The Air Line Pilots Association (ALPA), representing the safety interests of 53,000 professional airline pilots flying for 51 airlines in the United States and Canada, has reviewed the notice of proposed rulemaking (NPRM) in the referenced docket. The NPRM proposes modified standards to which engines are certified with respect to their ability to withstand impacts from birds or similar wildlife hazards. We feel the proposed standard is a step in the right direction, but cannot under any circumstances be considered attainment of a goal. As outlined below, the data used in developing the NPRM has been superseded by more accurate values for bird weight, flock size and risk of encounter. These more accurate data, and the reality of ever increasing bird populations, must be part of a program to continuously reevaluate and adjust airworthiness standards. Airport programs are decreasing and formal pilot training in wildlife hazards is nonexistent. Such deficiencies must be corrected and cannot be considered mitigating factors.
ALPA appreciates the opportunity to comment on this proposal. Although we feel the proposed standard would be an improvement over current standards, the effort falls short of establishing engine criteria that reflect the current and future picture of wildlife hazards. We urge the FAA to continue to sponsor industry groups and research efforts to improve understanding of the threat and, with that understanding, ways to counter it.
Available at: http://works.bepress.com/paul_eschenfelder/7/