Wildlife Hazard Policy
Air Line Pilot, April 2001, p.14
By Capt. Rob van Eekeren, VNV—Dutch Airline Pilots Association
Aerodrome control tower: "Cleared for takeoff, mind the birds on the runway."—The birds caused one engine of a B-747-300 to fail and one engine to stall at 40 percent; the airplane returned uneventfully with no casualties. The awareness of the tower controller as well as that of the pilot regarding bird hazards could be improved.
Airport employee: "We know that one single solution for wildlife strikes does not exist. Every situation requires its own specific measures. But management will not give us the money to set up a wildlife-hazard organization to do the job. However, a permanent Notice to Airmen (NOTAM) has been put forward."—Here, airport management does not think it necessary to allocate financial resources for a known problem and accepts the risks involved. Or does it intend, by putting out a permanent NOTAM, to say that the pilot has been warned in case of an accident?
Wildlife specialist: "The increase in environmental protection leads to an increasing quantity of wildlife. Air transport also increases; therefore, the number of accidents will increase."—This predicts higher accident rates in the future because of wildlife strikes.
U.S. ALPA pilot: "We are at the same point today with wildlife as we were with windshear and icing 20 years ago. Will we have to wait (again) for major crashes before measures will be taken?"—Only after some major accidents, with the loss of hundreds of lives and after thorough investigations, were measures taken to counter windshear and icing problems about two decades ago. Ironically, we have the misfortune that we are lucky—a B-747-400 with 500 people on board has not crashed into a suburb as a result of multiple bird hits yet. Although numerous bird strikes have occurred, no accident in recent years has been horrible enough to inspire the worldwide news media to report extensively on this problem. And politicians will react to news media attention. The law is waiting to happen. The question is, can this be avoided by doing the job right, now?
Irish ALPA: "Initially the Dublin court did not find any legal grounds to prevent the construction of a new waste disposal site near the airport. National law was apparently not congruent with ICAO. A contributing factor was that bird hazard-reduction is not a Standard but just a Recommendation in ICAO Annex 14."—This shows the limitations of the Recommendations in the ICAO Annexes—if not translated into national laws, they have no jurisdiction.
Since the beginning of airline travel, profit and safety have been in conflict. However, the airline industry, in its 80 years of existence, has in general managed to find an acceptable balance between these two opposites. This is mainly because the aviation industry has learned a lot from accidents—authorities demanded that action be taken after accidents, but the continuous effort of pilots to strive for safer flights has been a contributing factor.
This everlasting struggle among the airlines, the authorities, the pilots, and other organisations has paid its dividend, and the seesaw of finances and safety is in general balanced.
However, in the last decade, others have joined these two opposites. Nowadays, the environment plays an important role, and recently capacity has become a major player. So at this moment, finance, capacity, and environment—all three—are threatening the fourth factor, safety. All of these four factors also influence each other. This is a new ball game, and the airline industry has to find a way to balance these four.
I compare that with a plate with a marble on it. At the edge of the plate are finance, capacity, environment, and safety. In the middle is a marble. The aim of the game is to keep the marble in the middle. What one sees at the moment is that when, for example, environmental issues get priority, capacity tends to be reduced. This is not in the interest of an airport or of the airlines, so they strive for keeping capacity. By keeping the profits as they are, the plate will be banked toward safety, and therefore safety will degrade. The airline industry has not found the right balance yet—the situation is unstable, and safety is paying the price.
Contracting States of the International Civil Aviation Organization (ICAO) now base their regulation of bird-hazard reduction on Standards and Recommended Practices (SARPs) for aerodromes according to Annex 14 (Aerodromes), Chapter 9, as adopted in 1990. The International Federation of Air Line Pilots Associations believes that airline industry partners could be convinced by various arguments to invest effort and finances to reduce wildlife hazards.
Three convincing arguments follow:
• Economic—Wildlife damages airplanes. Direct costs, such as repair and replacement costs, are easy to quantify. But indirect costs, such as delays, re-booking of passengers, nonproductivity of a crippled aeroplane, the loss of customers (passengers), the increase of insurance premiums, etc., are much more difficult to quantify. Obviously, the airlines (the International Air Transport Association) benefit if these costs are reduced. Ironically, the IATA shows very little interest and virtually no initiative in limiting or reducing these costs. Therefore, economic arguments could induce the airlines and airports to invest. Management will be reached only by financial arguments. So let’s examine some facts:
—50 aircraft have been lost (since reporting began) to wildlife strikes.
