage and, more importantly, their passengers remain at risk of potential 

injury from flights that undershoot, overrun, or veer off a runway lacking a 

standard RSA. 

RSAs at 11 of the Nation’s 30 Largest Airports Face Major Challenges 

in Achieving Needed Improvements 

Man-made, natural, environmental, and 

legal challenges have delayed efforts to 

make needed RSA improvements at 

11 of the Nation’s largest airports (see 

exhibit C for a list of these airports and 

existing constraints). While FAA 

provides guidance, funding, and 

oversight for RSA improvements, the 

airport sponsor has substantial 

discretion in determining what actions 

to take and when to take them. 

Figure 2. RSA Obstacles at 

Reagan National Airport 

120 ft. to Parkway

170 ft. to Potomac River

Superfund Site

Environmental 

Clean-Up Site

Superfund Site

Environmental 

Clean-Up Site

Source: Google and OIG

For example, RSA improvements at 

Reagan National Airport in Washington 

D.C. (see figure 2) are hindered by the 

George Washington Parkway, the 

Potomac River, and an environmental 

clean-up site. 

The airport sponsor has conducted 

multiple studies over 26 years on how 

to bring this airport’s three RSAs up to 

standards and has considered options such as installing a partial EMAS, 

repositioning one or more runways, reducing the operational runway length, and 

extending one runway into the Potomac River. Although FAA supports the use of 

EMAS, the airport sponsor has been reluctant to select this option due to concerns 

about the impact of periodic flooding on this system. Overall, FAA estimates 

RSA improvements at Reagan National could cost upwards of $109 million. 

Although FAA is working with airport sponsors to bring RSAs up to standards, the 

Agency needs to expedite ongoing efforts to achieve needed improvements. As 

the table below illustrates, there have been at least four serious accidents involving 
 5

overruns since 1999. In each case, 

RSA improvements were made 

after the accidents—improvements 

that could have prevented 

80 injuries and 1 fatality had they 

been completed sooner. As these 

examples demonstrate, critical RSA 

improvements need to be made at 

the 11 large airports sooner rather 

than later to lower the risk of 

passenger injuries and aircraft 

damage in the event of runway 

accidents. 

Table. Examples of Major Runway Accidents 

Involving Non-Standard RSAs

Airport Date Impact 

105 injuries and 

11 fatalities Little Rock National 6/99 

Bob Hope Burbank 

Airport 3/00 44 injuries 

Teterboro Airport 2/05 14 injuries 

22 injuries and 

1 fatality Midway International 12/05 

Source: NTSB

RSAs Contain NAVAIDs That Pose Safety Risks to Aircraft and 

Passengers 

Although FAA has made progress addressing non-compliant NAVAIDs, 67 of 

163 RSAs we reviewed still had NAVAIDs that needed to be relocated or 

modified. To comply with FAA standards, NAVAIDs need to be either relocated 

outside the RSA or made frangible (i.e., breakable) at 3 inches or less above the 

ground. Non-compliant NAVAIDs can contribute to increased aircraft damage 

and potential loss of life. For example, in 1975, an aircraft collided with a nonfrangible ALS at John F. Kennedy International Airport. As a result, 

113 passengers died, and the aircraft was substantially damaged. More recently, 

in 2007, an aircraft overran the runway at Dekalb-Peachtree Airport, striking a 

NAVAID. While there were no fatalities or injuries, there was significant damage 

to the aircraft’s wing (see figure 3 on page 6). 

Non-compliant NAVAIDs remain in RSAs for various reasons, including 

(1) insufficient coordination between FAA’s Office of Airports and its Air Traffic 

Organization (ATO)6

 (2) lack of guidance on the use of new frangible bolts for 

NAVAIDs; (3) inadequate planning regarding NAVAID relocation or 

modification; and (4) Airport Improvement Program (AIP) funding restrictions. 

Combined, these factors have resulted in an inconsistent, disjointed process in 

which some NAVAIDs are corrected, some partially corrected, and some not 

addressed at all. To reduce the safety risks posed to passengers by non-compliant 

NAVAIDs, FAA needs to develop and implement a program for relocating or 

modifying NAVAIDs in RSAs, which should include improved coordination, 

greater use of new frangible bolts, and a funding plan for targeting those 

NAVAIDs posing the greatest safety risk. 

 

6

 The Office of Airports oversees compliance with the RSA standards, and the ATO manages Agency NAVAIDs in 

RSAs. 
 6

Figure 3. Aircraft Damage from Hitting NAVAID 

at Dekalb-Peachtree Airport 

 Source: FAA 

Incorrect, Incomplete, or Outdated Data Limit FAA’s Ability To 

Oversee and Accurately Report RSA Improvements 

We found errors in the Office of Airports 

RSA Inventory (i.e., database), including 

incorrect, missing, or outdated data. Of the 

163 RSAs we reviewed, 64 (38 percent) had 

at least 1 data error (see figure 4 for 

examples). These errors affect FAA’s 

ability not only to oversee the RSA program 

but also to provide accurate and 

comprehensive reports to Congress on the 

status of RSA improvements and future 

funding requirements. 

Such inaccuracies in the RSA Inventory 

occur because the Office of Airports 

(1) does not have sufficient guidance and 

training on how to properly identify, track, 

and report on needed RSA improvements; 

Figure 4. Data Errors in FAA’s 

RSA Inventory 

3⁄4 RSA Inventory states that an RSA 

at Baltimore Washington 

International Airport meets 

standards even though it is less 

than the required 250 feet on 1 side 

of the runway. 

3⁄4 RSA Inventory states that an RSA 

at Dulles International Airport 

meets standards, even though an 

ILS needs to be relocated. 

3⁄4 RSA Inventory states that 

$39 million was needed for a 

major runway and RSA project at 

Los Angeles International Airport 

when it had been completed 1 year 

earlier.
 7

(2) focuses on maintaining RSA dimensional data versus information on 

NAVAIDs; and (3) uses inadequate data verification and validation. 

For example, there is no standard form to document determinations7 to ensure all 

data elements are captured and consistently identified. As a result, every FAA 

region uses varying forms and terminology to complete determination paperwork. 

FAA regions also manually upload their determination data into the national RSA 

Inventory, with no data verification conducted by either the regions or the Office 

of Airports. Thus, the information in the determinations and the RSA Inventory is 

often inconsistent or contradictory. In addition, some of the 327 RSAs reported as 

“improved” may still need to be addressed. Also, as a result of inaccurate data, 

FAA’s annual report to Congress overstates the extent to which RSAs fully meet 

standards, especially those RSAs containing non-compliant NAVAIDs. 

