Dr Nial Moores, National Director, Birds Korea, January 2025.
- Introduction
In response to the tragic crash and loss of 179 lives at the Muan International Airport on December 29th 2024, relevant authorities in the Republic of Korea (ROK) have stated publicly that they will investigate aircraft maintenance issues and the placement of permanent, reinforced structures at the end of the runway at Muan and at other airports nationwide. This is presumably to bring airports into line with clear recommendations already provided by ICAO (2009).
Because safety of passengers is the priority of airport managers, there also needs to be an honest re-assessment of the suitability of the location of existing and of proposed airports – especially as it relates to the bird strike risk at each airport. This is an urgent imperative because of the high number of new airports that are being proposed, almost all in bird important areas near to the coast (Figure 1); and according to an Editorial in the Dong-A Ilbo on January 4th 2025, because of growing concerns over the current safety standards of several existing airports, with standards perhaps weakened by the airports’ lack of economic viability.
As explained in more detail below, reasons for deep and growing concern include runway expansion at the existing Muan International Airport, built next to wetlands which support ~40,000 waterbirds each winter; the proposed Saemangeum International Airport, to be built within internationally important wetland for waterbirds and within 7km of a natural World Heritage Site; the proposed Gadeokdo International Airport in Busan, to be built within 7km of the Ramsar Convention-defined internationally important Nakdong Estuary, and across a route used by migratory raptors and other landbirds; the proposed Jeju Second International Airport, to be built ~6km from a natural World Heritage site that supports a large colony of cormorants and is close to wetlands and a shoreline that supports many waterbirds; the proposed Baengnyeong airport, to be built across a major migratory bottleneck and in an area with thousands of geese and duck every winter; the proposed Seosan and Gyeonggi-Hwaseong airports, in areas used by massive concentrations of geese and other waterbirds; and even the Heuksan Island airport, to be built astride the main migration route for raptors crossing the Yellow Sea between PR China and the southwest of the ROK.
In addition to deep concerns over the bird strike risk, a re-assessment of all of these airport proposals and their operations could also contribute substantially to national efforts to reduce greenhouse gas emissions and also help the nation to meet its own targets as set out in the legally-binding Fifth National Biodiversity Strategy and Action Plan (2024-2028). This is “the highest-level, cross-ministerial strategy in biodiversity that sets out a five-year policy direction to ensure the conservation and sustainable use of biodiversity in the country” (ROK 2023).
Reassessment likely also makes great economic sense. The small airport on Ulleung Island, an island with a population of only 10,000 or so people, is projected to cost the nation a staggering 560.9 million USD. In addition, predictions for airport usage in many cases seem to have little connection to reality. The Environmental Impact Assessment / Statement for the Muan International Airport for example predicted that between 8.3 million and 11.22 million passengers per year would use the airport by 2020 (EIASS 1998: Table 2.6.5). In 2023, the actual total was apparently only 233,000.
All such re-assessments of airport locality (and operation) in the ROK – as everywhere across the world – need to be framed clearly by guidance provided by the International Civilian Aviation Organisation (ICAO). ICAO is the UN agency which through the Chicago Convention for civilian aviation (1944) works for aviation safety across the World under the banner of “Safe Skies, Sustainable Future” (ICAO 2025). The ICAO is not a regulatory body per se. Instead, it offers guidance based on decades of collective expertise of aviation issues, continually updated as understanding grows. Accordingly, ICAO has produced and continues to update a series of manuals on airport planning, design, operation and maintenance that help to set the global standard – with much of this guidance then enshrined in national laws, by-laws or policies by member States. All of these manuals, including in some cases older editions, can be found online; and of course, as a member State, all such materials are also available to relevant decision-makers in the ROK.
This post aims to introduce some of that ICAO guidance as it relates to the bird strike risk at the Muan International airport and other proposed civilian airports in the ROK; and also to assess some of the weaknesses of the Environmental Impact Assessment process.
2. Reducing the Risk to Aircraft by Bird Strike
Bird strikes (collisions between birds and aircraft) are a widespread and increasing problem worldwide that entail financial loss to commercial, civil, and military fleets worldwide as well as being a source of mortality for birds and more rarely for people (Metz et al. 2020; Andrews et al. 2022). Bird strike, perhaps with a flock of birds, is currently implicated as a contributory cause in the crash at Muan.
Not all species of bird pose the same level of risk to aircraft. Rather, the safety risk to aircraft posed by bird strike is defined by the ICAO (2020) in Section 3.1.4 as the probability of a strike multiplied by the severity of damage caused. As noted in Section 3.3.2, “the severity scale will depend essentially on the size of the animal and its tendency to flock or congregate. Generally, heavier wildlife and greater flock size increases the probability of damaging an aircraft and impacting its flight performance. Flocking behaviour could include multiple impacts or increase the probability of a strike.”
