Balancing Wildlife Hazard Concerns and Stormwater Management at

Airports

GAA Spring WorkshopFebruary 27, 2015

Kim M. Allerton, PresidentEnvironmental Resource Solutions, Inc.

Most Famous Bird Strike: “Miracle on the Hudson”

January 15, 2009

History: Wildlife Hazards at Airports• Documented since 1905

• Tracked by USDA/FAA since 1990

• Since 1960:• 160 civil aircraft destroyed

• 49 destroyed from 2001 through 2010 alone

• Globally, wildlife strikes have killed more than 250 people and destroyed over 229 aircraft since 1988.

• Dramatic INCREASE in strikes over the last 50 years... WHY?

History: Wildlife Hazards at Airports

Three major reasons for an increase in wildlife strikes:

1. Aircraft are built to fly quieter and more efficiently than in the past

2. Airplane travel is commonplace worldwide = a lot more planes

3. Environmental protection legislation (from 1960s to present) is working! Unprecedented period of successful population recovery for deer, geese, pelicans, eagles, alligators, etc.

FAA National Wildlife Strike Database (wildlife.faa.gov)

• Began in 1990, made public in 2009

• Approximately 40% of all wildlife strikes are reported• 1990 = 1,851 reported strikes

• 2012 = 10,726 reported strikes

• Birds involved in 97% of all strikes

• Damaging strikes have decreased!• 764 in 2000 and only 606 in 2012

FAA National Wildlife Strike Database (wildlife.faa.gov)

• Species-groups that cause the most damage to aircraft:• Waterfowl

• Gulls

• Raptors

• Deer

Stormwater Regulations and Requirements

Direct conflict between mitigating stormwater run-off and discouraging wildlife from using airfields

• Retention Basin

• Detention Basin

• Conveyance swales/ditches/canals

• Littoral Zones

ACRP 09-08Balancing Airport Stormwater and

Wildlife Hazard Management:Analysis Tools and Guidance

Problem StatementAirports are required to manage the quantity and quality of stormwater within their property to comply with a variety of federal, state, and local regulations. These requirements drive the need for stormwater best management practices (BMPs), many of which can be classified as hazardous wildilfe attractants due to their attraction of wildlife that poses a strike risk to aircraft, including water-dependent birds. Simultaneously, the FAA requires that airports provide for the safety of aircraft operations. Airports are in the need of guidance, tools, and further research to facilitate understanding of potential wildlife risk factors and decision making to mitigate these risk factors.

Objectives of ACRP 09-08 Develop tools and guidance for Airports that identify and evaluate

stormwater management options and provide a set of best management practices to minimize hazards posed to aviation by birds. Tools and guidance should include:1. Synthesis of existing airport stormwater management options.2. Review of Federal guidance and regulations pertaining to stormwater

management, wetlands, hazards posed to aviation by wildlife, and natural resource conservation relevant to airport stormwater management options, including a discussion of any ambiguities/conflicts among them.

3. Sample checklist of potential state and/or local environmental considerations that apply to stormwater management and may conflict with wildlife hazard management.

4. A bird strike risk analysis tool to provide a risk score for each stormwater management option considered.

5. A stormwater management decision tool to allow users to identify a preferred stormwater management plan using the results from the bird strike risk analysis tool.

6. A minimum of 2 case studies.7. Stakeholder outreach materials.

Approach to Tool Development

Safety Management Systems (SMS) Risk Process Steps:

Step 1 - Describe the system (Stormwater BMP);

Step 2 - Identify the hazards (Birds);

Step 3 - Determine the risk;

Step 4 - Assess and analyze the risk;

Step 5 - Treat the Risk

Step 6 - Manage the Risk

Risk is the product of two factors:

LIKELIHOOD&

SEVERITY

Risk Matrix• Based on FAA 8040.4A “Safety Risk Management

Policy”• 5 X 5 Matrix• High Risk Levels modified to be more consistent with other

models and SMS Pilot Process

• Based on Likelihood (Frequency/Probability) and Severity • Likelihood = based on proximity of birds and their history of

proximity to aircraft• Severity = based on size and number of birds (Mass) and the

attractiveness of the stormwater feature to the Mass • Multiple factors of Each

• Each Factor independently adds to the Total Risk• Three levels of Risk

• Low, Moderate, High• Within each level, relative risk is quantified

Definition of Risk Levels

Risk Levels Definition Example Consequences to Aircraft Suggested Actions

L (Low): Risk < 5Mitigation may

not be necessary

None or minor flight delay, no injuries, damage can be

repaired immediately

Controls such as elimination, substitution, isolation, and barriers are still preferable, but these hazards may rely more on warnings, administrative and other devices that may require operator intervention.