Our recommendations to FAA focus on (1) developing an action plan for 

improving RSAs at 11 large airports to the fullest extent practical; (2) developing 

and implementing an effective program for addressing NAVAIDs located in RSAs 

to ensure their timely removal or modification; (3) issuing detailed guidance and 

conducting training for those responsible for identifying, tracking, and reporting 

on the status of RSAs; (4) implementing quality control procedures to ensure the 

accuracy and integrity of RSA data; and (5) expanding the annual report to 

Congress to better reflect the true status of RSA improvement activities. Our 

complete recommendations are listed on page 18. 

FINDINGS 

Overall, we found that FAA and airport sponsors have made significant progress 

since 2000—with the Agency reporting that 327 of 454 RSAs (more than 

70 percent) have been improved. Nevertheless, various challenges still remain in 

bringing the remaining RSAs up to standards, including 11 of the 30 largest 

airports. Given the large number of passengers these airports serve, it is critical 

that FAA and airport sponsors expedite ongoing efforts to achieve needed 

improvements. 

We also found that FAA was generally effective in identifying, prioritizing, and 

funding needed RSA improvements. For example, FAA has awarded $1.2 billion 

in AIP grants for RSA improvements.8

 Nevertheless, FAA needs to make 

improvements in two significant areas—NAVAIDs and data quality. Specifically, 

 

7

 Determinations are used by FAA field staff to identify and document the status of the RSA and what improvements 

are needed. Determinations include such details as RSA dimensions, grading, slope, and whether NAVAIDs are 

located within the RSA boundaries. 8

 The AIP, which is administered by FAA’s Office of Airports, supports the Nation’s airport system by providing 

funds to enhance safety and security, maintain the infrastructure, increase capacity, and mitigate airport noise in 

surrounding communities. In 2007, the program awarded grants worth more than $3.3 billion to airport sponsors. 
 8

over 40 percent of the RSAs we examined contain NAVAIDs that need to be 

relocated or made frangible. Although FAA has moved or modified some 

NAVAIDs over the last 3 years, many still remain unaddressed—including some 

that pose significant safety risks to aircraft and their passengers. Moreover, 

inaccurate, incomplete, or outdated data have hampered FAA’s ability to track and 

report on RSA improvements. Until such data problems are corrected, it will be 

difficult for FAA to ensure needed improvements are made by the congressional 

deadline of 2015. We also found that FAA’s annual report to Congress, which 

was based on these data, was too general and did not provide sufficient detail for 

congressional decision makers. 

FAA Needs To Expedite RSA Improvements at 11 Large Airports 

Facing Significant Challenges in Meeting Standards 

We identified 11 large airports9

 that face significant challenges to bringing their 

RSAs up to standards, including man-made, natural, and other constraints. These 

challenges, in turn, have significantly delayed efforts to improve RSAs at airports 

such as Reagan National and San Francisco International—in the former case for 

more than 26 years. The challenges also raise questions as to whether the RSAs at 

some of the 11 airports will ever be improved. Yet, as incidents at Burbank, 

Midway, and Teterboro airports have demonstrated, only after serious accidents 

were the resources marshalled and decisions made to achieve needed 

improvements—improvements that could have prevented injuries and saved lives 

if done earlier. While FAA and airport sponsors are working to overcome the 

challenges facing the 11 large airports, it is critical that these efforts be expedited 

to avoid a repeat of the past and ensure the safety of the flying public. 

Past Delays in Improving RSAs Have Resulted in Serious Consequences 

At Burbank, Midway, and Teterboro airports, delays in achieving needed RSA 

improvements have had significant repercussions during overrun accidents. For 

example, in 2000, FAA determined that an RSA at Chicago’s Midway airport was 

impracticable to improve because it would require moving roads and result in 

significant and costly impacts on local neighborhoods. Four years later, the airport 

sponsor estimated that the project’s property acquisition alone would involve 

moving hundreds of commercial and residential buildings and cost between 

$200 million and $300 million. The sponsor also considered installing an EMAS 

but concluded that too little space was available. Then in 2005, an aircraft overran 

the runway at Midway and finally stopped in a public street—killing 1 person and 

injuring 4 persons in a car and another 18 on board the plane. Two years after the 

 

9

 Baltimore-Washington, Boston-Logan, Charlotte-Douglas, Fort Lauderdale/Hollywood, John F. Kennedy, 

LaGuardia, Los Angeles International, Philadelphia International, Phoenix-Sky Harbor, Reagan National, San 

Francisco International. 
 9

accident, the airport sponsor installed a partial EMAS at a cost of $5.8 million.10 

The EMAS manufacturer estimated that this partial solution, if implemented 

earlier, could have prevented the aircraft from skidding into the street. 

Similarly, FAA determined it was impractical to construct a full RSA at Burbank 

and Teterboro airports because of urban development and high improvement costs. 

While both airports had been evaluating improvement options, partial EMAS 

systems were installed only after serious overruns occurred at both airports that 

resulted in a total of 58 injuries. 

Eleven Large Airports Face Serious Challenges in Achieving Needed 

RSA Improvements 

We found that 11 of the 30 largest airports—representing nearly one-fourth of all 

passenger enplanements in 2006—are facing significant challenges to bringing 

one or more RSAs up to standards (see exhibit C for more information on these 

airports). These challenges are man-made, natural, environmental, and legal.11 

While FAA is working with these airports to overcome such challenges, some of 

the needed improvements may take some time to complete. For instance, RSA 

construction projects can be delayed by local lawsuits and community opposition12

as well as environmental reviews, which can take between 2 and 12 years to finish. 

Moreover, projects may be delayed if airport revenue drops or financial partners 

withdraw from airfield improvements. As a result, it may prove difficult for some 

of these airports to make needed improvements by the 2015 congressional 

deadline. 

For example, over the last 26 years, Reagan National Airport has conducted 

various studies on how to overcome significant constraints to improving RSAs. 

Its runways are bordered by the George Washington Parkway, Potomac River, and 

an environmental clean-up site (see figure 5 on page 10). One of the airport’s 

three RSAs (pictured in green), which is affected by the environmental clean-up 

site, is undergoing an FAA-required environmental assessment, which must be 

completed before the RSA improvement can begin. Once the assessment is 

completed later this year, the airport sponsor plans to extend the runway to the 

south and use declared distances13 to fulfill FAA standards. 