A plane colliding with a single small bird is unlikely to pose much risk to the aircraft. Aircraft colliding with large flocks of birds which have a high mass (body weight) pose a much higher risk. Larger-bodied birds which often form large flocks, like geese and cormorants, pose the highest bird strike risk if they frequently fly across the runway or heavily used flight paths.
In this simple understanding, there are three main steps that decision-makers can take to reduce the bird strike risk, the first two of which are covered in this post.
The first, and wisest step, is precautionary. That means avoiding building airports in areas known or found to have large concentrations of large-bodied birds – essentially migratory bottlenecks and wetlands. This step fits fully with ICAO guidance and also with Target 1 of the ROK’s Fifth National Biodiversity Strategy and Action Plan, to “Strengthen biodiversity management through spatial planning” (ROK 2023). If safety of aircraft is the priority, then many of the currently-proposed airports should have been cancelled during the initial project scoping period. There is still time to take this step.
Second, if an airport is deemed truly essential and the bird strike risk is considered acceptable, then proper research needs to be conducted, so that appropriate Wildlife Hazard Management Plans or Programmes can be developed at each airport. This is the stage where a series of difficult and sometimes expensive decisions on mitigation need to be taken – including reorientating proposed runways to avoid the most hazardous areas and, as advised by ICAO (2012, 2020) enacting ecological measures to reduce the attractiveness of the airport area to birds before operation.
And third, managers of airports then need to use their evidence-based Wildlife Hazard Management Programme to reduce the bird strike risk as much as they can through scaring off birds – especially near to runways, but if needed also all the way out to 13km from the airport as advised by ICAO. This is because 95% of documented bird strikes take place below 2,000 feet (=610m) above ground and “an aircraft on a normal approach would descend into this zone at approximately 13 km from the runway” (ICAO 2020, 2-6).
2. Airport Location
To the best of our knowledge, ICAO has not made any unequivocal statements on where airports should not be built. However, because of the bird strike risk, ICAO guidance has long advocated for avoiding building airports in and near open wetlands with large numbers of waterbirds and at migratory bottlenecks. A few examples follow.
Almost 40 years ago –pre-dating the construction of the Muan International Airport – ICAO (1987), Section 5.6.1, stated that, “Environmental factors should be carefully considered in the development of a new airport or the expansion of an existing one. Studies of the impact of the construction and operation of a new airport or the expansion of an existing one upon acceptable levels of air and water quality, noise levels, ecological processes, and demographic development of the area must be conducted”; and Section 5.5.8 (“Hazards”) stated, “Sites adjacent to wildlife reserves, lakes, rivers and coastal areas, refuse dumps and sewage outfalls, etc., may not be desirable because of the danger of aircraft collision with birds. This is of special importance where faster, larger aircraft are involved. The location of sites relative to the migratory patterns and routes of birds, especially large birds such as swans and geese also requires consideration.”
Subsequently, ICAO (2002), Section 2.5.8, states that “An important consideration related to airport operational safety is the prevalence and habits of birds in the area and the associated risk of aircraft bird strikes. Bird hazards at proposed new airports can be minimized by careful selection of the site to avoid established bird migration routes and areas naturally attractive to birds and by using the land surrounding the airport for purposes which will not attract concentrations of birds to the area”; Section 3.8.4 clarifies that it “is necessary to develop a description of both the physical and social environment, which includes…— avifauna migration routes, and — ecological systems,” and Section 4.2.3 warns, “where rivers, lakes, bays or swamps are found in the airport area, bird hazard problem may exist. At some airports, this problem has been so serious as to cause accidents.”
ICAO (2002) also includes an Appendix, “Land-use Guidelines for the Avoidance of Bird Hazards”, which advises that there should be no bird sanctuaries or game reserves within 8km of airport operations. This latter guidance has been adopted into law by the ROK’s Ministry of Land, Infrastructure and Transport, but based on questions asked during a legal challenge being made to the Saemangeum New Airport in 2024, it seemed to several of us that one of the lawyers appeared to view this as a mandate to block the designation of national Wetland Conservation Areas and Ramsar sites within 8km of existing airports – and not as a way to reduce the risk of bird strike (Nonetheless, several of these airport proposals are at sites within 8km of bird-important, nationally protected areas).
And more recently, ICAO (2020), Section 1.3.9 states that, “State authorities should analyse and approve the location of new aerodromes, to ensure that issues with high potential for wildlife attraction are considered and mitigated where necessary.”
Figures 2 and 3 show the location of the Muan International Airport and the proposed Baengnyeong Airport. Clearly, neither sites are “desirable” for airports because of their high bird strike risk.
