U. S.

DEPARTMENT OF 

TRANSPORTATION

FEDERAL 

AVIATION 

ADMINISTRATION

EVALUATION OF THE NORTH 

SHORE MARINE TRANSFER 

STATION AND ITS 

COMPATIBILITY WITH 

RESPECT TO BIRD STRIKES 

AND SAFE AIR OPERATIONS 

AT LAGUARDIA AIRPORT

(DRAFT)

U. S. Department 

of Agriculture

Animal and 

Plant Health 

Inspection 

Service

Wildlife Services

REPORT FOR THE ASSOCIATE ADMINISTRATOR FOR AIRPORTS

OFFICE OF AIRPORT SAFETY AND STANDARDS

AIRPORT SAFETY & CERTIFICATION DIVISION

WASHINGTON, DC

APRIL 2010
The U.S. Departments of Transportation and Agriculture prohibit discrimination in all 

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

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

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

means for communication of program information (Braille, large print, audiotape, etc.) 

should contact the appropriate agency.

The Federal Aviation Administration produced this report in cooperation with the U. S. 

Department of Agriculture, Animal and Plant Health Inspection Service, Wildlife Services.
1

TABLE OF CONTENTS Page

EXECUTIVE SUMMARY 4

1. INTRODUCTION 6

2. APPROACH 8

3. COMPONENTS OF THE NORTH SHORE MTS STUDY 9

3.1. Bird-aircraft Collisions at LaGuardia Airport 9

3.2. Urban Wildlife and Bird Observations at the Proposed Site 11

3.3. Design Features of the Proposed North Shore MTS Facility 16

3.4. Operational Procedures of the Proposed North Shore MTS Facility 17

3.5. Examination of Currently Operating Trash-transfer Facilities 18

3.6. Risk Assessments 21

3.7. Determination of Findings 22

4. RECOMMENDATIONS 23

5. SOURCES OF INFORMATION 25

6. APPENDIX A 27

7. APPENDIX B 28
2

LIST OF FIGURES

Figure Page

3-1 Summary of bird strikes at LaGuardia Airport during 2004–2008 when 

the bird(s) involved was identified. 11

3-2 Site location for the proposed North Shore MTS near College Point, 

Queens, New York. The proposed site is approximately 2,200 feet 

from LaGuardia Airport. 12

3-3 Birds observed during a long-term monitoring program to assess 

wildlife hazards at LaGuardia Airport during 2004–2009. 13

3-4 House sparrows (top photo) and pigeons (bottom photo) are often a pest 

 at trash-transfer stations and other facilities where solid waste is received 

 and processed. 14

3-5 A European starling. Introduced into Central Park in New York City 

the late 1800s, this bird has spread across North America. Today the

starling population in the United States exceeds 100 million birds. 14

3-6 Two adult herring gulls. Herring gulls (and other gull species) use waste 

management facilities, such as trash-transfer stations and landfills, as a 

place to find food. 15

3-7 Cross-sectional schematic of the proposed North Shore MTS. 17

3-8 Standardized bird surveys were conducted at the Staten Island Transfer Station, 

a truck-to-rail transfer station facility located in Staten Island, New York. 

The building design and operational procedures of this facility are similar 

to those of the proposed North Shore MTS. 19

3-9 Assessment of the risk to aviation safety for aircraft using LaGuardia 

Airport under three alternatives related to the proposed North 

Shore MTS. 22
3

LIST OF TABLES

Table Page

3-1 Study activities and date of achievement for the North Shore MTS 

joint study conducted by FAA and USDA in accordance 

with a pre-determined schedule. 9

3-2 Top-20 ranked FAA Part-139 certificated airports (out of a total of 64 

 airports) within the FAA Eastern Region regarding reported gull-aircraft 

 collisions (includes several gull species) per 100,000 aircraft movements

 during 2004–2008. 10

3-3 Average number of birds (of selected species) observed per hour 

of survey time within 0.25-mile of the proposed North Shore MTS 

site located near College Point in Queens, New York during standardized 

bird surveys conducted in February and March of 2010. 15

3-4 Average number of birds (of selected species) observed per hour of 

survey time within 0.25-mile of the Staten Island Transfer Station 

located in Staten Island, New York and the average number of 

birds per hour of survey time using the transfer station during

6 standardized bird surveys conducted in February and 

March of 2010. 20
4

EXECUTIVE SUMMARY

In 2006, the City of New York Department of Sanitation (DSNY) developed and issued a

Comprehensive Solid Waste Management Plan (SWMP) to address the long-term 

exportation and disposal of municipal solid waste from metropolitan New York City. 

Four closed Marine Transfer Stations (MTS) previously operated by DSNY have been

proposed for refurbishment. One of the four proposed facilities, the North Shore MTS,

would be located in the College Point section of Queens, NY, 2,206 feet from the landing 

threshold of Runway 13 / 31 at LaGuardia Airport (LGA). 

In January of 2007, the New York State Department of Environmental Conservation 

received the Final Part 360 Permit Application for the North Shore MTS for review and 

public comment. The Federal Aviation Administration (FAA) issued a determination of 

„No Hazard to Air Navigation‟ under the Code of Federal Regulations Part 77. Further 

FAA guidance contained within Advisory Circular 150/5200-33B, „Hazardous Wildlife 

Attractants on or near Airports‟ states that certain waste-handling facilities designed and 

operated under specific conditions generally are compatible with safe airport operations, 

provided they are not located on airport property or within the Runway Protection Zone 

(RPZ). Although the proposed site for the facility is not in the RPZ for LaGuardia 

Airport, Congressional and public scrutiny resulted in additional investigation. 