—Wildlife strikes cost $380 million/year in the United States (figures for the rest of the world are not known).
—Wildlife strikes account for 461,000 hours of aircraft down-time per year in the United States.
—Birds caused 40 percent of engine foreign-object debris in 1999 at United Airlines.
• Awareness of the danger of wildlife strikes—Pilots, air traffic controllers, airport managers, and aviation authorities need to become more aware. The general public needs to be made aware of the potential risks involved—they vote, and they control the politicians who are in the position to change the regulations.
• Rules and regulations—As proven before, necessary adjustments to procedures or investments take place only after the authorities make the changes mandatory. Therefore, the authorities should be persuaded to do the job on wildlife hazards. One way to do this is by changing ICAO Annex 14 and by getting wildlife-hazard control into national rules and regulations.
We are facing a number of restrictions, which all lead to an increasing risk of wildlife strikes:
• Economic pressure—Airlines hate delays, and the pressure on pilots and ATC to minimize delays is huge. Apparently some colleagues will accept a birdstrike risk just to avoid delay.
Not so long ago, I requested a bird-scare at Hamburg Airport because a lot of birds were crossing the runway. The tower controller said: "Yes, sir, we know there are a lot of birds, it is in the NOTAMS; and for a bird-scare we have to get somebody, that could take 20 minutes. Are you sure you don’t want to take off now?"
"No," I said and taxied clear of the runway. A colleague from Deutsche BA did not want the delay and accepted a clearance to take off. He took off; luckily enough, he did not hit any birds and cleared the runway for me. (Thank you, dear colleague!)
• Real estate that surrounds airports forms another economic restriction. Dublin Airport is a good example of this, but problems also exist in the Netherlands at Schiphol and in New Zealand at Christchurch.
• Risk assessment involves the reluctance to invest adequate cash in a wildlife-hazard organization, which could be seen as an insurance premium. By not paying this premium, a future accident could end in huge legal claims and the loss of public trust in aviation safety. Objective risks and objective statistical data, however, are not always in line with public opinion and political reality. Therefore, the analysis of risk versus premium should be reviewed regularly. What results depends on local circumstances and it changes with time.
• Environmental issues raised by wildlife protection organizations, which are growing, particularly in the neighborhood of airports, result in a proportional increase in the birdstrike risk. Is the general public aware of this consequence and what this could mean for their safety?
• Awareness regarding the wildlife- strike hazard has increased, thanks to the great effort of the members of this Conference. But have we reached our goals yet? I think, although we are flying on the right track now, we are actually just in the departure path and still have a long way to go.
A lot of people seem to think that because the problem concerns wildlife, you cannot do a lot about it. Well, in the beginning of airline travel, people thought the same about the weather.
But now we have a worldwide professional meteorological service. Before every flight, the pilot studies extensively all weather factors and adapts the flight plan accordingly. During the flight, the pilot uses weather radar to alter the airplane’s track when necessary.
Therefore, avoiding natural dangers is possible, given the factual and actual information and the right tools.
• Operations forms the last restriction on avoiding wildlife strikes. The information available to pilots about bird migration or bird hazard is often limited to a permanent NOTAM or what they see directly in front of them with their eyes. Especially when flying close to the ground, aircraft maneuverability is very limited; therefore, the later the warning, the less pilots can do. We have no instruments on board to detect bird mass, nor do we have actual or forecast bird migration reports relevant to our flightpath. Therefore, pilots are extremely limited in what they can do to avoid wildlife strikes.
With all these factors in mind, IFALPA, at its 1999 conference, developed its new wildlife-hazard policy. We speak of wildlife rather than birds, because the term wildlife covers everything. We are now trying to get ICAO and the national aviation authorities to adopt this policy. We strongly believe in the establishment of national birdstrike committees (as has been done in some countries), and we believe that a pilot should be a voting member in such a committee. Furthermore, an awareness campaign should be launched. Finally, IFALPA could apply its classification system to airspace regions or airports that do not comply.
The main elements of IFALPA’s policy are to determine responsibilities more clearly, in airspace areas, and introduce an acceptable risk factor. I will discuss only the differences between the ICAO and the IFALPA policy.
First, the Dublin case has proven that all Paragraph 9.5 articles should be upgraded from Recommendation to Standard to gain more jurisdictional force.