 

10 FAA officials note that this system represented an improvement over earlier technology, providing added protection 

from jet blast. 11 Examples of specific challenges are: man-made (highways, railroad tracks, and urban development), natural (bays 

and rivers), environmental (noise restrictions and environmental clean-up sites), and legal (local opposition). 12 For example, improvements to Sikorsky Memorial Airport in Connecticut have been delayed for about 15 years 

because of disagreements between the airport sponsor and a local community, even though the deficient RSA was a 

factor in 1994 and 2001 accidents. 13 To meet FAA’s RSA standards, an airport sponsor can declare the usable operational length of a runway to be less 

than the actual runway length. 
 10

For the second RSA (pictured in red), the 

airport sponsor is examining several 

options, ranging from a partial to full 

EMAS—the latter of which would require 

an extension into the Potomac River. 

Since the cost of either option exceeds 

FAA’s maximum cost figure of 

$18 million for determining practicability 

for this runway, the sponsor and FAA may 

decide to pursue only a partial 

improvement. 

Figure 5. Constrained RSAs at 

Reagan National Airport 

Potomac 

River

George

Was

hingto

n

Parkway

Environmental

Clean-Up Site

Potomac 

River

George

Was

hingto

n

Parkway

Environmental

Clean-Up Site

Figure 6. Constrained RSAs at 

San Francisco Airport 

 Sources: Wikipedia & OIG

 Source: Google & OIG 

For the third RSA (pictured in yellow), 

which is also affected by the 

environmental clean-up site, the airport 

sponsor is considering extending the 

runway, installing a partial or full EMAS, 

or limiting the runway to smaller aircraft. 

While FAA has long supported the use of 

EMAS at Reagan National, airport 

officials have been reluctant to select this 

option due to concerns about the impact of 

seasonal flooding on an EMAS. 

For both the red and yellow RSAs, the sponsor does not plan to make a final 

decision until the environmental review process is completed over the next 

2 years. Yet, depending on what decisions are made, additional environmental 

reviews or legal challenges could cause further delays in completing needed 

improvements. Overall, the airport 

sponsor estimates RSA improvements 

at Reagan National could cost 

upwards of $109 million. 

Similarly, San Francisco International 

Airport faces significant challenges in 

bringing all four of its RSAs up to 

standards. The runways are bordered 

by San Francisco Bay and Highway 

101 (see figure 6). Although the 

airport sponsor is conducting a study 

to determine how best to address the 

airport’s four RSAs, the sponsor 

tentatively plans to use declared 
 11

distances to bring one pair (pictured in yellow) up to standards. The other pair 

(pictured in red) will be far more difficult to correct. Airport officials stated that it 

may be impossible to extend these RSAs at each runway end within current airport 

property limits and, as a result, it may be impracticable to improve the red RSAs 

to full dimensional standards. 

Figure 7. RSA EMAS Extension Project at 

Boston Airport 

 Sources: Wikipedia & OIG 

Boston Logan Airport faces similar 

RSA constraints, including a major 

waterway, surrounding urban 

development, and environmental 

restrictions. Yet, over the last 

several years, the airport has 

constructed partial EMAS on two 

of its RSAs—one of which was 

fully funded by the airport sponsor 

as an interim measure. The airport 

is working with FAA to construct 

an EMAS on this RSA, which will 

involve filling in or constructing a 

ramp into the Boston Harbor (see 

figure 7). According to FAA 

officials, this project is estimated to cost more than $40 million, which exceeds the 

Agency’s maximum cost figure (i.e., approximately $24 million) for determining 

practicability for this runway. 

FAA regional officials, however, were able to get support from the Office of 

Airports for this project based on a number of key factors, including: 

• a 1982 accident in which an aircraft went off the runway into Boston Harbor 

killing two passengers; 

• the runway’s critical role in servicing large jet aircraft (e.g., Boeing 747); and 

• Boston Logan’s importance as the domestic and international gateway to New 

England. 

While FAA and airport officials hope to complete the project by the 2015 

congressional deadline, the extra effort being taken to bring this RSA to full 

standards should serve as a model for other airports facing similar challenges. 

Because of the safety risk from not improving RSAs—such as with Midway 

Airport—it is important that FAA and airport sponsors complete RSA 

improvements as soon as possible at the 11 airports. For Reagan National, San 

Francisco International, and the other nine airports, FAA regional offices should 

exhaust all options—as is being done at Boston Logan airport—before declaring 
 12

RSAs impracticable to improve or deciding on only partial improvements. In 

doing so, the Office of Airports should develop an action plan for ensuring RSAs 

at the 11 large airports are improved as soon as possible and to the fullest extent 

practical. This plan should include projected milestones and costs, a designated 

improvement method, and the extent to which RSAs will meet standards. 

FAA Needs To Ensure the Timely Removal or Modification of 

NAVAIDs in RSAs 

Although FAA reports having relocated or modified NAVAIDs in more than 

60 RSAs over the last 3 years, approximately 38 percent (394 of 1,016) of all 

RSAs still contain one or more non-compliant NAVAIDs—including some that 

pose considerable safety risks to aircraft and their passengers. We found that FAA 

has not addressed these NAVAIDs for various reasons, including insufficient 

coordination, lack of guidance on the use of new frangible bolts, inadequate 

planning, and AIP funding restrictions. Combined, these factors have resulted in 

an inconsistent, disjointed process in which some NAVAIDs are corrected, others 

only partially corrected, and others—some of which pose safety risks—are not 

corrected at all. 

Non-Frangible NAVAIDs Remain in RSAs and Can Pose a Safety Risk to 

Aircraft and Their Passengers 

We found that over 40 percent (67 of 163) of the RSAs we reviewed had one or 

more NAVAIDs that need to be relocated or made frangible. NAVAIDS are 

lighting and instrument guidance systems—such as ALS and ILS—that aid in the 

landing of aircraft. Such equipment can vary in height, ranging from several feet 

to more than 40 feet. While design standards issued by the Office of Airports 

Engineering Division allow NAVAIDs to be located in RSAs in order to function 

properly, they must be made frangible at no more than 3 inches above the ground. 

In addition, FAA’s ATO is responsible for installing and maintaining all Agencyowned NAVAIDs in RSAs, as well as ensuring that such equipment meets design 

standards. 

Large NAVAIDs that are not moved or made frangible can pose a considerable 

safety risk to aircraft and passengers when struck during an overrun. For example, 

in June 1975 a Boeing 727 crashed into several non-frangible ALS towers while 

attempting to land at John F. Kennedy Airport in New York. Of the 124 persons 

aboard, 113 died of injuries received in the crash. Likewise, in November 1976, 

an aircraft taking off at Stapleton International Airport in Denver Colorado 

collided into two non-frangible ALS structures resulting in 14 injuries. 

In response to the Stapleton incident, the NTSB recommended that FAA expedite 

retrofitting of ALS structures with frangible materials so that the improvements 

would be completed within 3 to 5 years. However, more than 30 years later, we 
 13

found that non-frangible ALS remain in RSAs and continue to pose a safety risk to 

aircraft and passengers. For example, the ATO is aware of several non-frangible 

ALS structures located within the RSAs at Sacramento International Airport, but it 

has not funded efforts to remove them or make them frangible. We also found that 

other large non-frangible structures, such as ILS glide slope antennae and 

associated power sheds, remain in RSAs (see figures 8 and 9). 