A joint study conducted by the FAA and United States Department of Agriculture, 

Animal and Plant Health Inspection Service, Wildlife Services (USDA), with guidance 

from a technical panel of experts, reviewed current and historical wildlife data and 

surveys, the bird strike history at LaGuardia Airport, and the proposed building design 

plans, specifications, and operational parameters. This study considered currently 

operating and similarly designed trash-transfer stations located in other boroughs of New 

York City and conducted risk assessments on a range of alternatives, from „no facility‟ to 

„a fully operational facility with mitigation measures in place.‟

Previous research has demonstrated that gulls, European starlings, and pigeons are bird 

species frequently attracted to trash-transfer facilities. A review of available information, 

such as the history of bird-aircraft collisions (bird strikes) at LGA and findings from a 

wildlife hazards monitoring program at the airport, clearly demonstrates that gulls are a 

documented strike hazard at LGA and that gulls are frequently observed in the coastalurban environment where the proposed MTS has been sited. 

The proposed MTS would be a three level, over water facility explicitly designed for the 

indoor transfer of solid waste from collection vehicles into sealed leak-proof containers. 

Each container would be sealed and cleaned within the transfer station building and then 

loaded onto barges for transfer to the final disposal site. No solid waste would be stored 

or processed outside of the fully enclosed MTS building. 

Historical and current observations clearly demonstrate that gulls and other birds 

frequently occur within the vicinity of the proposed North Shore MTS site and in the 

general area near LaGuardia Airport. Standardized bird surveys conducted at the Staten 
5

Island Transfer Stations (a facility with a similar building design and operational 

procedures for the proposed North Shore MTS) indicated that although gulls were 

abundant in the general area, those birds were not attracted to transfer station and the 

waste management activities occurring inside the building.

Reduction of hazards to aviation safety posed by birds that might be attracted to the 

proposed North Shore MTS can be accomplished through the incorporation of building 

design modifications, adherence to strict operational procedures, and the development 

and implementation of an integrated wildlife hazard management plan and program. The 

FAA, USDA, and members of the technical panel of experts conclude that the 

recommendations provided will achieve compatibility between the North Shore MTS and 

LaGuardia Airport with respect to bird strikes and safe air operations. The following 

recommendations provide a framework for proactive monitoring and mitigation of 

wildlife hazards to aviation at the proposed North Shore MTS:

Planning and Construction Phases:

• Develop an integrated wildlife hazards management plan for the MTS facility.

• Eliminate ledges and other perching sites in the building design to the greatest extent 

possible. As an example, signage on the building should not use raised letters as this 

provides perching and nesting sites for European starlings and house sparrows. 

• Install anti-perching devices on the transfer station roof, pilings, and other surfaces 

where birds might perch.

• Strict enforcement of a “no feeding wildlife or feral animals” policy.

• Ensure landscaping plants and materials are selected to be non-attractive to wildlife 

(such as minimizing grassy areas which might attract Canada geese).

Fully Operational Transfer Station:

• Implement an integrated wildlife hazards management program for the MTS facility.

• Provide a dedicated (i.e., only duties) wildlife control professional who is trained and 

equipped to mitigate bird use of the transfer station as issues develop (i.e., proactive 

approach).

• Strict enforcement of a “no feeding wildlife or feral animals” policy.

• Monitor trash containers to ensure no trash is extruding from them prior to leaving the 

transfer station building.

• Monitor barge activity for birds that might be attracted to them (due to water 

disturbance and/or the refuse containers) and mitigate accordingly. 
6

1. INTRODUCTION

Trash-transfer stations are a relatively new component of solid waste management 

systems. A transfer station is a facility where solid waste (i.e., household garbage, 

commercial refuse, construction and building debris) is received, processed, and 

subsequently transferred to another solid waste management facility for further treatment, 

processing, or final disposal. Similar to other solid waste management facilities, such as 

landfills, certain species of birds can be attracted to trash-transfer stations. If such 

facilities are located near airports, the potential for collisions between birds and aircraft 

(bird strikes) could increase and thus negatively impact safe aircraft operations. 

Recently, a scientific study administered through the National Wildlife Research Center 

of the United States Department of Agriculture, Animal and Plant Health Inspection 

Service, Wildlife Services (WS) program (hereafter the WS research and operations 

groups will be referred to as USDA) evaluated the attractiveness of trash-transfer stations 

to wildlife, in particular species of birds that have been documented to be a hazard to 

aviation. Findings from this study indicate the design and operation of trash-transfer 

facilities, in addition to other factors, can influence whether or not birds are attracted to a 

trash-transfer station. Thus, if the facility is located near an airport, these factors can be 

related to the overall compatibility of a transfer station to safe aircraft operations.

In 2006, the City of New York Department of Sanitation (DSNY) developed and issued a 

Comprehensive Solid Waste Management Plan (SWMP) to address the long-term 

exportation and disposal of municipal solid waste (i.e., residential and commercial waste) 

from metropolitan New York City. The refurbishment of four former (closed) Marine 

Transfer Station (MTS) facilities previously operated by DSNY into new MTS facilities 

is an integral part of the SWMP. Municipal solid waste (i.e., household garbage) would 

be transported to the MTS facilities by curbside garbage trucks, processed and 

containerized within each facility, and transported by barge from each MTS to intermodal 

facilities or waste disposal sites (e.g., landfills) outside of the New York City area. 

