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04 April 2009

Why the FAA Should Not Block Access to Bird Strike Data

In March 2009, the FAA quietly made a stunning proposal to make it nearly impossible for the public to access a vital aviation safety resource. Since 1990, the FAA's National Wildlife Strike Database has been one of the most important tools for understanding bird and wildlife strike risks to aircraft. With over 100,0000 records, this database has the potential to benefit everyone who flies by giving the aviation safety community and the general public the opportunity to analyze that data in order to discover ways to reduce the threats to aircraft caused by birds and other wildlife. The FAA states several concerns about the database, but none of their arguments support their proposal to block public access to the data.

The FAA admits that over the last 19 years they have collected and used this data to improve safety. One of their concerns with the current database is that there is a serious potential that information related to bird strikes will not be submitted because of fear that the disclosure of raw data could unfairly cast unfounded aspersions on the submitter.

This argument only makes sense if the FAA assumes that there is no way to counter an argument based on a biased or incompetent analysis. This is not the case at all. The tools needed to analyze aviation safety data are widely available. If an analysis is unfair or incorrect it should be easy to review the assumptions, the data, the analysis, and determine whether the conclusions were justified.

Another part of the FAA's argument to make this database unavailable to the public is that when the FAA began collecting this data, it assured the entities submitting the data that the submissions would not be made available to the public. While that may have been true 19 years ago, it apparently hasn't been the case for at least the past 12 years The current online submission form and the paper wildlife strike report forms available since at least 1997 made no such promises of secrecy.

In the proposal, the FAA states releasing this information without benefit of proper analysis would not only produce an inaccurate perception of the individual airports and airlines but also inaccurate and inappropriate comparisons between airports and airlines.

The concern of the FAA is clearly not for individual submitters, since they already redact this kind of personal information from the database. Their concerns appear to be for the reputation of airports and airlines. More importantly, this argument implies that the FAA has the attitude that the public doesn't have the ability to properly analyze the data. It's true that the process of asking and answering aviation safety questions can be an extremely difficult task even for aviation safety experts. It's probably true that if most members of the media or the general public attempt to analyze this bird strike data they may come to conclusions that may unfairly highlight an airline or airport. However, this possibility should not be the FAA's concern. The FAA has many roles, but passing judgment on the ability of the public to scrutinize data is not one of them.

The FAA in their proposal states that it is imperative that nothing should stifle flow of information into this database. However, their proposed action will do exactly that. For aviation safety data to be useful, the flow of information has to go in two directions, not just one. Cutting off the pubic from this information makes it less likely that the aviation safety community will learn from the experiences of others and use that knowledge to enhance safety.

The FAA can and should take steps to ensure the privacy of individuals who voluntarily submit safety data. However, protecting airports and airlines from the potential embarrassment of unfair or incompetent data analysis is not a valid reason to close public access to the database. The database exists in part to help prevent accidents and to help save lives. Putting a wall around this database may help to enhance the public's opinion of airlines and airports, but it will not help protect the public from risk. If the FAA's goal is to save lives then the database should remain available to the public, and they should not be allowed to implement their proposed changes.

The public has an opportunity to make its voice heard on this issue. In an upcoming post, will give you step-by-step instructions from submitting your comments prior to the close of the public comment period on 20 April 2009. will follow this issue closely, and in the next few days will provide detailed guidance on how to submit your comments to the FAA and prevent this policy change. If you have not done so already, please subscribe to the mailing list or get Twitter updates to keep up to date on this critical issue.

Related Information
FAA Proposal to Change Database Access
Background Information on Bird Strike Threats
Bird Strike Committee USA

1 comment:

  1. They really should not block the data to public, we gotta do something about it!