Guidance on how to respond effectively to FAA NPRM on Bird Strike Standards

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bird22Oddly though aviation traces its roots to mimicking birds, the below article and this FAA NPRM on Bird Strike Requirements for Transport Category Airplanes discuss the problems when ornithology intersects with aeronautical engineering.

The FAA has asked for comments about whether the Part 25 design standards (14 CFR §§ 25.71 , 25.631) should be revised. Certainly the US Flight 1549 landing in the Hudson raised the awareness of this risk, but the recent trends in bird strikes as reported in a 2014 Report are the primary reason for this regulatory review.


The FAA has done a lot to mitigate the threat of wildlife at airports (like this picture of a gun being fired to scare birds from runways and other efforts to separate the birds from airplanes). The NPRM effort is intended to examine the airworthiness standards, in particular, whether the current testing standards require revisions to reflect the data which has been accumulated. Questions posed in the Federal Register are intended to get expert opinions on what aircraft windshields and structural elements should be able to sustain when birds strike:

  1. Should the bird weight requirement be applied consistently across the airplane?
  2. Should the bird weight requirement be increased, to eight pounds or some other value?
  3. Should a “no-penetration” requirement be applied to the entire fuselage, not just the windshields?
  4. Should the bird strike criteria be expanded to 10,000 feet?
  5. Should the 0.85 speed reduction factor at 8,000 feet, currently specified in Sec. 25.571, be removed?
  6. Should the speed criterion for bird strikes be based on VMO (maximum operating limit speed) rather than VC (design cruise speed)?

If you have material which you believe is relevant to this NPRM and if you believe that your opinion should be incorporated in a potential Part 25 revision, here are some suggestions on how to submit comments to the docket:

a. It is an excellent idea to submit your comments on a timely basis (November 17, 2015). If that date is impossible to meet for good reasons (it is not enough that you are busy) you may submit a written request for delay. The letter/email should be sent, as soon as possible, to:

Todd Martin
Airframe and Cabin Safety Branch, ANM-115, FAA
Transport Airplane Directorate, Aircraft Certification Service
1601 Lind Avenue SW, Renton, WA 98057-3356
Telephone: (425) 227-1178
Fax: (425) 227-1232

b. Your comments should be sent by 11/17/2015 to a different address:

  • Federal eRulemaking Portal: Go to and follow the online instructions for sending your comments electronically.
  • Mail: Send comments to Docket Operations, M-30; U.S.Department of Transportation, 1200 New Jersey Avenue SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001.
  • Hand Delivery or Courier: Take comments to Docket Operations in Room W12-140 of the West Building Ground Floor at 1200 New Jersey Avenue SE., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays.
  • Fax: Fax comments to Docket Operations at 202-493-2251.

c. It is important to write your comments in terms which are common to the FAA staff persons, that means;

  • It is wise to cite and follow the language of the FARs, any ACs, the Handbooks, etc. These are terms of common reference to your audience.
  • Recognize that your expertise is likely to be greater than your reader.
  • Do not assume that the vocabulary, technical knowledge, research, etc., which is basic to your discipline, will be immediately understood by the readers of your comments.
  • Take the time to explain the complexities of your position. It may be helpful to include/attach/cite important sources which support your assertions.
  • Most experts discuss their technical topics with peers by moving from major conclusions to the next premise. It is useful to walk through the minor premises which buttress your conclusions; it will help their acceptance of your position.
  • While many of these suggestions tend to lead towards a lengthy paper. Try to balance brevity against completeness.
  • The most powerful method of impacting the final standards is to contribute to a paper submitted by a group, institution or association. The imprimatur of an organization carries weight with the FAA.
  • One very effective tactic is to actually draft substitute language for §§ 25.571 , 25.631 which reflects the point of your comments.

This FAA NPRM is quite open to suggestions; witness the six questions listed above. Unlike many such notices, the FAA staff has not concluded as to what the right answer may be. Thus, they are reaching out for ideas of how to improve Part 25. Any change, which the FAA adopts in any final rule, must have strong data or evidence to justify an amendment. The point of this NPRM is to collect such information FROM YOU.


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