M (Moderate): 5 < Risk < 15Mitigate on a priority basis

Major flight delay, change planes, injuries

Controls such as elimination, substitution, and engineering controls are preferable. If reliance on warnings and administrative controls only, these should be redundant to additional controls, or additional barriers, guards and other protective devices. Continuously monitor controls for effectiveness.

H (High): Risk > 15Mitigation is

requiredLoss of Aircraft. Loss

of life.

Use controls or multiples of controls, such as elimination, substitution, or engineering controls, controls with built in redundancies, physical devices that do not require adjustment or operator intervention, or provide positive, ongoing indicators of operation. Continuously monitor controls for effectiveness.

Risk Matrix developed for ACRP 09-08

Risk Matrix (See Table Below Risk Matrix for a Definition of Risk Levels)

FREQUENT PROBABLE REMOTEEXTREMELY

REMOTEIMPROBABLE

5 4 3 2 1daily - weekly sightings (year

round)

daily to weekly sightings -

seasonal only

weekly to monthly sightings

weekly to monthly sightings

(seasonal only)Annual sightings History of Observations

on the runway or RPZ in flight

on the runway on the ground

on the AOAwithin airport

propertyoff airport property Proximity of Bird Sightings

>75% 50-75% 10-50% 5-10% <5%Percentage of Total Airport Bird Strikes Associated with Species

> 2 SD above national average

Between 1 and 2 SD above

national average

Within 1 SD of national average

Between 1 and 2 SD below national

average

< 2 SD below national average

History of Total Bird Strikes per Operations Compared to National Average

AOA <5000 ft 5000 - 10,000 ft 10,000 ft - 5 mi > 5 milesProximity of BMP to Airport Movement Areas

NEGLIGIBLE 1 1 < 12Irregularity <=

1.11:1 none ≥ 5 mi 100% 5.0 4.0 3.0 2.0 1.0

MINOR 2 2 > 12< 241.1 <

Irregularity <= 2.8

2:1 3.75 - 5 mi 0% 10.0 8.0 6.0 4.0 2.0

MAJOR 3 3 > 24 < 362.8 <

Irregularity <= 4.6

3:1 2.5 - 3.75 miless than 16.5% OR greater than

83%15.0 12.0 9.0 6.0 3.0

HAZARDOUS 4 4 > 36 < 484.6 <

Irregularity <= 6.4

4:1 1.25 - 2.5 mi16.5% to

32.9% OR 66.1% to 83%

20.0 16.0 12.0 8.0 4.0

CATASTROPHIC 5 5 >48 61Irregularity >

6.4>=5:1 < 1.25 mi 33% to 66% 25.0 20.0 15.0 10.0 5.0

BMP - Proximity of

Water Bodies (from each other)

Incorporates Mass of Bird and Flock Size by Reported Adverse Effects to A/C

Weighted Hazard Ranking Severity

Relative Hazard Score (Adjusted to

exclude mammals)

Likelihood (Frequency) Factors - (Proximity to aircraft)Severity Factors (hazard of birds volume/mass of birds attracted)

Severity Levels

BMP - Apparent Slope to Water's Edge

Relative Hazard Score - Species

BMP - Percentage of Stormwater Vegetation Coverage

BMP - Perimeter Irregularity

Severity Factors from Risk Matrix

1. Species: Select species of greatest concern and tool auto-populates standardized relative hazard score (Devault et. al., 2011)

2. BMP – Perimeter Irregularity: The ratio of the pond perimeter to the perimeter of a perfect circle of equal area

3. BMP – Apparent Slope to Water’s Edge: Horizontal run (H): Vertical rise (V)

4. BMP- Proximity of Water Bodies (from each other): Distance between additional water bodies (i.e. natural or manmade ponds/wetlands/rivers) in the vicinity of the surface water being evaluated in the tool. Use closest water body.