Regulations regarding solid waste management facilities, specifically section 6 of the

New York Codes, Rules and Regulations Part 360 , are the authority by which the State 

of New York sets design standards and operational criteria for all solid waste 

management facilities within the state. In January of 2007, the New York State 

Department of Environmental Conservation received the Final Part 360 Permit 

Application for one of the four proposed MTS (the North Shore MTS) for review and 

public comment. 

On November 10, 2004, the Federal Aviation Administration (FAA) received a proposal 

from the DSNY to construct the North Shore MTS [building height of 110 feet Above 

Mean Sea Level (AMSL)] at a site located 2,206 feet from the landing threshold of 

Runway 13/ 31 at LaGuardia Airport (LGA). In response, an aeronautical study was 

completed and no internal objections were received. The proposed MTS building was 

identified as an obstruction under the Code of Federal Regulations Part 77 and was 

released for public comment in April of 2005. A determination of „No Hazard to Air 

Navigation‟ was issued by the FAA on September 18, 2006. Following concerns 
7

expressed by the Port Authority of New York and New Jersey, the NYSD submitted a 

revised proposal (with a modified building height of 100 feet AMSL) to the FAA in 

March of 2007. The FAA conducted a second aeronautical study and consequently 

determined that the proposed structure (the North Shore MTS building) would have no 

substantial adverse effect on the safe and efficient use of the navigable airspace by 

aircraft or on the operation of air navigation facilities (Decision issued on September 19, 

2008).

FAA guidance contained within Advisory Circular 150/5200-33B, „Hazardous Wildlife 

Attractants on or near Airports‟ states that enclosed waste-handling facilities that receive 

garbage behind closed doors; process it via compaction, incineration, or similar manner; 

and remove all residue by enclosed vehicles generally are compatible with safe airport 

operations, provided they are not located on airport property or within a Runway 

Protection Zone (RPZ). The proposed site for the facility is not in the RPZ for LaGuardia 

Airport.

In general, public interest and overall awareness of collisions between wildlife and 

aircraft increased substantially in recent years, most notably following U.S. Airways 

flight 1549 “Miracle on the Hudson” event on January 15, 2009. Public concern about 

the potential safety hazards that wildlife populations and habitat features that attract 

wildlife to areas on or near airports also increased. The proposed location for the North 

Shore MTS is within the current flight path corridor for LaGuardia Airport. The public, 

as well as local, state, and federal government agencies have expressed concern that 

waste management activities occurring at a trash-transfer station located less than 

0.5 miles from LaGuardia Airport could serve to attract birds that are known hazards to 

aviation, thereby negatively impacting safe flight operations at LaGuardia Airport. 

Notable discourse regarding this issue, evident in local and national media stories, 

occurred throughout 2009. Congressional interest from the New York delegation resulted 

in several questions regarding FAA policies and previous examinations of the topic by 

the FAA and other government agencies. During the autumn of 2009, the Secretary of 

the United States Department of Transportation held a series of meetings with the New 

York Congressional delegation, the City of New York, FAA, and USDA personnel. In 

the interest of public safety, it was determined that the FAA and USDA should engage in 

a joint study to re-examine the topic. The FAA and USDA currently cooperate in the 

conduct of research on various topics related to wildlife hazards to aviation. Research 

findings are used by the FAA develop and promulgate safety regulations related to 

wildlife at airports, thus ensuring safe aircraft operating environments at the Nation‟s 

airports. For this particular study, the two federal agencies decided to request the 

assistance of a “blue ribbon” technical panel of experts recognized as knowledgeable 

about wildlife hazards at airports (Appendix A). This technical panel was charged with 

providing guidance and advice to the agencies as the process moved forward. A key 

effort by the agencies was to produce a study report in which all available information 

concerning the issue would be examined. The purpose of this report is to provide an 

answer as to whether the North Shore MTS proposed by DSNY is compatible with safe 

airport operations at LaGuardia Airport. 
8

2. APPROACH

The approach used in this effort is not unique. Typically, examinations of wildlife 

hazard issues related to aviation safety involve a series of quantitative and qualitative 

approaches that are commonly used by wildlife management professionals. 

Following an established study schedule (Table 3-1), the FAA and USDA team 

decided to review plans regarding the design and operation of the proposed North 

Shore MTS in detail while considering the ecology of birds that are commonly found 

in the highly urbanized coastal area where the proposed MTS site and LaGuardia 

Airport are located. The objective of this effort was to determine the compatibility of 

the proposed MTS with safe airport operations at LaGuardia Airport with respect to 

bird strikes. Specifically, the FAA and USDA team, with the guidance of the 

technical panel, decided to:

1) Review wildlife data, including wildlife strike history, surveys, previous wildlife 

hazard assessments, and other related studies that pertain to LaGuardia Airport. 

Recognizing that applicable FAA guidance was updated in 2004 (i.e., Title 14 

Code of Federal Regulations Part 139 – Certification of Airports) the team

decided that information collected prior to 2004 would not be considered. 

2) Conduct a detailed review of the proposed building design plans, specifications, 

and operational parameters of the proposed North Shore MTS, including transport 

trucks, barges, trash types and volume, and nature of general operation.

3) Conduct a physical assessment of the proposed facility location. This included a 

series of direct observations (i.e., surveys) to quantify the presence and abundance 

of wildlife at the proposed North Shore MTS location. 