Secondly, we have made considerable changes to Paragraph 9.5.2 (see page 16). The appropriate authority could be the national or local authority, or it could be delegated to the airport. IFALPA believes that a possible loss of human lives or severe damage to aircraft is not acceptable. An aircraft is most vulnerable when its speed is low with lots of drag, its power is high, and it is close to the ground. This is the case on the airport during takeoff and landing and in the approach or departure path within 3 kilometers of the runway.
Thirdly, IFALPA believes that required actions must be made more specific. This should include identifying the wildlife species on and near the airport, followed by making a sound assessment of the wildlife-strike risk at that aerodrome. A national birdstrike committee could take these actions. If the committee finds a wildlife-strike risk, then an organization with adequate equipment for effective wildlife control should be established and address any habitat problems on the airport or in its vicinity, using effective dispersal measures where necessary.
Finally, a reporting and feedback system for collecting wildlife-strike data closes the loop.
Special interest should be given to waste disposal sites or any other sites that attract birds. When such a site falls under the approach or departure path or could increase the number of birds in the active airspace, that site is incompatible with aircraft operations. Thus, the correct and smart use of land surrounding airports and good area planning is the key to avoiding wildlife strikes.
We have no instruments on board to detect bird mass (along the lines of weather radar), so we have to rely on our Mark I eyeball principle: see and avoid. Therefore, we as pilots cannot do a lot, but we can do the following:
—Check NOTAMs and ATIS for wildlife danger.
—If the NOTAM is a continuous, permanent, and general type of bird-hazard warning, suspect the airport management or aviation authority of motives other than informing pilots accurately —they probably want to be able to point to the pilot in case of an accident ("pilot has been warned"). Be very cautious.
—If, on the other hand, the NOTAM is up-to-date and factually correct and lists actions the airport is taking during the valid time, then the airport management is taking its responsibility seriously. Proceed with caution.
• Taxi out
—Scan for wildlife and report to ATC.
—Use the word PIREP.
• Before takeoff
—If animals are near or on the runway, don’t take off.
—Select another runway, or
—Delay takeoff and ask for a bird-scare (airport management is obliged to supply this).
• Takeoff in areas of high bird activity
—Take off only if you have no doubt that the animals have been dispersed from
your intended flightpath.
—When taking off in a string of departures, as is common in hub airports, be particularly cautious. The lead aircraft may frighten feeding or loafing birds into becoming airborne in your intended flightpath.
—Birds may try to return to their spot on the airport after the lead aircraft has scared them. Therefore, wait until the flock has cleared your flightpath.
—Realise that striking a goose at 130 knots equals the force of a 1,000-pound weight dropped from 30 feet.
• Initial climb in areas of high bird activity
—Climb expeditiously to 3,000 feet AGL, using the ICAO noise abatement profile; climb at V2+10 to 3,000 feet. You will
1. reduce the probability of a bird hit because 90 percent of all bird strikes occur below 2,300 feet AGL—most birds fly below 2,300 feet AGL between their roosting, loafing, and resting areas;
2. lower the impact energy (˝ mass times velocity squared); and
3. stay closer to the airport—most bird reduction and control measures are within the airport boundary.
• Flying in areas of high bird activity
—Fly at a max speed of 200 knots in a known bird environment.
—Pull up—birds will see you not as a predator, but as an obstacle, and will brake briskly to avoid you.
• After flight
—Report strikes and "too-close-for-comfort" encounters. Fill in the appropriate company safety report for wildlife encounters and/or the appropriate government birdstrike report. Data show that one damaging encounter occurs for every five nondamaging ones, and one accident occurs for every 150 damage reports. Your report is vital for the scientists and gives airline operators and airports the incentive to invest in measures that will reduce the birdstrike risk. Eventually it will help you and your colleagues.
You should not expect
• birds to respond to your efforts to hasten their departure;
• that switching on lights will safeguard you—when loafing on the ground, birds face into the wind; therefore, they will not see you;
• airborne radar to be a safeguard—it has no proven or demonstrated effect;
• that spooling up your engines will cause birds to clear your flightpath—today’s reduced engine noise is not in the primary frequency range for birds’ ears;
• that your engines, airframe, or windshield can take any bird—no engine is certified to ingest larger birds like geese, swans, storks, eagles, vultures, etc.;
• that your engines, airframe, or windshield are certified to ingest flocks of birds (maximum 4 or 16, depending on size, although they can fly in flocks of thousands together); or
• that above 2,300 feet AGL you are completely safe—migrating birds are known to fly up to 10,000 feet.