Figure 8. Glide Slope Antenna at 

Long Beach Airport 

 Source: OIG 

Figure 9. Power Shed at 

Long Beach Airport 

Source: OIG 

Insufficient Coordination Has Impeded FAA’s Tracking of NAVAIDs in 

RSAs 

We found that the Office of Airports and ATO field offices we visited rarely 

coordinated to (1) determine the status of all NAVAIDs within RSAs; (2) ensure a 

plan was in place to relocate those NAVAIDs outside the RSA; or, if relocation 

was not an option, (3) ensure the equipment met frangibility requirements. While 

the Office of Airports and the ATO worked together in 2000 and 2005 in 

identifying NAVAIDs in RSAs, the two organizations have not conducted any 

further surveys. 

Moreover, while the Office of Airports and the ATO have coordinated the 

relocation or modification of NAVAIDs on a case-by-case basis, they have not 

developed a nationwide plan to address all NAVAIDs in RSAs, with priority given 

to those posing the greatest safety risks to aircraft and passengers. As a result, the 

Office of Airports officials did not always know what NAVAIDs may have been 

moved or modified over the last 3 years. This was the case for two non-compliant 

ILS antennae that had been relocated at Los Angeles and Sacramento airports after 

the 2005 survey. In both cases, the RSA Inventory did not reflect that these 

improvements had been completed. Both the Office of Airports and the ATO 

recognize that they need to solve this problem and have discussed the need to 

develop a plan and schedule for moving non-compliant NAVAIDs out of RSAs. 
 14

Lack of Guidance Has Limited the Use of New Frangible Bolts in 

Correcting Non-Compliant NAVAIDs 

Insufficient guidance on the use of new frangible bolts has 

prevented many NAVAIDs from meeting FAA’s 

standards. Certain NAVAIDs, because of their size or 

location, previously could not meet the 3-inch standard 

without compromising their structural integrity. However, 

in 2006, the Office of Airports Engineering Division 

started approving the use of 3-inch frangible bolts (see 

figure 10) on ALS and ILS applications. Although some 

NAVAIDs have been installed or retrofitted with the new 

bolts, the Office of Airports has yet to issue formal 

guidance to FAA field personnel on how the bolts should 

be applied. This has hampered efforts to retrofit existing NAVAIDs and ensure 

full compliance with FAA’s 3-inch frangibility standard. 

Figure 10. 3-Inch 

Frangible Bolt

 Source: FAA

Inadequate Planning and AIP Funding Restrictions Prevent the Timely 

Relocation and Modification of NAVAIDs 

The ATO, though responsible for installing and maintaining FAA NAVAIDs, has 

not adequately planned for the relocation or modification of non-compliant 

NAVAIDs in RSAs. For instance, the ATO’s annual Business Plan lists the 

various projects that are most likely to receive funding. Although the Business 

Plan supports the maintenance and upgrading of NAVAIDs for operational 

purposes, it does not prioritize the need to relocate or modify non-compliant 

NAVAIDs in RSAs. As a result, the ATO has not provided the funding necessary 

for the relocations and modifications. The one exception is NAVAIDs in RSAs 

that need to be replaced for operational reasons. In these situations, the ATO 

works to ensure the new NAVAIDs meet RSA standards. 

In contrast, the Office of Airports is responsible for ensuring compliance with 

RSA standards, but it is restricted from permitting airport sponsors to use AIP 

funds to address non-compliant NAVAIDs in RSAs. The primary exception is the 

relocation or modification of a NAVAID affected by a larger project, such as a 

runway extension (i.e., the NAVAID must be moved). Another exception is a 

change in runway operations that requires a larger RSA, such as when a runway is 

used by jet aircraft instead of propeller planes. Consequently, the restrictions 

placed on the use of AIP funds have prevented the Office of Airports from using 
 15

them to help in the removal and modification of non-compliant NAVAIDs 

remaining in RSAs.14 

Given the lack of ATO planning and AIP funding restrictions, FAA needs to 

develop a plan for addressing non-compliant NAVAIDs that places a higher 

priority on NAVAIDS posing the greatest threat in the event of a runway overrun 

or undershoot. This plan should identify and prioritize NAVAIDs that need to be 

addressed, develop a schedule for relocating or modifying them, and request 

sufficient funds for accomplishing all related tasks. 

FAA also needs to improve the coordination between the Office of Airports and 

the ATO in monitoring NAVAIDs that have been relocated or modified. Further, 

FAA needs to issue guidance to field personnel on the use of frangible bolts. 

Finally, FAA needs to develop a plan for addressing those NAVAIDs posing the 

greatest threat to aircraft and their passengers. 

FAA Needs To Establish an Effective Process for Identifying, 

Tracking, and Reporting RSA Improvements 

FAA’s ability to effectively identify, track, and report on the status of RSA 

improvements is hampered by inaccurate, incomplete, or outdated data. Such data 

problems are due to several factors, including insufficient guidance and training 

for FAA field personnel responsible for entering data into the RSA Inventory and 

lack of quality assurance controls. This hinders FAA’s ability to monitor the 

status of its RSA Program and ensure achievement of the congressional mandate. 

In addition, FAA’s annual report to Congress contains inaccurate information and 

does not identify specific RSAs that do not meet standards (e.g., contain noncompliant NAVAIDs), describe planned improvements, or list challenges that 

could prevent individual RSAs from meeting the 2015 deadline. 

FAA’s Oversight of Needed RSA Improvements Is Hampered by 

Inaccurate or Outdated Data 

During our audit, we compared RSA determinations and inventory records for 

163 RSAs and found numerous errors and inconsistencies between the various 

documents. Of the 163 RSAs we reviewed, 64 (39 percent) contained 1 or more 

data errors and 59 (36 percent) did not support the information in the RSA records. 

Inaccuracies included outdated, missing, or erroneous data entries in both the 

determination and RSA Inventory. 

 

14 In an effort to establish an alternative means of funding NAVAID improvements, FAA proposed a pilot program 

under which the Administrator would transfer ownership and operating and maintenance responsibilities for 

NAVAIDs to 10 medium or large hub airports. Submitted as part of FAA’s 2007 reauthorization bill, Congress 

never acted upon the proposal. 
 16

FAA personnel in the regions and Airport District Offices are responsible for 

determining the status of RSAs and their needed improvements, to include details 

on RSA dimensions, grading, and slope and whether objects or NAVAIDs are 

located within the RSA boundaries.15 FAA regional personnel manually enter this 

information into the RSA Inventory database, which was developed in 1999 to 

help manage the program. FAA uses this database to track progress, measure 

system-wide compliance of the RSA program, determine future funding needs, 

and prepare the annual report to Congress. 

