Balancing Wildlife Hazard Concerns and Stormwater Management at Airports GAA Spring Workshop February 27, 2015 Kim M. Allerton, President Environmental 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: Aircraft are built to fly quieter and more efficiently than in the past Airplane travel is commonplace worldwide = a lot more planes 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 09-08 Balancing Airport Stormwater and Wildlife Hazard Management: Analysis Tools and Guidance

Problem Statement Airports 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: Synthesis of existing airport stormwater management options. 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. Sample checklist of potential state and/or local environmental considerations that apply to stormwater management and may conflict with wildlife hazard management. A bird strike risk analysis tool to provide a risk score for each stormwater management option considered. 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. A minimum of 2 case studies. 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 Example Consequences to Aircraft Suggested Actions L (Low): Risk < 5 Mitigation 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 < 15 Mitigate 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 > 15 Mitigation is required Loss 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

Severity Factors from Risk Matrix Species: Select species of greatest concern and tool auto-populates standardized relative hazard score (Devault et. al., 2011) BMP – Perimeter Irregularity: The ratio of the pond perimeter to the perimeter of a perfect circle of equal area BMP – Apparent Slope to Water’s Edge: Horizontal run (H): Vertical rise (V) 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. 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 History of Observations: How often the species of concern is observed by airport staff Proximity of Bird Sightings: Where the species are being observed in relation to the runway History of Strikes: Total percentage of strikes from strike database for species being evaluated (only evaluate strike data within the last 5 years) 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

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

Wildlife Hazard Management Mitigation Measures ENGINEERING WARNINGS ADMINISTRATIVE Wildlife Hazard Management

Step 3 – BMP Characteristics

Step 4 – Identification of Initial Risk and Additional Mitigations

Step 5 – Proposed BMP Modifications

Step 5 (cont.) – Identification of Residual Risk

Bird Strike Summary

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 Reviewed 5 local manuals, 5 state manuals, all in different FAA regions Variation in regulations depends on local water resource issues, e.g., receiving water impairments, protected species, designated uses, soil characteristics, etc. Some manuals require emphasis on infiltration (eg Portland), others have no requirements (eg Columbus). Some manuals like Roanoke require permanent pools for WQ, others like Memphis allow other forms of treatment (forebay, stormwater quality inlet) Memphis TN prohibits underground detention Peak flow requirements vary – Columbus 100 post to 10 pre, Portland waives to large streams, Other manuals match post to pre Some manuals require minimum detention volume (eg RIDEM), others do not

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 Separation – 10,000 ft outside AOA (turbine-powered aircraft) or 5,000 ft outside (piston)

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 NPS USFS 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?