Management pilots should
• ensure that their operations manuals reflect actions that aircrews should
take to avoid wildlife strikes;
• ensure that they have a reporting and feedback system for wildlife strikes;
• motivate aircrew awareness of wildlife strikes; and
• train aircrew for wildlife strikes as they train for windshear, icing, etc.
A national airline pilots association should
• convince members to adopt the above-mentioned suggestions;
• start and maintain a wildlife-strike awareness campaign;
• be a voting member in your national birdstrike committee (see page 18);
• convince operators on safety and economic grounds;
• motivate the aviation authority and airport authorities to adopt IFALPA Annex 14 Articles 9.5; and
• inform IFALPA about airports that do not comply with this policy.
• representing airline pilots on the International Bird Strike Committee;
• developing the IFALPA wildlife-hazard policy;
• working actively to get this policy adopted by ICAO;
• using a classification system for airports/airspaces that do not comply; and
• motivating member associations.
Bird strikes have a direct financial effect on the airlines and reduce flight safety. The danger increases as environmental protection and air transport increase. However, the effects could be reduced. This requires structure and funding. A national wildlife strike committee gives that structure.
Believing that adopting rules and regulations is the most powerful and effective tool, IFALPA has developed a policy that determines clearly the responsibilities, defines an area, introduces an acceptable risk factor, and specifies a number of actions. ICAO should be convinced by as many parties as possible and with strong arguments to change its Annex 14 accordingly. This also applies to the national authorities.
IFALPA believes that through national rules, the birdstrike risk will be reduced, improving flight safety. Experts believe that correct area planning for the land surrounding airports is most effective. Meanwhile, all member pilots should be made aware that they also play an important role in avoiding wildlife strikes. We cannot look only at others to do the job; we should be doing all we can with the limited tools we have today.
Whether these actions succeed depends fully on you—it’s your flight!
Capt. Rob van Eekeren (KLM) is chairman of the Technical Committee of the Dutch Airline Pilots Association, a member of the Dutch Birdstrike Committee, and a member of the IFALPA Airport and Ground Environment Group. He was duty commander of Schiphol Airport for 2 years before joining KLM. This article is adapted with permission from IFALPA’s INTERpilot, No. 2, 2000, which adapted it from a presentation given to an IFALPA Conference held in Tunisia in October 2000.
IFALPA Annex 14 policy
IFALPA has recommended that the following changes be made to ICAO’s Annex 14.
IFALPA’s proposed new text is shown in italics. IFALPA wants
strike through text to be replaced. (The original ICAO document uses
italics for Recommendations and Notes, but we could not use italic for both that
and the proposed changes.)
9.5 Bird hazard reduction
Recommendation The birdstrike hazard on, or in, the
vicinity of an aerodrome should shall be assessed
a) the establishment of a national procedure for recording and reporting bird strikes to aircraft, and
b) the collection of information from aircraft operators, airport personnel, etc., on the presence of birds on or around the aerodrome.
Note.—The ICAO Bird Strike Information System is designed to collect and disseminate information on bird strikes to aircraft. Information on the system is included in the manual on the ICAO Bird Strike Information System.
Recommendation When a birdstrike hazard is identified
at an aerodrome, the appropriate authority should shall
take action to decrease the number of birds constituting a potential hazard to
aircraft operations by adopting measures for discouraging their presence on, or
in the vicinity of, an aerodrome.
The appropriate authority shall take action to decrease the number of birds constituting a potential hazard to aircraft operation by adopting measures which result in eliminating the chances of a bird strike leading to severely damaging aircraft or endangering human lives on the airport during the takeoff or landing run, or in the approach or departure path within 3 kilometers (10,000 feet) of the runway. This action should include
a) Identification of the bird species on, and in the vicinity of, the aerodrome.
b) Assessment of the aerodrome birdstrike risk.
c) Address any habitat problems on the aerodrome or in its vicinity.
d) Utilisation of effective dispersal measures where necessary.
e) Organisation of the aerodrome staff and equipment for effective bird control.
f) A reporting and feedback system for the collection of birdstrike data.
Note.—Guidance on effective measures for establishing whether or not birds, on or near an aerodrome, constitute a potential hazard to aircraft operations, and on methods for discouraging their presence, is given in the Airport Services Manual, Part 3.
