7 April, 2003
Jeffrey J. Short, Colonel (ret.) USAFR
3064 Eutaw Forest Drive
Waldorf MD 20603

Mr. Wayne Arney
Deputy Assistant Secretary of the Navy (Installations and Facilities)
1000 Navy Pentagon, Rm. 4E765
Washington DC 20350-1000

Dear Mr. Arney,

As a quick introduction, I recently retired from the USAF Reserves with experience as a combatrescue pilot and research scientist. I have spent the majority of my career working to reduce losses of aircrews and aircraft to birdaircraft strike hazards (BASH). I have been closely involved in every aspect of the BASH issue: airfield hazard evaluations, bird hazard management and control, risk assessment and modeling, applied engineering studies, and could be considered the father of the USAF Bird Avoidance Model-still in use after two decades. Since 1996, I have served the International Bird Strike Committee as Technical Advisor.

I write to express my concern that a Navy Outlying Landing Field (OLF), proposed to be located approximately five miles west of the Pungo Unit, Pocosin Lakes National Wildlife Refuge (PLNWR) in eastern North Carolina, may have disastrous results. In 25 years of dealing with military BASH issues I cannot recall a worse place to situate an airfield for jet training. Aircraft at the proposed OLF would suffer from continual and dangerous hazards to safe operations due to the huge waterfowl populations that use the PLNWR from October to March each year. I should note that my interests are related solely to the safe flight operations at the OLF and protection of the aircrew and aircraft resources that would use the OLF; I have no property or other interests in the area of the proposed site.

Since the Navy is aware of the bird hazards at the proposed site, it would seem prudent either to mitigate or remove the risk. This foreseeable hazard could make the Navy liable if (or when) a fatality occurs from a bird strike at the OLF. The dangers caused by birds-especially in the great numbers using the PLNWR-are wellknown. Indeed, Navy Safety Center guidance admonishes aviators to avoid flying near wildlife refuges and known concentrations of waterfowl.

Considering the significant bird strike hazards and their impact on the mission, it would seem to be folly for the Navyand the U.S. taxpayers-to invest in the development of an OLF near the PLNWR. It will prove to be difficult and expensive for the Navy to ensure that these serious hazards are controlled adequately to allow yearround flight operations. The life-cycle costs of trying to manage the bird hazard risks at the OLF would be substantial, and perhaps, ultimately ineffective. Regarding lifecycle costs, the proposed OLF location would seem to be a terrible investment considering the additional expenditures related to degraded aircraft operations, reduced training opportunities, costly repairs for Navy aircraft, and predictably, increased loss-of-aircraft and/or lossof-life aircraft mishaps.

Complete elimination of the bird hazards might be considered more objectionable than noise impacts from using an alternate OLF site.
My hope is that you will seriously consider the recommendations of the U.S. Fish and Wildlife Service, North Carolina Wildlife Resources Commission, Ducks Unlimited, The Nature Conservancy, Audubon (North Carolina), and others, to abandon the plans for the proposed OLF site near PLNWR. Alternate sites are available that will provide safe flight training and that meet other Navy criteria for acceptance.

Losses to due to birds and other wildlife are preventable. The Nation can´t afford to lose precious aircrew and aircraft resources to birds. Fortunately, the decision to locate the OLF at another site will protect Navy resources. Please don´t hesitate to contact me at (301) 9324612 if you have any questions.

Sincerely,

cc:

Dan Cecchini
Matt Klope