5. BMP – Percentage of stormwater vegetation coverage: ow:ew is the ratio of area of open water to area of emergent and woody vegetation

Likelihood Factors from Risk Matrix

1. History of Observations: How often the species of concern is observed by airport staff

2. Proximity of Bird Sightings: Where the species are being observed in relation to the runway

3. History of Strikes: Total percentage of strikes from strike database for species being evaluated (only evaluate strike data within the last 5 years)

4. Proximity of BMP to airport movement areas: where is the BMP in relation to the AOA (using FAA recommended separation distances from AC 150/5200-33B)

Step 1 – Input Bird Data

Species Hazard

RankingHistory of Observations

Proximity of Bird Sightings

Number of Strikes

Percentage of Total Airport Bird Strikes

Associated with Species

Species # 1 Osprey 3daily - weekly sightings (year

round)on the runway on the

ground115 50-75%

Species # 2 Ring-billed Gull 2daily to weekly sightings -

seasonal onlyon the runway or RPZ in

flight52 10-50%

Species # 3 Canada Goose 4daily to weekly sightings -

seasonal onlyon the AOA 15 5-10%

Species # 4 Herring Gull 3daily to weekly sightings -

seasonal onlyon the AOA 11 5-10%

Species # 5 Blackbirds 1daily to weekly sightings -

seasonal onlyon the AOA 8 <5%

Species # 6 Other Geese 5

Species # 7 Sandhill Crane 3

Species # 8 None 2

Species # 9 None 2

Species # 10 None 2

Species of Concern

SEVERITY Factor LIKELIHOOD Factors

BIRD OBSERVATION DATA

Factor Confidence

History of Observations Low

Proximity of Bird Sightings LowHistory of Strikes High

Total number of bird strikes entered for species of concern in the Bird Observation Data Table

201

History of Total Bird Strikes per Operations Compared to National

Average

> 2 SD above national average

Number of aircraft operations 5,939,477

AIRPORT OPERATIONS

BIRD DATA CONFIDENCE

Total bird strikes for Water Dependent Bird Species

11

212

BIRD STRIKES

Is there bird strike data for Water Dependant Bird Species that you did not include in the Bird Observation Data Table?

Yes

Total bird strikes for Water Dependent Bird Species that were NOT Listed as a Species of Concern in the Bird Observation Data Table

Mitigations (aka Controls)• Mitigations, both existing and new, impact initial and

residual risk, respectively.• Hierarchy of Mitigations include:

• Elimination (most effective)• Substitution• Engineering• Warnings • Administrative (least effective)

• Failure Modes and Effects Analysis (FMEA) concepts were used to determine the risk reductions that can be applied for Mitigations

• Risk reduction increases if the mitigation is ongoing as opposed to applied at the time of sighting only (e.g. an effigy on display is “ongoing” whereas shooting to kill is “upon sighting only”)

Step 2 – Identify Existing Bird Mitigations

Type of Bird MitigationIs Measure

Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Is Measure Used for Species?

Is Measure Ongoing?

Total Substitution 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Engineering: Harrassment (e.g., dogs, falconry)Toxicants; fumigantsAnti-perching devices adjacent to stormwaterCapture and lethally take yesLethal take (shooting) Yes yes yesInstall wire grid across/around pondAlter mowing regimeCapture (trap) and relocateDead bird effigiesInstall bird ballsOtherTotal Engineering Mitigations 0 0 1 0 2 0 0 0 1 0 0 0 0 0

Warnings:Bioacoustics (distress calls)Propane cannons YesVehicle Harassment Yes Yes yes yesVisual deterrentsWarnings from ATC yesOther Yes Yes yes yes yesTotal Warnings Mitigations 3 0 2 0 3 0 1 0 2 0 0 0 0 0

Administrative:Maintain a Wildlife Management Log (data collection) Yes Yes Yes Yes YesSignageWildlife Hazard Management TrainingWildlife Hazard Assessment/Site Visit Yes Yes Yes Yes YesWildlife Strike Reporting Yes Yes Yes Yes YesWildlife control permits Yes Yes Yes Yes YesWildlife patrols/inspections Yes Yes Yes Yes Yes Yes Yes Yes Yes YesWildlife Hazard Management Plan YesOther Yes Yes Yes Yes Yes Yes Yes Yes Yes YesTotal Administrative Mitigations 7 2 6 2 6 2 6 2 6 2 0 0 0 0

Other Geese Sandhill CraneOsprey Ring-billed Gull Canada Goose Herring Gull BlackbirdsSpecies # 1 Species # 2 Species # 3 Species # 4 Species # 5 Species # 6 Species # 7

Mitigation Measures

Wildlife Hazard Management

ADMINISTRATIVE

WARNINGS

ENGINEERING

Step 3 – BMP CharacteristicsExisting

Characteristics

Is the water surface in the BMP fully enclosed? NO (Increases Risk)

Is the BMP designed to fully drain within 48 hours after a storm event? NO (Increases Risk)

What is the area of the BMP water surface when full, in square feet?