Recommendation Garbage disposal dumps or any such
other source attracting bird activity on, or in the vicinity of, an aerodrome
should shall be eliminated or their establishment
prevented, unless an appropriate study indicates that they are unlikely to
create conditions conducive to a bird hazard problem.
Note.—A potential safety hazard exists when a waste disposal site is located within 3 kilometres (10,000 feet) … of a runway used by turbo-engined aircraft. When a waste disposal site is located within 8 kilometers (5 miles) radius of a runway and falls under the approach or departure path or has the potential to increase [the number of] birds in the active airspace, such a site shall be considered incompatible with aircraft operations.
Ongoing ALPA Efforts to Reduce Wildlife Hazards
Capt. Paul Eschenfelder (Northwest), ALPA’s Wildlife Hazards Project Team Leader, reports that "ALPA is fully engaged on the problems of wildlife hazards to aviation."
F/O Dave Hayes (Northwest) has been providing line pilot input to the Engine Working Group of the government/industry Aviation Regulatory Advisory Committee (ARAC) on engine certification. The Group has been trying to develop a consensus on new, more stringent certification standards intended to make new engines more robust and better able to handle present and future threats from bird ingestion.
Capt. Ross Sagun (United), chairman of ALPA’s Air Traffic Services Group, and other ALPA line pilot volunteers have brought up at meetings of the government/industry Air Traffic Procedures Advisory Committee (ATPAC) and elsewhere the fact that air traffic controllers are not fulfilling their responsibility—mandated in the FAA’s Air Traffic Controller’s Handbook—to convey safety-of-flight information about birds and other wildlife hazards to flight crews when that information is available to the controllers.
The ATS reps also are debating the wisdom of continuing the operational experiment at Houston in which controllers can—and often do—waive the FAA requirement that pilots observe the 250-knot speed limit below 10,000 feet. Windshields, however, are certified to resist only strikes of 4-pound birds at Vc— the design cruise speed of the aircraft. Large flocking birds, such as geese, swans, pelicans, vultures, which can weigh as much as 22 pounds, far exceed these design limits. Also, the empennage is certified only to withstand a strike from an 8-pound bird.
Meanwhile, Capt. Eschenfelder
serves on the U.S. Secretary of Agriculture’s advisory committee;
• is an advisor to the International Bird Strike Committee, primarily a scientific group whose goal is to better understand the nature of the threat;
• serves on the Steering Committee of Bird Strike Committee USA; and
• will present a paper on wildlife hazards this month at a meeting of the International Civil Aviation Organization (the aviation arm of the United Nations) in Miami.
ALPA also has been involved in investigating three bird strike accidents that occurred this past winter—all involving turboprops.
On Nov. 5, 2000, an Air Ontario DHC-8 struck a flock of Canada geese while landing at night at Toronto City Center Airport. The fiberglass blades on both props shattered so badly that the flight crew had to call for a tug to tow the crippled airplane to the gate.
Three days later, a Mesaba SF-340 hit a flock of snow geese while landing at Aberdeen (S.D.) Regional Airport. A metal fragment—perhaps a dislodged windshield wiper arm deflected by a propeller—flew into the cabin, lodging in a passenger’s leg.
On Dec. 6, 2000, an Atlantic Southeast Embraer EMB-120 Brasilia struck two large deer while landing at Charleston, W.Va. Again, a shattered fiberglass prop blade penetrated the fuselage and injured a passenger, who needed surgery.
Lest any pilots think that flying jets will let them escape the feathered bullet, Capt. Eschenfelder is quick to point out, "According to the latest FAA statistics, the Canadair jet has rocketed to the top of the list for rate of engine hits [i.e., bird strikes to engines]—by a factor of 10."
Funding for research and mitigation measures lags dramatically behind the damage being done. "The funding situation is just plain bad," Capt. Eschenfelder reports. "The U.S. Department of Agriculture is the agency in this country with the responsibility to deal with wildlife hazards and damage. USDA definitely wants to do something about wildlife hazards to aviation. Finding the funds to mitigate this hazard should be a priority for the aviation industry, but it’s not.
"The technology is available now to significantly reduce this safety hazard," Capt. Eschenfelder asserts. "The USAF’s Aviation Hazard Advisory System (AHAS), for example, has reduced their birdstrike problem by 70 percent. Any airline dispatch office can use it, but most have no idea it exists (see it yourself at www.ahas.com). This is an aviation hazard just like windshear, inflight icing, volcanic ash. We mitigated those; with education and research we can mitigate this."