4) Examine currently operating trash-transfer stations of similar design located in 

other boroughs of New York City (more specifically, in the Bronx and Staten 

Island) to better understand the processes employed in solid waste transfer and to 

observe firsthand how these facilities and/or processes might attract birds. 

5) Conduct risk assessments on a range of alternatives, from „no facility‟ to „a fully 

operational facility with mitigation measures in place.‟ 

Based on the team‟s examination of the available data the FAA and USDA will issue 

a „determination of findings‟ related to (1) whether the trash transfer facility is 

incompatible with safe airport operations at LaGuardia Airport with respect to bird 

strikes, (2) whether the MTS and its operation (as proposed in the Part 360 Permit) is 

adequate, or (3) whether the proposed facility can safely coexist if further mitigation 

measures are applied.
9

Table 3-1. Study activities and date of achievement for the North Shore MTS 

joint study conducted by FAA and USDA in accordance with a 

pre-determined schedule.

Item Date of Achievement

Project Initiation and Task Assignment to USDA November 30, 2009

First Technical Panel Meeting December 7, 2009

Finalize Detailed Project Plan December 9, 2009

Mid Project Progress Briefing February 8, 2010

Initial Draft Report March 19, 2010

Technical Panel Draft Report Review March 26, 2010

Report Released for Public Comment April 23, 2010

Completion of Public Comment Period May 24, 2010

Public Comment Review Meeting May 28, 2010

Delivery of Final Report June 3, 2010

Final Report Published by the FAA June 18 – August 13, 2010

3. COMPONENTS OF THE NORTH SHORE MTS STUDY

3.1. Bird-aircraft Collisions at LaGuardia Airport

Civil and military aviation communities have long recognized that the threat to human

health and safety from aircraft collisions with birds and other wildlife (wildlife strikes) is 

real and increasing. Worldwide, wildlife strikes have resulted in more than 229 human 

fatalities and the destruction of over 220 aircraft since 1988. Information regarding 

wildlife strikes to civil aviation within the United States is contained in the FAA National 

Wildlife Strike Database. 

Recent events have amplified public awareness of wildlife strikes to aircraft. The

dramatic "forced landing" of US Airways Flight 1549 in the Hudson River after Canada 

geese were ingested by both engines on 15 January 2009 dramatically demonstrated to 

the public that wildlife strikes are a serious aviation safety issue.

LaGuardia Airport is managed by The Port Authority of New York and New Jersey and 

is located on the northeastern end of Long Island, in Flushing, New York. LaGuardia 

Airport is one of 64 Part 139 certificated airports regulated by the FAA Eastern Region. 

It is bordered on the north, east, and south by Flushing Bay (part of Long Island Sound) 

and on the west by highly urbanized (i.e., residential and commercial properties), densely 

populated areas of northern Queens County. Similar to other airports located adjacent to 

large bodies of water, large populations of various species of birds that live in or near 
10

aquatic environments (such as gulls and waterfowl) can be found near LaGuardia Airport. 

Due to the presence and behavioral patterns (e.g., flocking, soaring) of these birds, the 

risk of bird strikes is a concern at LaGuardia Airport as well as other airports located on 

waterways. Data from the FAA National Wildlife Strike Database clearly show that bird 

strikes frequently occur and thus represent an important issue. One means of 

understanding and quantifying bird strikes at airports is to determine the number of 

reported bird strikes per 100,000 aircraft movements. Of the 64 Part 139 certificated 

airports in the FAA‟s Eastern Region, LaGuardia Airport ranked 9

th when the number of 

wildlife strikes per 100,000 aircraft movements (during 2004–2008) is considered (20.5 

strikes per 100,000 aircraft movements were reported). Furthermore, incidents with gulls 

constitute a large portion of the bird strikes that occur at LaGuardia Airport (Figure 3-1) 

and other airports located on waterways within the mid-Atlantic region (Table 3-2). 

Table 3-2. Top-20 ranked FAA Part-139 certificated airports (out of a total of 64 

airports) within the FAA Eastern Region regarding reported gull-aircraft collisions 

(includes several gull species) per 100,000 aircraft movements during 2004–2008.

Airport Name (State)

Reported Gull Strikes 

per 100,000 Aircraft 

Movements Rank

Norfolk International (VA) 8.6 1

LaGuardia Airport (NY) 8.0 2

Buffalo-Niagara International (NY) 6.0 3

John F. Kennedy International (NY) 5.8 4

Albany International (NY) 5.2 5

Harrisburg International (PA) 4.2 6

Atlantic City International (NJ) 4.2 7

Ronald Reagan National (VA) 3.8 8

Elmira / Corning Regional (NY) 3.3 9

Newark Liberty International (NJ) 2.7 10

Greenbrier Valley (WV) 2.5 11

New Castle (DE) 2.4 12

Niagara Falls International (NY) 2.0 13

Newport News (VA) 2.0 14

Hagerstown Regional (MD) 1.9 15

Baltimore/Washington International (MD) 1.7 16

Philadelphia International (PA) 1.6 17

Williamsport Regional (PA) 1.5 18

Greater Rochester International (NY) 1.4 19

Erie International / Tom Ridge Field (PA) 1.4 20
11

55%

19%

4%

6% 5%

11%

Gulls Ducks & Geese

Blackbirds & Starlings Doves & Pigeons

Small Perching Birds Other Birds

Figure 3-1. Summary of bird strikes at LaGuardia Airport during 2004–2008 when 

the bird(s) involved was identified. 