We found the determinations or RSA Inventory data for some RSAs had either not 

been updated to reflect changes or contained contradictory information. These 

inaccuracies are caused by various factors, including insufficient guidance and 

training, poor coordination among field personnel, and lack of quality controls. 

Specifically: 

• There is no standard form to document determinations to ensure all data 

elements are captured and consistently identified. As a result, every region 

uses varying forms and terminology to complete determination paperwork, 

which leads to inconsistent types of data being gathered. 

• Determinations and the RSA Inventory are not linked electronically. Thus, the 

information between the two is often inconsistent and contradictory. 

• Regional FAA offices manually upload their determination data into the 

national RSA Inventory database; however, they do not always do so in a 

timely manner, and the data are not verified by the Office of Airports. 

• The RSA Inventory does not include current data on NAVAIDs in RSAs due 

to the lack of coordination between the Office of Airports and the ATO. For 

example, the RSA Inventory states that (1) an ILS antenna within a Los 

Angeles International Airport RSA needs to be relocated or made frangible, 

even though the ATO relocated the ILS antenna approximately 1 year earlier, 

and (2) an RSA at Dulles International Airport meets standards, even though 

the determination notes that the RSA does not meet standards due to a noncompliant ILS antenna. 

To correct these deficiencies, FAA needs to issue detailed guidance to its regional 

offices on the proper identification, tracking, and reporting of RSA status 

nationally. FAA also needs to ensure all regional offices receive training on the 

new guidance. Finally, FAA needs to implement an effective quality assurance 

process to ensure the accuracy of data in RSA determinations and the RSA 

Inventory. This process should electronically link the determination 

 

15 FAA Order 5200.8, Runway Safety Area Program, 1999. 
 17

documentation from FAA regional offices to the RSA Inventory, thereby 

eliminating errors between the two data sets. 

FAA’s Annual Report to Congress Does Not Accurately Reflect Status of 

RSA Improvements 

FAA’s annual report to Congress, which was mandated by law in 2005,16 contains 

inaccuracies and therefore does not fully inform Congress on the status of RSA 

improvements. We found that a number of factors are causing these discrepancies 

in FAA’s report. In particular, we found that FAA: 

• primarily relies on the RSA Inventory to summarize RSA status, although the 

Inventory contains inaccurate or outdated data, 

• provides only summary information on the number of improvements 

completed and the number remaining but does not identify individual airports, 

• reports RSA improvements as complete even though some of these 

improvements did not result in the RSA meeting the full standards, 

• fails to address those RSAs that do not meet standards due to non-compliant 

NAVAIDs and thus over-reports the total number of RSAs fully meeting 

standards by more than one-fourth, and 

• understates the future funding requirements for RSA improvements since it 

does not include cost estimates for those airport sponsors that have yet to 

decide on a corrective action. 

As a result, Congress does not know which airports have RSAs that do not meet 

standards (e.g., those containing non-compliant NAVAIDs) or what risks may 

prevent airports from meeting the 2015 deadline—such as the 11 large airports 

highlighted in this report. 

In our opinion, FAA’s annual report to Congress should identify (1) which RSAs 

do not meet the full design standards and specific reasons for noncompliance, 

(2) what plans are in place to allow these RSAs to attain the full standards, 

(3) what risks may prevent these RSAs from meeting standards by 2015, and 

(4) what financial assistance is needed from FAA to make these improvements. 

Such enhancements to the annual report will assist Congress and other 

Government officials in making informed decisions related to RSA funding and 

program priorities. 

 

16 In 2005, Congress mandated in Public Law 109-115 that FAA “shall report annually to the Congress on the agency’s 

progress toward improving runway safety areas” at all Part 139 certificated airports. FAA issued its first report in 

May 2007 and its second report in July 2008. 
 18

RECOMMENDATIONS 

We recommend the following actions to FAA’s Office of Airports: 

1. Develop and implement an action plan for ensuring RSAs at the 11 large 

airports are improved to the fullest extent practical. This plan should include 

projected milestones and costs, a designated improvement method, and the 

extent to which RSAs will meet standards. 

2. Work with the ATO to develop and implement an effective program for 

addressing NAVAIDs located in RSAs. This program should focus on 

(a) improved coordination, (b) guidance on using new 3-inch frangible bolts, 

and (c) a plan for relocating or modifying those NAVAIDs posing the greatest 

safety risk. 

3. Issue detailed guidance and conduct training for all field offices on the proper 

identification, tracking, and reporting of RSA status, including NAVAIDs. 

4. Implement quality control procedures to ensure the accuracy and integrity of 

RSA data. These procedures should (a) standardize documentation for field 

offices to use in making determinations, (b) electronically link determinations 

from FAA regional offices with the RSA Inventory, and (c) require periodic 

tests of data maintained in RSA Inventory. 

5. Expand the annual report to Congress to identify (a) which RSAs do not meet 

the full RSA design standards and specific reasons for noncompliance (e.g., 

non-compliant NAVAIDs, roadways, or rivers); (b) what plans are in place to 

allow these RSAs to attain full standards; (c) what challenges exist to prevent 

these RSAs from meeting the full standards by 2015; and (d) what financial 

assistance will be needed to achieve planned improvements. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

We provided FAA with our draft report on December 18, 2008. We received 

FAA’s formal response on February 6, 2009, which is included in its entirety in 

the appendix to this report. In addition to its response, FAA provided a number of 

clarifying technical comments. We addressed these comments as appropriate in 

our final report. 

FAA concurred with all five recommendations and plans to take several corrective 

actions. For example, FAA will direct its regions to energize efforts on 

completing RSA improvement plans for each of the 11 major airports cited in our 

report. FAA is also working to identify and address non-compliant NAVAIDs in 
 19

RSAs and plans to issue an advisory circular on frangible bolts in March 2009. 

Finally, FAA will take a number of steps to improve the quality of the RSA 

Inventory data and its annual report to Congress. 

FAA’s planned actions are responsive to our recommendations, and we consider 

all five recommendations to be resolved but open pending completion of the 

planned actions. We appreciate the courtesies and cooperation of FAA 

representatives during this audit. If you have any questions concerning this report, 

please contact me at (202) 366-0500 or Darren L. Murphy, Program Director, at 

(206) 220-6503. 

