IG’S REPORT CRITICISM OF FAA WILDLIFE HAZARD PROGRAM—INSIGHTFUL OR INANE?

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ARTICLE: FAA Has Not Effectively Implemented its Wildlife Hazard Mitigation Program

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The concept of an Inspector General has great intentions: establish an independent oracle whose job is to examine the work of an operating agency. From this perspective, judgment can be given as to how effective the other agency meets its mission. The IG produces guidance and its wisdom can be adopted.

The IG, however, assesses the action of the subordinate organization with the clairvoyance of hindsight, without a detailed knowledge of the program being examined and without the burden of having to actually meet its mission. The IG’s report on the FAA’s wildlife hazard program demonstrates these inherent distortions of the process.

The report states “We found that FAA’s oversight and enforcement activities are not sufficient to ensure airports fully adhere to Program requirements or effectively implement their wildlife hazard plans.” This statement overlooks the basic reality of the FAA’s current personnel status—the Airports organization is not going to add to its staff anytime in the near or distant future. So, the IG’s criticism that the FAA’s “activities are not sufficient” should be directed at Congress, which has the authority to increase the employees of the airport organization.

Another quote shows that the IG does not understand the rulemaking process, the mission of airports and the current attention which all aviation professionals focus on wildlife hazard. The IG says ” FAA’s policies and guidance for monitoring, reporting, and mitigating wildlife hazards are mostly voluntary, thereby limiting their effectiveness.” The FAA’s regulatory program with multiple layers of reviews consumes between 2 and 5 years between beginning a rulemaking and issuance of a final rule. Issuing voluntary guidance is the most expeditious method to getting better techniques to control wildlife to the airport community. Further, airport directors do not need a gun to their head and do not wait until a final rule is promulgated in order to implement a better way of dealing with animals which create safety risk. There is a sense of urgency that exists in the airport community—the airport staff, the airlines and the tenants—to get control of this problem.

When one reads such superficial, shallow assessments, it is easy to wonder whether the goal of the IG is to help or just to criticize.

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