3.2. Urban Wildlife and Wildlife Observations at the Proposed Site

Many species of wildlife have adapted to living in areas that are densely populated with 

humans. Canada geese, gulls, pigeons, European starlings, songbirds, and a wide variety 

of other birds, mammals, and insects flourish in urban and suburban areas. The diversity 

and abundance of urban wildlife is enhanced when urban areas are located near large 

bodies of water. Although many people derive much pleasure from watching birds and 

other wildlife in cities and urban areas, often conflict situations arise that negatively 

affects some aspect of the quality of life for people. Examples of such conflicts include 

bird strikes, parks and recreational areas contaminated with wildlife droppings, and 

damage to landscaping plants around homes and community residences.

Given the proposed site of the North Shore MTS is located on Flushing Bay (Figure 3-2), 

the potential exists for large numbers of many species of birds associated with marine 

and/or urban environments to be present on or near the proposed building site. 
12

Figure 3-2. Site location for the proposed North Shore MTS near College Point, 

Queens, New York. The proposed site is approximately 2,200 feet from LaGuardia

Airport. 

Historical and current observations of birds clearly demonstrate that gulls and other birds 

are frequently present in large numbers within the general vicinity of the proposed North 

Shore MTS site. During 2004–2009, a program was implemented at LaGuardia Airport 

to monitor and assess wildlife hazards to aviation. Ducks, geese, and gulls comprised the 

majority of birds observed on or near LaGuardia Airport (Figure 3-3). In addition, on 

several occasions members of the technical panel of experts and other wildlife 

professionals observed gulls at several locations adjacent to LaGuardia Airport and in the 

immediate vicinity of the proposed North Shore MTS site. For example, observations of 

gull use of mud flats near LaGuardia Airport were collected by members of the technical 

panel of experts. These observations are consistent with previously documented gull 

activity gathered during wildlife monitoring at LaGuardia Airport. Additionally, longterm monitoring data collected at LaGuardia Airport (2004−2009), in addition to other 

studies of birds within the New York City area, clearly show that bird activity and 

abundance within these environments is dynamic and likely influenced by several 

environmental factors, such as weather patterns, tidal cycles and other seasonal 

influences (e.g., LaGuardia Airport Wildlife Hazard Assessment and Shooting gulls to 

reduce strikes with aircraft at John F. Kennedy International Airport, 1991−2008).
13 44% 36%

3% 9% 7%

1%

Gulls Other Birds

Blackbirds & Starlings Doves & Pigeons

Small Perching Birds Ducks & Geese

Figure 3-3. Birds observed during a long-term monitoring program to assess 

wildlife hazards at LaGuardia Airport during 2004–2009. 

On December 15, 2009 the technical panel of experts (including agency representatives 

from FAA and USDA) conducted a site visit at the proposed North Shore MTS location 

to gather information and conduct general observations about the proposed location. 

Observations of available habitat and the types of wildlife that were currently using the 

location were made. The group gained first hand knowledge of current conditions at the 

proposed site (including information about habitats, wildlife activity, and other important 

factors) and about the proximity of this site to LaGuardia Airport. 

An evaluation of bird activity at the site of the proposed North Shore MTS was needed to 

assess „background‟ levels of bird abundance and activity at the site (without an active 

trash-transfer station in existence). Standardized bird surveys were conducted by 

professional wildlife biologists during February and March of 2010 at the proposed MTS 

site to gain insight into bird activity at or near the proposed building site. During these 

surveys, all bird species observed within the area were identified and the number of birds 

and behaviors exhibited were recorded. The data from these efforts were summarized to 

provide insight into the „background‟ bird activity of at the proposed site, with particular 

consideration of birds that are recognized as being hazardous to aircraft operations. 
14

During the 18 standardized bird surveys conducted, 396 birds [consisting of 308 gulls, 

72 pigeons (Figure 3-4), and 16 European starlings (Figure 3-5)] were observed in the 

vicinity of the proposed North Shore MTS site (Table 3-3). Of the birds seen near the 

proposed site, only 1% of the birds were using the former North Shore MTS building. 

On one occasion, several pigeons were observed flying into the former transfer station 

building to roost. The gulls observed during the surveys, which consisted of a mixture of 

herring gulls (Figure 3-6) and ring-billed gulls, were flying over the proposed site or 

perched on the roof of the New York City Department of Sanitation‟s truck repair and 

maintenance facility building. This building is adjacent to the site of the proposed North 

Shore MTS. 

Figure 3-4. House sparrows (left photo) and pigeons (right photo) are often pests at 

trash-transfer stations and other facilities where solid waste is received and 

processed. 

Figure 3-5. A European starling. Introduced into Central Park in New York City

during the late 1800s, this bird has spread across North America. Today the 

starling population in the United States exceeds 100 million.
15

Table 3-3. Average number of birds (of selected species) observed per hour of 

survey time within 0.25-mile of the proposed North Shore MTS site located near 

College Point in Queens, New York during 18 standardized bird surveys conducted 

in February and March of 2010.

Bird Species

Average Number Observed Per 

Hour of Survey Time

Herring Gull 62

Ring-billed Gull 40

Pigeon 24

Figure 3-6. Two adult herring gulls. Herring gulls (and other gull species) use 

waste management facilities, such as trash-transfer stations and landfills, as a place 

to find food.
16

3.3. Design Features of the Proposed North Shore MTS Facility

As currently proposed, the facility will be a fully enclosed transfer station building with 

four walled sides and a pitched roof (Figure 3-7). It will be a three level, over water 

facility specifically designed for the indoor transfer of solid waste from collection 

vehicles into sealed leak-proof containers. Each container will be sealed and cleaned 

then loaded onto barges for transfer to a final disposal site outside of the New York City 

metropolitan area. 