27737

What is the perimeter of the BMP water surface when full, in linear feet?

760

BMP Perimeter Irregularity (automatically calculated by the Tool from area and perimeter)

1.1 < Irregularity <= 2.8

What is the apparent slope to water's edge within the BMP?

2:1

Is the length:width ratio (aspect ratio) of the BMP 3:1 or greater?

YES (Desirable)

How close is the nearest BMP to the BMP being analyzed?

< 1.25 mi

How close are airport movement areas to the BMP? <5000 ft

Is there less than 12 acres of combined standing water (6,500 feet) on the AOA? NO (Increases Risk)

What percentage of the BMP open water surface is covered with vegetation (vegetation height above water surface) when BMP is full?

0%

Are the BMP vegetation species wildlife-resistant, as determined through coordination with wildlife biologists or USDA?

NO (Increases Risk)

Does the BMP include only one species of vegetation (monoculture)?

NO (Increases Risk)

BMP Location

BMP Vegetation

Monoculture (single species) vegetation is less attractive to wildlife than vegetation with multiple species of plants.

Guidance

Percentage of open stormwater that is covered with vegetation when the BMP is full of water. When more of the water surface is covered by vegetation (vegetation extends above the water surface), the BMP is less attractive to wildlife.

Vegetation within a BMP may attract hazardous wildlife that has the potential to increase bird strike risk. Wildlife biologists or USDA representatives can be consulted with to determine if existing or proposed vegetative species are attractive to hazardous wildlife. For reference, this Tool includes a list of wildlife-resistant species that was developed by the USDA for the state of Ohio (see "USDA" tab). Users may want to consult with local resources to identify other species that may be appropriate for their region of the Country.

BMPs in close proximity to each other have an increased attractiveness to wildlife. A BMP strategy that involves fewer and larger BMPs may allow for more efficient and targeted wildlife management than a strategy with many small BMPs. This characteristic represents the distance between additional water bodies (i.e. natural or manmade ponds/wetlands/rivers) in the vicinity of the BMP being evaluated in the tool. Use the closest water body.

The closer the BMP is to the airport movement area the more likely birds attracted to that BMP will be at risk for being struck by aircraft.

Several waterbodies in close proximity have an increased attractiveness to birds. More than 12 acres of open water surfaces within the AOA increases the risk of bird strikes.

The area of the BMP water surface is defined as the area (in square feet) of the water surface in the BMP, as measured or estimated by the user assuming that the BMP is full of water. The entered value is used by the tool to calculate BMP irregularity. Various approaches may be used to estimate BMP water surface perimeter, including digital measurements in CAD or web-based mapping applications, manual measurements using a scale or planimeter with a to-scale hard copy drawing, or field measurements.

The perimeter of the BMP water surface is defined as the perimeter (in linear feet) of the water surface in the BMP, as measured or estimated by the user assuming that the BMP is full of water. The entered value is used by the tool to calculate BMP irregularity. Various approaches may be used to estimate BMP water surface perimeter, including digital measurements in CAD or web-based mapping applications, manual measurements using a scale or planimeter with a to-scale hard copy drawing, or field measurements.

BMPs with an exposed sides slope along the water's edge have the potential to grow attractive vegetation. Use a steep side slope to minimize vegetation growth and wildlife access. Side slope is represented by Horizontal run (H) : Vertical rise (V). This value may be estimated based on topographic mapping or field visual estimates.

WSDOT Aviation Stormwater Design Manual recommends a Length to Width (L:W) ratio of 3 or greater to reduce wildlife attractiveness. This parameter may be estimated from a drawing of the BMP by measuring or estimating the longest dimension of the BMP (length) and dividing that by the distance across the BMP perpendicular to that dimension (width). If the result is greater than 3, answer "YES;" otherwise answer "NO."

The water surface in a BMP is considered to be fully enclosed if the BMP is underground or the water surface is completely encapsulated within a structure, with no chance of exposure to birds. This tool assumes that enclosed BMPs are not associated with an increased risk of bird strikes, because the water surface is not visible or accessible to birds. Open basins that have a floating cover or bird balls should answer "NO" to this question, and should add the cover as a mitigation in Step 1.

FAA guidance requires that BMPs draw down within 48 hours. BMPs that retain water for extended periods of time tend to attract more birds. BMP drawdown time may be collected from field observations, design reports, or stormwater modeling data.

