OIG’s Oversight Overlooks FAA and Local Expertise in Aviation Wildlife Hazards

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ARTICLE: IG Report: FAA Wildlife Hazard Plans Ineffective

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The subject of wildlife management captures considerable attention due to the dire consequences (see above photograph) and the need for local initiatives. Globally, wildlife strikes have killed more than 231 people and destroyed over 220 aircraft since 1988. Factors that contribute to this increasing threat are increasing populations of large birds and increasing air traffic by quieter, turbofan-powered aircraft.

The Office of Inspector General knows better but in this case for some reason fails to comprehend the FAA’s powers and the nature of the wildlife problem. Their conclusions seem to be driven by the notion that for every problem, there is a mandatory rule which the FAA should issue and enforce. Stated from the OIG’s bias about airports, they will not take wise proactive actions unless there is the threat of FAA enforcement.

First, the data does not support the general conclusion that the FAA is doing a bad job. Analysis of the numbers makes it clear that most varieties of flying wildlife (birds in general, but particularly the problematic white pelican and Canadian goose populations) are increasing. The below table shows one such fowl growth:

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What these numbers demonstrate is that the growth in the problem is not primarily attributable to the FAA. Meanwhile, the number of strikes annually reported has increased over 5-fold from 1,804 in 1990 to 10,083 in 2011 (119,917 for 1990-2011) due to the increased diligence and resources invested by the airport industry and the FAA.

The OIG’s second failure to comprehend demonstrates their ignorance of the FAA’s rulemaking powers. Again, they know that any proposal is subject to extensive internal review, then the draft is submitted to the Office of the Secretary for its comments and finally the NPRM is scrutinized by the Office of Management and Budget. The rules are published in the Federal Register; that publication typically draws substantial, substantive comments from airports, airlines, state and local wildlife management departments, animal advocacy groups and the general public. All of that input must be digested, summarized, incorporated (where appropriate) and responded to. Once the draft rule migrates to a final, the labyrinth of FAA, OST and OMB reviews (plus possible iterations) must be walked through again. It takes years to go from concept to implementation. Detailed regulations are not the first choice of most regulators, for obvious reasons, but apparently unfathomable by the OIG.

Last and perhaps foremost, airports are not monolithical scenarios in terms of weather, geography and location, proximity to animal habitats, runway configurations, perimeter and a number of other relevant variables. The airport environment is almost always unique to the local conditions. A solution for airport’s wildlife denizen near a Southern urbane environment, for example, is not likely applicable to different fauna that are causing problem for an airport in an Eastern coastal area. Thus, the FAA’s deference to local solutions recognizes both the incredible variety of problems and the agency’s familiarity with (and trust in) airports executives’ extreme dedication to improving safety.

The examples of Jackson, WY and Johnstown, PA exemplify the involvement of the local or state wildlife experts in designing unique, locally acceptable/effective responses to these threats. If the FAA issued lengthy rules on what needs to be done, that rigidity might have prevented or delayed the reasonable solutions which these airports identified.

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