Not-to-exceed permit limits for the North Shore MTS are based on a weekly and 

maximum peak tons per day of solid waste. The expected average daily throughput is 

2,200 tons of municipal solid waste and up to 1,000 tons of commercial waste. The 

proposed weekly limit is 21,840 tons. A 20% allowance is included for seasonal 

variability, growth in waste generation and system redundancy. The proposed maximum 

peak tons per day limit is 3,672 tons and it addresses DSNY post-holiday collections.

Design features of the proposed transfer station facility include:

• Waste will be delivered to the transfer station facility inside closed collection vehicles 

(i.e., curbside garbage trucks). 

• All trucks will enter and exit the transfer station building through rapid, roll-up doors. 

• A truck scale, ramps, and the tipping floor inside the building are all designed to 

minimize the number of trash trucks that are entering and exiting the building, 

particularly during peak hours. 

• All waste will be processed in an enclosed building that maintains negative air 

pressure to prevent odors from escaping while building doors are open. In addition, 

exhaust air from the transfer station building will be treated using an odor neutralizing 

system. 

• Each container will be sealed and cleaned inside the transfer station building.

• All waste will leave the North Shore MTS in sealed, leak-proof containers and all 

containers will also enter and exit through rapid roll-up doors.
17

3.4. Operational Procedures of the Proposed North Shore MTS Facility

As currently proposed, all solid waste would arrive via covered trucks that enter the 

facility through rapid roll-up doors and dump the waste from a high level tipping floor 

down to a lower level loading floor (Figure 3-7). Next, waste would be loaded into 

containers that are sealed and cleaned in the lidding / unlidding area. Lastly, the 

containers would leave the MTS building through rapid roll-up doors and be placed onto 

barges for the next stage of transportation. 

Operational procedures to be used at the proposed facility include:

• No solid waste will be processed or stored outside of the transfer station building.

• The tipping floor will be cleaned daily.

• All vehicles will be cleaned prior to exiting the building. 

Figure 3-7 Cross-sectional schematic of the proposed North Shore MTS.
18

3.5. Examination of Currently Operating Trash-transfer Facilities

In an effort to predict what type of attraction to wildlife the proposed North Shore MTS 

might be if it were to be constructed and put into operation, other trash-transfer facilities 

in the greater New York City metropolitan area that are currently in operation were 

identified and examined. 

On December 15, 2009 the technical panel visited the Harlem River Yard Transfer 

Station, located in the Bronx. During the site visit, the panel observed how this transfer 

station is operated, considered how the building was designed, and attempted to 

determine to what extent the facility and its operational procedures attracted birds.

On the same day the technical panel of experts traveled to the Staten Island Transfer 

Station (Figure 3-8), located in Staten Island, New York. This facility is an example of a 

trash-transfer station that is very similar to the proposed North Shore MTS. As a whole, 

the group observed that opportunities for the facility to act as an attractant to wildlife 

were limited. This appeared to be a result of the basic design of the facility in that little 

opportunity was available for wildlife to use the structure or access portions of the waste 

transfer operation. However, the group decided that it would be in the interest of the 

project to collect additional short term data at this location to document possible wildlife 

attractant issues that may not have been discerned during this visit.

During February and March of 2010, a total of 6 standardized bird surveys were 

conducted by professional wildlife biologists at the Staten Island Transfer Station to gain 

information regarding the attractiveness/use of that trash-transfer facility by birds 

hazardous to aviation and to assess the overall bird activity in the immediate vicinity of 

the transfer station. All bird species observed within the area of the transfer station 

(within 0.25 miles of the facility) were identified, counted, and recorded during these 

surveys. In addition, the behaviors exhibited by birds (in particular birds observed using 

the trash-transfer station (either perching on or in the building or directly feeding on 

trash) were noted and documented. These data were summarized to provide insight into 

the „background‟ bird activity at the site and to what degree birds used the transfer station 

facility, in particular those birds recognized as being hazardous to safe air operations.

An hourly average of 41 birds (all species combined) were observed using the Staten 

Island Transfer Station, based on surveys conducted during February and March of 2010 

(Table 3-4). Birds were considered to be using the transfer station if they were observed 

feeding on or in the refuse present or were perched on or in the transfer station building. 

Gulls (primarily herring gulls and great black-backed gulls) comprised most of the birds 

seen near the Staten Island Transfer Station (Table 3-4). However, even though (on 

average) 140 gulls were observed per hour of survey time, less than 1 gull per hour was 

seen „using‟ the transfer station. Gulls commonly used the waterway adjacent to the 

transfer 
19

Figure 3-8. Standardized bird surveys were conducted at the Staten Island Transfer 

Station, a truck-to-rail transfer station facility located in Staten Island, New York. 

The building design and operational procedures of this facility are similar to those 

of the proposed North Shore MTS. 

station property but appeared to show little interest in the facility and the waste

management activities that occurred inside the building.

European starlings (Figure 3-3) accounted for 26% of the birds observed using the Staten 

Island Transfer Station. On average, ten starlings were observed feeding on trash while it 

was being processed inside the Staten Island Transfer Station building each hour. Recent 

research conducted by USDA showed that starlings accounted for approximately half of 

all birds that used trash-transfer stations to search for food and find places to nest. 