BMPs that allow for ponding with an irregular perimeter, similar to a natural water body, are more attractive to wildlife. Use a linear edge to minimize attractiveness. Perimeter irregularity is the ratio of the BMP perimeter to the perimeter of a perfect circle of equal area. This value is calculated automatically by the Tool based on user input of BMP area and perimeter (above).

Water Exposure

BMP Characteristic Questions

BMP Geometry

Step 4 – Identification of Initial Risk and Additional Mitigations

Additional Mitigation Measure

Is New Measure

Ongoing?

Additional Mitigation Measure

Is New Measure

Ongoing?

Additional Mitigation Measure

Is New Measure

Ongoing?

Osprey - Initial Mitigation Count None None Ongoing Multiple None Ongoing Multiple Multiple Ongoing

1 Osprey 16.3 15.6 Alter mowing regime Yes Propane cannons Yes N/A 11.7 Major Remote

Ring-billed Gull - Initial Mitigation Count 1 None Ongoing Multiple None Ongoing Multiple Multiple Ongoing

2 Ring-billed Gull 12.6 11.3Install wire grid

across/around pondYes

Bioacoustics (distress calls)

Yes N/A 8.8 MajorExtremely Remote

Canada Goose - Initial Mitigation Count Multiple None Ongoing Multiple None Ongoing Multiple Multiple Ongoing

3 Canada Goose 16.4 14.4 N/A N/A N/A 14.4 Hazardous Remote

Herring Gull - Initial Mitigation Count None None Ongoing 1 None Ongoing Multiple Multiple Ongoing

4 Herring Gull 13.9 13.2 Lethal take (shooting) Yes Propane cannons N/A 9.5 MajorExtremely Remote

Blackbirds - Initial Mitigation Count 1 None Ongoing Multiple None Ongoing Multiple Multiple Ongoing

5 Blackbirds 8.6 7.6Install wire grid

across/around pondYes Warnings from ATC N/A 5.7 Minor

Extremely Remote

Mitigation: ENGINEERING Mitigation: WARNINGS

Residual Likelihood

Mitigation: ADMINISTRATIVE

Residual Risk

Residual Severity

Proposed Additional Bird Mitigations And Frequency of MitigationsResidual Risk

(Steps 1-4)Initial Risk(Steps 1-3)

Species of Concern

Initial Risk(Without Existing

Mitigations)

Initial Risk(With Existing

Mitigations)

Step 5 – Proposed BMP Modifications

Is the water surface in the BMP fully enclosed?

Is the BMP designed to fully drain within 48 hours after a storm event?

What is the surface area of your storm water feature in square feet?

What is the surface perimeter of your storm water feature in linear feet?

BMP Perimeter Irregularity (automatically calculated by the Tool from area and perimeter)

What is the apparent slope to water's edge within the BMP?

Is the length:width ratio (aspect ratio) of the BMP 3:1 or greater?

How close is the nearest BMP to the BMP being analyzed?

How close are airport movement areas to the BMP?

Is there less than 12 acres of combined standing water (6,500 feet) on the AOA?

What percentage of the BMP open water surface is covered with vegetation (vegetation height above water surface) when BMP is full?

Are the BMP vegetation species wildlife-resistant, as determined through coordination with wildlife biologists or USDA?

Does the BMP include only one species of vegetation (monoculture)?

Water Exposure

NO (Increases Risk)

< 1.25 mi

NO (Increases Risk)

NO (Increases Risk)

<5000 ft

< 1.25 mi

NO (Increases Risk)

<5000 ft

BMP Characteristic Questions Description of Initial Stormwater BMP Drawdown w/in 48 hours

BMP Design Alternative 3:Insert Description Below

BMP Design Alternative 2: Insert Description Below

BMP Design Alternative 1:Insert Description Below

Initial BMP Design

27737

760

27737 27737

760

YES (Desirable)

2:1

< 1.25 mi

NO (Increases Risk)

<5000 ft

YES (Desirable)

1.1 < Irregularity <= 2.8

YES (Desirable)

2:1

1.1 < Irregularity <= 2.8

YES (Desirable)

2:1

NO (Increases Risk)

0%

NO (Increases Risk)BMP

Vegetation

NO (Increases Risk)

BMP Geometry

BMP Location

0%

NO (Increases Risk)

0%

NO (Increases Risk) NO (Increases Risk)

NO (Increases Risk)

See Table Below for Residual Risk Associated With BMP Alternatives

1.1 < Irregularity <= 2.8

760

Fully enclosed

NO (Increases Risk)

NO (Increases Risk)