# 

cc: FAA Deputy Administrator 

Chief Operating Officer, Air Traffic Organization 

Associate Administrator for Airports 

Anthony Williams, ABU-100 

Martin Gertel, M-1 
 20

EXHIBIT A. SCOPE AND METHODOLOGY 

We conducted this performance audit in accordance with generally accepted 

Government Auditing Standards prescribed by the Comptroller General of the 

United States. As required by those standards, we obtained evidence that we 

believe provides a reasonable basis for our findings and conclusions based on our 

audit objectives. We conducted the audit between November 2007 and 

November 2008 and included such tests of procedures and records as we 

considered necessary, including those providing reasonable assurance of detecting 

abuse and illegal acts. 

During our audit, we visited or contacted FAA Headquarters, Airport regional 

offices, Airport district offices, and ATO service centers. We also visited or 

contacted a number of airport sponsors, airports, and stakeholder organizations. 

See exhibit B for a complete list of facilities visited or contacted during the audit. 

To assess FAA’s and airports’ progress and challenges, if any, in fulfilling the 

congressional RSA mandate, we selected a judgmental sample of 163 of the 

1,016 RSAs nationwide.17 The sample was designed to capture a mix of large, 

medium, and small airports requiring RSA improvements and associated FAA 

regional and district offices. As part of this process, we reviewed FAA and airport 

sponsor documentation showing the status of the 163 RSAs at 30 large, 

10 medium, and 13 small airports. We then interviewed FAA and airport officials 

to determine the status of future RSA improvements and to identify any 

impediments that would prevent an RSA from meeting standards by the 2015 

congressional deadline. Moreover, from the list of 30 large airports, we identified 

11 that have RSAs facing major man-made, natural, environmental, and legal 

challenges to being brought up to standards (see exhibit C). Finally, for RSAs that 

FAA considers impracticable to improve, we reviewed relevant documentation 

and discussed FAA’s rationale for its decisions. 

To evaluate the effectiveness of FAA’s process for identifying, prioritizing, and 

funding needed RSA improvements, we interviewed FAA Headquarters officials; 

reviewed various planning, funding, and reporting documents; and obtained a list 

of the RSA universe. We also interviewed personnel at FAA regional and Airport 

District Offices and obtained documentation showing the current status of RSAs. 

Due to significant differences in RSA determinations and the RSA Inventory, we 

could not rely on those data sources. We therefore visited selected airports and 

their RSAs to validate and test the accuracy of the information. Finally, we 

discussed our observations with FAA and airport officials. 

 

17 Between 2000 and 2007, the total number of RSAs at Part 139 airports decreased from 1,024 to 1,016 due to various 

reasons, including data errors in the RSA Inventory and decommissioned runways. In addition, the 1,016 RSAs 

were located at 53 airports (e.g., 30 large hubs, 10 medium hubs, and 13 small hubs). 

Exhibit A. Scope and Methodology 
 21

EXHIBIT B. FACILITIES VISITED OR CONTACTED 

Airports 

• Baltimore Washington International, MD 

• Bob Hope Burbank, CA 

• Boston Logan International, MA 

• Charlotte-Douglas International, NC 

• Fort Lauderdale/Hollywood Airport, FL 

• John F. Kennedy International, NY 

• John Wayne-Orange County, CA 

• LaGuardia, NY 

• Los Angeles International, CA 

• Long Beach, CA 

• Long Island MacArthur, NY 

• Metropolitan Oakland International, CA 

• Newark Liberty International, NJ 

• Phoenix Sky Harbor International, AZ 

• Reagan National, DC 

• Sacramento International, CA 

• San Diego International, CA 

• San Francisco International, CA 

• Teterboro, NJ 

• White Plains, NY 

Airport Sponsors/Owners 

• Maryland Aviation Administration, Linthicum, MD 

• Metropolitan Washington Airports Authority, Washington, DC 

• Port Authority of New York/New Jersey, New York, NY 

• Town of Islip, NY 

FAA Airport District Offices 

• Atlanta Airport District Office, Atlanta, GA 

• Honolulu Airport District Office, Honolulu, HI 

• Los Angeles Airport District Office, Lawndale, CA 

• New York Airport District Office, Garden City, NY 

• San Francisco Airport District Office, Burlingame, CA 

• Washington Airport District Office, Dulles, VA 

Exhibit B. Facilities Visited or Contacted 
 22

Exhibit B. Facilities Visited or Contacted 

FAA Regional Offices 

• Eastern Regional Office, Jamaica, NY 

• Great Lakes Regional Office, Des Plaines, IL 

• New England Regional Office, Burlington, MA 

• Northwest-Mountain Regional Office, Renton, WA 

• Southern Regional Office, College Park, GA 

• Southwestern Regional Office, Ft. Worth, TX 

• Western-Pacific Regional Office, Lawndale, CA 

FAA ATO Service Centers 

• Central Service Center, Ft. Worth, TX 

• Eastern Service Center, College Park, GA 

• Western Service Center, Renton, WA 

FAA Headquarters, Washington, DC 

• Office of Airport Safety and Standards, Office of Airports 

• Office of Airport Planning and Programming, Office of Airports 

• Navigation Services Office, Air Traffic Organization 

Stakeholders 

• Air Line Pilots Association, Washington, DC 

• American Association of Airport Executives, Alexandria, VA 

• Applied Research Associates, Elkridge, MD 

• National Transportation Safety Board, Washington, DC 

• Engineered Arresting Systems Corporation, Logan Township, NJ 
 23

EXHIBIT C. ELEVEN LARGE AIRPORTS FACING SIGNIFICANT 

CHALLENGES TO IMPROVING RSAS 

Baltimore Washington International-Thurgood Marshall Airport (State of 

Maryland) must improve four RSAs. All four RSAs are constrained by 

interstate and state highways. The airport sponsor and FAA have agreed on 

methods for improving the RSAs but will not execute them until the sponsor has 

updated the airport’s long-range Master Plan. This plan may decommission one of 

the runways, which would eliminate the need to improve one of the four RSAs. In 

addition, the Master Plan must be approved by FAA and undergo an 

environmental review. Finally, three of the four RSAs have NAVAIDs that need 

to be either relocated or made frangible.

Boston Logan International Airport (Boston, Massachusetts) must improve 

one RSA. This airport is constrained by Boston Harbor and urban development. 

As an interim measure to improving the RSA, the airport sponsor installed a 

partial EMAS (at its own cost) and is studying the possibility of installing a 

runway deck or filling in part of Boston Harbor and then installing a full EMAS. 

In addition, FAA’s regional office raised the maximum feasible improvement cost 

to over $40 million because the runway is used by Boeing 747 aircraft and was the 

site of a fatal 1982 accident. The airport sponsor has started assessing the 

project’s environmental impact and plans to complete the project by late 2013. 