An hourly average of 12 pigeons (Figure 3-2) were observed at the Staten Island Transfer 

Station (Table 3-4). Almost all of the pigeons seen at the facility were feeding on the 

trash inside the transfer station building. These birds are often considered a pest and 

cause problems in buildings and other man-made structures through corrosion and 

disease concerns caused by fecal contamination and nesting debris.

Starlings and pigeons are a concern in regard to aviation safety issues and commonly 

collide with aircraft. Starlings and pigeons are important birds to consider when 

assessing bird strike risks, as they have been involved in collisions with both civil and 

military aircraft that have resulted in human fatalities.
20

Approximately one-half (49%) of the birds observed using the Staten Island Transfer 

Station were house sparrows (Figure 3-2), which were frequently feeding on the trash 

inside of the transfer station building (Table 3-4). Although these birds are considered a 

pest and have the potential to cause problems for transfer station operators and 

employees, they are not considered a substantial problem in regard to bird strikes. 

Table 3-4. Average number of birds (of selected species) observed per hour of 

survey time within 0.25-mile of the Staten Island Transfer Station located in Staten 

Island, New York and the average number of birds per hour of survey time using 

the transfer station during 6 standardized bird surveys conducted in February and 

March of 2010.

Bird Species

Average Number of Birds 

Observed within 0.25-mile of 

the Transfer Station Per Hour 

of Survey Timea

Average Number of Birds 

Observed Usingbthe 

Transfer Station Per Hour 

of Survey Time 

Herring Gull 165 < 1

Great Black-backed Gull 69 < 1

Ring-billed Gull 6 < 1

European Starling 19 10

Pigeon 12 11

House Sparrow 21 20

a All birds observed within 0.25 miles of the Staten Island Transfer Station building 

were counted and recorded. 

b Birds that were perching on or in the transfer station building or were seen 

feeding on refuse were considered to be using the transfer station.
21

3.6. Risk Assessments 

Effective decision making about how the proposed North Shore MTS facility might

attract birds and become a hazard to aviation operations can be assisted by conducting a 

risk assessment process and portraying available alternatives in a risk matrix. Figure 3-9

illustrates a series of three alternatives related to the proposed North Shore MTS. 

The three alternatives that were considered in the risk assessment process were:

(1) No MTS facility (i.e., the present situation);

(2) North Shore MTS as proposed in the Part 360 application;

(3) North Shore MTS with modifications to the building design & operational 

procedures and the development and implementation of a wildlife hazard 

management program.

These risk assessments only consider the risk posed to safe aircraft operations at 

LaGuardia Airport by birds (i.e., primarily gulls) using the site where the proposed North 

Shore MTS would be located. This risk assessment does not specifically refer to the 

overall risk posed to aircraft operations to and from LaGuardia Airport by birds that 

could be present throughout the general vicinity of the airport, but considers this factor 

(dynamic, area-wide bird populations) within the site-specific assessment of risk.

Sizable populations of gulls and other birds are commonly found in highly urbanized 

areas in coastal environments. Historic and current observations, in addition to the 

frequency that gulls are struck by aircraft at or near LaGuardia Airport, clearly 

demonstrate that gulls and other birds that pose a hazard to air operations are commonly 

present where the proposed MTS has been sited. Bird activity and abundance within 

these environments are dynamic and influenced by numerous factors and conditions 

(including, but not limited, to weather patterns, tidal cycles, seasonal influences, and the 

availability of natural foods). Previous research has shown that bird use of trash-transfer 

facilities varies among different times of the year. Consequently, risk assessments must 

consider differing levels of the abundance and activity of birds hazardous to safe aircraft 

operations. 

Overall, the highest risk posed to safe aircraft operations by birds would likely occur if a 

MTS was constructed and operated at the proposed site with no consideration of wildlife 

issues. This level of risk would be associated with increased bird movements (primarily 

gulls) flying to and from the MTS, in particular if these movements occurred within the 

flight paths of aircraft approaching or departing from LaGuardia Airport. By 

incorporating modifications to the MTS building design and implementing changes to 

operational procedures (see Section 4. Recommendations) that dissuade birds from using 

the MTS, the probability of birds and other wildlife being attracted to the facility would 

be reduced (compared to a facility with no modifications), resulting in a lower level of 

risk associated with bird strikes. The lowest level of risk to aircraft operations posed by 

birds would occur when a MTS (with design and operational procedure modifications) 

was operated with an integrated wildlife hazard management program. 
22

Figure 3-9. Assessment of the risk to aviation safety for aircraft using LaGuardia 

Airport under three alternatives related to the proposed North Shore MTS.

Alternative 1

a

No facility 

(present situation)

Alternative 2

b

Proposed facility

Alternative 3

c

Proposed facility 

with modifications 

and wildlife hazard 

management plan

Hazardous 

Bird Activity

High High Low

Medium Medium Low

Low Low Low

Risk Levels

a Alternative 1: represents the present situation (no MTS facility).

b Alternative 2: represents the MTS as proposed under the Part 360.

c Alternative 3: represent the MTS with building design and operational procedure 

modifications and the implementation of a wildlife hazard management plan. 