YES (Desirable)

Enter Area and Perimeter Values Above To Calculate Perimeter Irregularlty

Input your own notes describ ing the change or alternate approach

Step 5 (cont.) – Identification of Residual Risk

Existing Risk Existing Severity

Existing Likelihood

Residual RiskResidual Severity

Residual Likelihood

Residual RiskResidual Severity

Residual Likelihood

Residual RiskResidual Severity

Residual Likelihood

1 Osprey

11.7 Major Remote 9.9 Major Remote 1.0 Negligible Improbable 11.7 Major Remote

2 Ring-billed Gull

8.8 MajorExtremely Remote

7.5 MinorExtremely Remote

1.0 Negligible Improbable 8.8 MajorExtremely Remote

3 Canada Goose

14.4 Hazardous Remote 12.2 Major Remote 1.0 Minor Improbable 14.4 Hazardous Remote

4 Herring Gull9.5 Major

Extremely Remote

8.0 MajorExtremely Remote

1.0 Negligible Improbable 9.5 MajorExtremely Remote

5 Blackbirds5.7 Minor

Extremely Remote

4.8 MinorExtremely Remote

1.0 Negligible Improbable 5.7 MinorExtremely Remote

Species Summary

Residual Risk from Step 4(Initial BMP Design With Existing and

Add'l Mitigations)

Residual Risk: BMP Design Alternative 1

(With Existing + Add'l Mitigations)

Residual Risk: BMP Design Alternative 2

(With Existing + Add'l Mitigations)

Residual Risk: BMP Design Alternative 3

(With Existing + Add'l Mitigations)

Bird Strike Summary

Species of Concern

Initial Risk:Initial BMP

(Without Mitigations)

Initial Risk:Initial BMP

(With Existing Mitigations)

Residual Risk: Initial BMP

(With Existing + Add'l Mitigations)

Residual Risk: BMP Alternative

1(With Existing + Add'l Mitigations)

Residual Risk: BMP Alternative

2(With Existing + Add'l Mitigations)

Residual Risk: BMP Alternative

3(With Existing + Add'l Mitigations)

Species # 1 Osprey16.3 15.6 11.7 9.9 1.0 11.7

Species # 2 Ring-billed Gull12.6 11.3 8.8 7.5 1.0 8.8

Species # 3 Canada Goose16.4 14.4 14.4 12.2 1.0 14.4

Species # 4 Herring Gull13.9 13.2 9.5 8.0 1.0 9.5

Species # 5 Blackbirds8.6 7.6 5.7 4.8 1.0 5.7

Regulatory BMP Drivers• BMPs driven by federal, state, local requirements• Requirements vary significantly by location• Variability in design criteria for BMPs:

• Allowable BMP types• Required functions• Design storms / sizing• BMP shape and dimensions• Permanent pool / drawdown time• Vegetation

FAA Wildlife AC 150/5200-33

• FAA criteria for water management facilities:• < 48 hour drawdown, no standing water• Linear edge• Long and Narrow• Steep side slopes• Eliminate attractive vegetation• Separation criteria

• FAA criteria applicable to variety of BMP types• Local/state criteria sometimes conflicts with FAA• Conflicts are not predictable by BMP type

BMP Conclusions for Tool• FAA compliance requires evaluation of BMP

characteristics, regardless of BMP type• Local requirements for BMP types vary• BMP designs may vary from requirements, due to

site constraints or FAA AC• Characteristics that attract or deter wildlife can be

incorporated into any type of BMP• Tool defines BMPs in terms of characteristics with

potential to attract wildlife, rather than BMP type• Tool may be used to discuss conflicts with

regulators and effect on bird strike risk

Problem? Conflicting Missions of Regulatory Agencies

FAA

USFWS

USACE & EPA

USDA

NPSUSFS

NMFS

DOD

STATE Agencies

Wildlife Hazard Mitigation and Natural Resources: Moving

Forward• In 2003, FAA entered into MOA with 5 federal

agencies:

• U.S. Air Force

• U.S. Army

• EPA

• USFWS

• USDA WS

• MOA implies that these agencies must try to better unite their missions for the benefit of aviation safety

Stormwater Regulations and Requirements

• MOA is federal level only and water quality is often regulated by state agencies

• North Carolina passed Senate Bill 229 in 2011• Section 6 directs the Dept. of

Environment and Natural Resources to accept alternative measures of stormwater control at airports (i.e. no ponds or standing water) AND...

• Ponds are no longer required at development sites within 5 miles of an AOA

Questions?