Charlotte-Douglas International Airport (Charlotte, North Carolina) must 

improve two RSAs. The airport sponsor is installing an EMAS on one RSA but 

is waiting for that project’s completion before deciding on actions for the other 

RSA. This second RSA is constrained by a parkway and railroad tracks, and may 

be required to undergo an environmental review. 

Fort Lauderdale/Hollywood Airport (Broward County, Florida) must 

improve three RSAs. The first RSA, which is constrained by a canal, an 

interstate highway, and railroad tracks, will be improved during a runway 

extension project. This project completed the environmental review process in 

January 2009. The second RSA is not likely to be improved since the airport 

sponsor plans to decommission the associated runway once the above extension 

project is completed. The third RSA—which has been improved with a partial and 

full EMAS—still contains four non-frangible NAVAIDs. 

Exhibit C. Eleven Large Airports Facing Significant Challenges To Improving 

RSAs 
 24

John F. Kennedy International Airport (Port Authority of New York and 

New Jersey) must improve three RSAs. This airport is constrained by Jamaica 

Bay, roads, and wetlands. One RSA is being improved during a 2009-2010 

runway rehabilitation project, which includes capacity enhancements (e.g., new 

taxiways). After the project is complete, the airport sponsor plans to begin the 

other two RSA improvement projects. Completing runway rehabilitation and RSA 

improvement projects requires careful sequencing so that they do not reduce 

operations on the airport’s runways. As a result, FAA officials noted that it may 

take more than 7 years to complete the RSA improvements. The airport sponsor is 

currently designing the improvement projects, which will have to undergo 

environmental review. 

LaGuardia Airport (Port Authority of New York and New Jersey) must 

improve two RSAs. Although partial EMAS have been installed on the airport’s 

two RSAs, final improvements—which involve extending runway decks over 

Flushing Bay—present engineering challenges and may take more than 8 years to 

complete. FAA estimates that the cost of these improvements will be more than 

$36.5 million. The airport sponsor is designing the project but has not completed 

the environmental review process. 

Los Angeles International Airport (Los Angeles, California) must improve 

two RSAs. These two RSAs are on the airport’s north side and are constrained by 

roads, urban development, and environmentally sensitive areas. The airport has 

two other RSAs, on the airport’s south side, that were brought up to standards in 

2008 during runway expansion projects. Improvements to the remaining two have 

been delayed by legal battles over the airport’s Master Plan, which requires the 

airport sponsor to redesign north side runway expansion projects and submit them 

to local review. The airport sponsor is conducting a state environmental impact 

review, which will be followed by a Federal environmental impact statement. 

These studies, which may be finished as early as 2011, will help determine the 

preferred design for the north side runways. 

Philadelphia International Airport (Philadelphia, Pennsylvania) must 

improve two RSAs. This airport is constrained by the Schuylkill and Delaware 

Rivers, an interstate highway, a U.S. Army Corps of Engineers dredge disposal 

site, and an industrial area. One RSA requires the airport sponsor and the 

U.S. Army Corps of Engineers to reach an agreement on how to mitigate the 

project’s impact on wetlands. The second RSA improvement project is part of a 

larger program to enhance Philadelphia International’s capacity, and that project’s 

draft environmental impact statement is expected to be issued before 2009. 

Finally, the airport’s other two RSAs meet dimensional standards but contain 

non-frangible ALS structures. 

Exhibit C. Eleven Large Airports Facing Significant Challenges To Improving 

RSAs 
 25

Phoenix Sky Harbor International Airport (Phoenix, Arizona) must improve 

one of its three RSAs. This airport is bordered by a river and urban development. 

FAA has approved the installation of an EMAS in this RSA; however, the City of 

Phoenix would like to construct a full, standard RSA extending 1,000 feet beyond 

each runway end. FAA approves of Phoenix pursuing the full RSA, but the city 

has not finished a study on how to complete the project. Once the study is 

complete, the project will must be approved by FAA and undergo an 

environmental review. 

Reagan National Airport (Washington, D.C.) must improve its three RSAs. 

The airport is constrained by the George Washington Parkway and the Potomac 

River. The airport sponsor plans to improve one RSA by extending the main 

runway and has already started assessing the project’s environmental impact. The 

sponsor has not yet decided how to improve the other two RSAs but plans to do so 

after completing a second environmental assessment. 

San Francisco International Airport (San Francisco, California) must 

improve its four RSAs. The airport is challenged by San Francisco Bay and 

Highway 101. Although it is conducting a study to determine how best to address 

the airport’s four RSAs, the sponsor tentatively plans on using declared distances 

to bring two RSAs up to standards. The other two RSAs may be impossible to 

extend within current airport property limits and, as a result, may be impracticable 

to bring up to full dimensional standards. 

Exhibit C. Eleven Large Airports Facing Significant Challenges To Improving 

RSAs 
 26

EXHIBIT D. MAJOR CONTRIBUTORS TO THIS REPORT 

Name Title 

Darren Murphy Program Director 

Jerrold Savage Project Manager 

Greggory Bond Senior Auditor 

Curtis Dow Auditor 

Michael Dunn Auditor 

Henning Thiel Auditor 

Petra Swartzlander Senior Statistician 

Andrea Nossaman Writer-Editor 

Exhibit D. Major Contributors to This Report 
 27

APPENDIX. AGENCY COMMENTS 

Federal Aviation 

Administration 

Memorandum 

Date: February 6, 2009 

To: Lou E. Dixon, Assistant Inspector General for Aviation and Special 

 Program Audits 

From: Lynne Osmus, Acting Administrator, AOA-1 

Prepared by: Catherine M. Lang, Acting Associate Administrator for Airports, ARP-1 

Subject: Draft Report on the Federal Aviation Administration’s Runway Safety 

Area (RSA) Program – Project Number 07A3013A000; Your Memo of 

12/18/08

Thank you for the opportunity to provide comments on your draft report of December 18, 

2008. 

Overall, we found your draft RSA report to be very useful. We concur with your 

recommendations. However, we do have some concerns with portions of the report’s 

findings and incorrect technical statements. We have attached a redlined copy of the 

draft report that addresses these concerns and provides clear background information on 

the FAA’s RSA program. 

We have also attached a response to your five specific recommendations. 

Attachments 

Appendix. Agency Comments 
 28

Attachment 1 

(Page 1 of 2) 

Recommendation #1: Develop and implement an action plan for ensuring RSAs at the 

11 large airports are improved to the fullest extent practicable. This plan should include 

projected milestones and costs, designated improvement method, and the extent to which 

RSAs will meet standards. 