3.7. Determination of Findings

The FAA and USDA, with full consensus from the technical panel of experts, determined 

that Alternative (3) Modifications & Monitoring/On-site wildlife hazard management 

activities, would provide the safest, most acceptable alternative in regard to the 

compatibility of the North Shore MTS. By incorporating modifications to the building 

design, implementing operational procedures, and developing and conducting an 

integrated wildlife hazard management program, the risk of bird strikes could be greatly 

reduced when compared to the present situation (that is, no MTS facility present and no 

mitigation of wildlife hazards at the proposed North Shore MTS site).
23

4. RECOMMENDATIONS

Reduction of hazards to aviation safety posed by birds that might be attracted to the 

proposed North Shore MTS can be accomplished through the incorporation of building 

design modifications, adherence to strict operational procedures, and the development 

and implementation of an integrated wildlife hazard management plan and program. The 

FAA, USDA, and members of the technical panel of experts conclude that the 

recommendations provided will achieve compatibility between the North Shore Marine 

Transfer Station and LaGuardia Airport with respect to bird strikes and safe air 

operations. 

The following recommendations provide a framework for proactive monitoring and 

mitigation of wildlife hazards to aviation at the proposed North Shore MTS:

Planning and Construction Phases:

• Develop an integrated wildlife hazards management plan for the MTS facility.

• Eliminate ledges and other perching sites in the building design to the greatest extent 

possible. As an example, signage on the building should not use raised letters as this 

provides perching and nesting sites for European starlings and house sparrows. 

• Install anti-perching devices on the transfer station roof, pilings, and other surfaces 

where birds might perch.

• Strict enforcement of a “no feeding wildlife or feral animals” policy.

• Ensure landscaping plants and materials are selected to be non-attractive to wildlife 

(such as minimizing grassy areas which might attract Canada geese).

Fully Operational Transfer Station:

• Implement an integrated wildlife hazards management program for the MTS facility.

• Provide a dedicated (i.e., only duties) wildlife control professional trained and 

equipped to mitigate bird use of the transfer station as issues develop (i.e., proactive 

approach).

• Strict enforcement of a “no feeding wildlife or feral animals” policy.

• Monitor trash containers to ensure no trash is extruding from them prior to leaving the 

transfer station building.
24

• Monitor barge activity for birds that might be attracted to them (due to water 

disturbance and/or the refuse containers) and mitigate accordingly.
25

5. SOURCES OF INFORMATION

Guidance:

Advisory Circular No: 150/5200–33B, Hazardous Wildlife Attractants On or Near 

Airports

Advisory Circular No: 150/5200–34A, Construction or Establishment of Landfills Near 

Public Airports

14 Code of Federal Regulations Part 77 Notification of Proposed Construction or 

Alteration on Airport 

40 Code of Federal Regulations Part 258 – Criteria for Municipal Solid Waste Landfills 

Wildlife Hazard Management at Airports - A Manual for Airport Operators – 2

nd edition, 

2005

Reports:

Evaluation of Trash-transfer Facilities as Bird Attractants, Report No. DOT / FAA / 

 AR-09 / 62, 2009

Wildlife Strikes to Civil Aircraft in the United States 1990–2008 – Serial Report No. 15, 

2009

FAA National Wildlife Strike Database (available at: http://wildlife.faa.gov)

LaGuardia Airport Wildlife Hazard Assessment, 2000

Shooting Gulls to Reduce Strikes with Aircraft at John F. Kennedy International Airport,

1991−2008. Special Report for the Port Authority of New York and New Jersey by 

U.S. Department of Agriculture, National Wildlife Research Center, 2009. 

USDA/APHIS/Wildlife Services New York – Site Visit Letter for LaGuardia Airport, 

 1 June 2009

USDA/APHIS/Wildlife Services New York – Site Visit Letter Regarding North Shore 

MTS to FAA Eastern Regional office of Safety and Standards Branch, 4 June 2009

USDA/APHIS/Wildlife Services New York – Wildlife Hazard Monitoring Program 

Annual Reports for LaGuardia Airport (2004–2007, 2008, and 2009)
26

Proposed Facility:

Engineering Report for the North Shore Marine Transfer Station Waste Containerization 

Facility – Part 360 Permit Application, Volume 1, City of New York Department of 

Sanitation, January 2007
27

APPENDIX A. Listing of the members of the technical panel of experts for the 

evaluation of the North Shore Marine Transfer Station and its compatibility with 

respect to bird strikes and safe air operations at LaGuardia Airport.

Brian E. Washburn, PhD (Report author)

Research Biologist

USDA / APHIS / Wildlife Services National Wildlife Research Center

John R. Weller (Project Manager, FAA)

National Wildlife Biologist

Federal Aviation Administration

Michael J. Begier (Project Manager, USDA)

National Coordinator, Airport Wildlife Hazards Program

USDA / APHIS / Wildlife Services 

Richard A. Dolbeer, PhD

Science Advisor

USDA / APHIS / Wildlife Services 

Edward C. Cleary

President, WASHMan LLC

Eugene LeBoeuf

Chief, USAF BASH Team

U.S. Air Force 

Laura C. Francoeur

Chief Wildlife Biologist 

Port Authority of New York/New Jersey

Christopher A. Nadareski

Section Chief, NYC Environmental Protection

Bureau of Water Supply/ WWQO/ Wildlife Studies Section
28

APPENDIX B. Listing of the scientific names of all animals mentioned in this 

document.

Common Name Scientific Name

Canada goose Branta canadensis

European starling Sturnus vulgaris

Great black-backed gull Larus marinus

Herring gull Larus argentatus

House sparrow Passer domesticus

Pigeon Columba livia

Ring-billed gull Larus delawarensis