FAA response #1: FAA agrees. We will direct FAA regions to energize efforts on 

working with sponsors to complete plans for each of these RSAs. Four of the 11 airports 

have plans in place for improving RSAs. We will require FAA regions to submit the 

plans to Headquarters and require status reports at the end of each fiscal year. Summaries 

of these reports will be included in the report to Congress starting in 2009. 

Recommendation #2: Work with ATO to develop and implement an effective program 

for addressing NAVAIDs located in RSAs. This program should focus on (a) improved 

coordination, (b) guidance on using new 3-inch frangible bolts, and (c) a plan for 

relocating or modifying those NAVAIDs posing the greatest safety risk. 

FAA response #2: FAA agrees. The Office of Airports continues to work with the 

Air Traffic Organization to develop procedures for the two organizations to identify 

NAVAIDS in RSAs and to take appropriate action to comply with RSA standards by 

2015. We will develop these procedures by May 15, 2009. We will develop a plan, 

schedule, and budget for completing the NAVAID RSA projects to the extent practicable 

by the end of 2015. This plan will be completed by June 30, 2009. Finally, we will issue 

an advisory circular providing updated guidance on frangible bolts in March, 2009. 

Recommendation #3: Issue detailed guidance and conduct training for all field offices 

on the proper identification, tracking, and reporting of RSA status, including NAVAIDs. 

FAA response #3: FAA agrees. We will continue to support the RSAI database and 

provide guidance as needed for reporting purposes. The RSAI database has been through 

16 revisions since it was first developed in 2000. There is a detailed user guide posted on 

a common electronic folder, and internal orders are in place to ensure quality data. 

Updated guidance will be issued by June 30, 2009. The guidance will address training 

issues, as we understand one of the problems with the proper data entry is that the 

responsibility for entering data often shifts to new people due to transfers, retirements, or 

other actions. 

Recommendation #4 Implement quality control procedures to ensure the accuracy and 

integrity of RSA data. These procedures should (a) standardize documentation for field 

offices to use in making determinations, (b) electronically link determinations from FAA 

regional offices with the RSA Inventory, and (c) require periodic tests of data maintained 

in RSA Inventory. 

Appendix. Agency Comments 
 29

Appendix. Agency Comments 

(Page 2 of 2) 

FAA response #4: FAA agrees. The RSA database is being constantly updated. We 

will review these procedures to identify improvements that can be implemented, 

including electronically linking determinations from FAA regional offices. We will 

complete this review by September 30, 2009. The review will address the need for 

periodic review of the data and sharing of the data with the Airport Development Offices 

(ADO) who are in the best position to validate the data entries. 

Recommendation #5: Expand the annual report to Congress to identify (a) which RSAs 

do not meet the full RSA design standards, (b) what plans are in place to allow these 

RSAs to attain full standards, (c) what challenges exist to prevent these RSAs from 

meeting the full RSA design standards by 2015, and (d) what financial assistance will be 

needed to achieve planned improvements. 

FAA response #5: FAA agrees and will include this information in the 2009 report to 

Congress. 
The following pages contain textual versions of the graphs and charts included in this 

document. These pages were not in the original document but have been added here to 

accommodate assistive technology. 
Actions Taken and Needed To Improve the Federal Aviation Administration’s 

Runway Safety Area Program 

Section 508 Compliant Presentation 

Figure 1. Runway Safety Area Dimensional Standards 

Figure depicts standard runway safety area surrounding a runway with the 

dimensional requirements noted. Specifically, runway safety areas must typically be 

1,000 feet by 500 feet at each runway end and 250 feet from the runway centerline. 

Figure 2. Runway Safety Area Obstacles at Reagan National Airport 

Aerial photograph shows Reagan National Airport area and notes location of 

environmental clean-up site, runway distance from Potomac River (170 feet), and 

runway distance from the George Washington Parkway (120 feet). 

Source: Google and Office of Inspector General 

Table. Examples of Major Runway Accidents Involving Non-Standard Runway 

Safety Areas 

• Accident at Little Rock National Airport in June 1999 resulted in 105 injuries and 

11 fatalities. 

• Accident at Bob Hope Burbank Airport in March 2000 resulted in 44 injuries. 

• Accident at Teterboro Airport (New Jersey) in February 2005 resulted in 

14 injuries. 

• Accident at Chicago’s Midway International Airport in December 2005 resulted in 

22 injuries and 1 fatality. 

Source: National Transportation Safety Board 

Figure 3. Aircraft Damage from Hitting Navigational Aid at Dekalb-Peachtree 

Airport 

Photograph shows damaged aircraft wing and destroyed navigational aid. 

Source: Federal Aviation Administration 
Figure 4. Data Errors in the Federal Aviation Administration’s Runway Safety 

Area Inventory 

• Runway Safety Area Inventory states that a runway safety area at Baltimore 

Washington International Airport meets standards even though it is less than the 

required 250 feet on 1 side of the runway. 

• Runway Safety Area Inventory states that a runway safety area at Dulles 

International Airport meets standards, even though an Instrument Landing System 

needs to be relocated. 

• Runway Safety Area Inventory states that $39 million was needed for a major 

runway and runway safety area project at Los Angeles International Airport when 

it had been completed 1 year earlier. 

Figure 5. Constrained Runway Safety Areas at Reagan National Airport 

Aerial photograph shows three runway safety areas at Reagan National Airport which 

are constrained by an environmental clean-up site, the Potomac River, and the George 

Washington Parkway. 

Source: Google and Office of Inspector General 

Figure 6. Constrained Runway Safety Areas at San Francisco Airport 

Aerial photograph shows four constrained runway safety areas at San Francisco 

International Airport. The four runway safety areas are bordered by San Francisco 

Bay and Highway 101. 

Source: Wikipedia and Office of Inspector General 

Figure 7. Runway Safety Area Engineered Material Arresting System (or 

EMAS) Extension Project at Boston Airport 

Aerial photograph of Boston Logan Airport shows end of Runway 15R/33L meeting a 

partial EMAS, which measures 158 feet by 170 feet. Area outlined in red shows how 

the proposed full-sized EMAS would extend over Boston Harbor. 

Source: Wikipedia and Office of Inspector General 
Figure 8. Glide Slope Antenna at Long Beach Airport 

Photograph shows large, non-frangible Instrument Landing System glide slope 

antennae at Long Beach Airport. 

Source: Office of Inspector General 

Figure 9. Power Shed at Long Beach Airport 

Photograph shows large, non-frangible power shed building at Long Beach Airport. 

Source: Office of Inspector General 

Figure 10. 3-Inch Frangible Bolt

Photograph shows frangible bolt required to secure navigational aids located in 

runway safety areas. The bolt is positioned vertically on a desk next to an ink pen to 

show actual size. 

Source: Federal Aviation Administration.