The ROK is a small country. In addition to publications with broad-sweep analyses of migratory routes based on predictable bird behaviours, there are multiple datasets and count programs that could be used for identifying sites which most obviously pose a high bird strike risk.
These include the winter bird census, conducted under the auspices of the national Ministry of Environment at more than 200 sites nationwide (MOEK 1999-2023). The winter bird census is primarily focused on waterbirds (i.e., ducks, geese, cranes, cormorants, herons, storks and gulls etc.) and on known, important wetlands and coastal areas. The winter bird census does not cover every important wetland or proposed airport site, and at many wetlands also does not capture the seasonal high peak in number of waterbirds. However, 23 of these bird census count sites are wholly or partly within 13km of Muan International Airport and five of the proposed airports, in total supporting up to half a million waterbirds in winter between them (see Table 1). Two (the Muan International Airport and the proposed Saemangeum New Airport) are also less than 8km from the natural World Heritage tidal-flat serial property (ROK 2021), while the proposed Second Jeju airport is within 6km or so of the outstandingly beautiful Natural World Heritage property, Seongsan Ilchulbong Tuff Cone.
It is therefore important to understand: Government data clearly indicate that at least seven and perhaps all eight of these new airports, once operational, will inevitably experience a high or an exceptionally high risk of bird strike to aircraft. The same data also indicate the outstanding importance of many of these same sites for biodiversity. As such, biodiversity conservation should be prioritised at these sites, in accordance with the 5th National Biodiversity Strategy and Action Plan. Otherwise, how will it be possible to stop the ROK’s “clear downward trend in biodiversity” (ROK 2023)?
Table 1. Peak number of waterbirds recorded by the winter census at Muan International Airport and at several proposed airports, with additional support information.
| EIA conducted? | Approved? / Start Year of Operation | Number of Census Count Sites within 13km | Highest Census Count of birds at relevant census count sites | |
| Baengnyeong Island | No | Approved / 2030 | None | n/a |
| New Gyeonggi International, Hwaseong | No | Two locations being considered? | 3 completely (Namyang Bay, Namyang Lake, Daebu Island) | 132,124 (December 2015) |
| Seosan | No | Apparently approved | 4 completely (Ganwol Lake, Haemi Stream, Jamhong Reservoir & Seongnam Reservoir); & 1 partially (Cheonsu Bay) | 194,747 (November 2022) |
| Saemangeum | Yes | Approved (though current legal challenge)/ 2030? | 3 completely (Mangyeong River, Lower Stretch, Okgu Reservoir, Okryo Reservoir); 1 almost completely (Dongjin River) & 2 partially (Yubu Island, Geum Estuary) | 182,506 (February 2022) |
| Muan | Yes | Operational since 2007 | 1 completely (Muan Reservoir) & 3 partially (Muan-Mokpo Coast, Muan-Hyeongyeong Myeon & Aphae Do) | 62,729 (January 2021) |
| Gadeokdo | Yes | Approved (though current legal challenge) / 2030 | 1 almost completely (Nakdong River Estuary) & 1 partially (Geoje coast) | 37,824 (December 2015) |
| Jeju coast | Yes | Approved (though current legal challenge) / 2030? | 2 completely (Hado, Seongsan), 1 in large part (Seongsan-Namwon Coast) and 1 partially (Hwabuk-Seongsan Coast) | 33,944 (January 2021) |
| Heuksan Island | ? | Approved / 2028 | None | n/a |
| Ulleung Island | ? | Under construction / 2028? | None | n/a |
In addition to the winter bird census (which is referenced in some EIAs but not in others), there are a smaller number of shorebird counts conducted by the Shorebird Network Korea (2010-2015), with survey and publication supported by Shinan County government and the Ministry of Oceans and Fisheries. These counts have clear potential relevance to ongoing runway extension at the Muan International Airport. And there also peer-reviewed papers on e.g., Saemangeum and the Hwaseong Wetlands (e.g., Moores et al .2016, Lee et al 2018; Moores et al. 2022). There are also extensive data sets on migratory landbirds which have been generated by the Korea National Parks Migratory Bird Research Centre on Heuksan Island for two decades; and of course, there are also data sets generated during environmental impact assessments conducted for reclamation projects and for the airports themselves. Many of these are accessible through the Environmental Impact Assessment Support System (EIASS).
There are few government or formally published datasets for Baengnyeong Island and Ulleung Island, and to the best of our knowledge, there has been no formal EIA conducted for the proposed Baengnyeong airport. Fortunately for decision-makers, we have been conducting research on Baengnyeong Island since 2013. We have published one report highlighting biodiversity hotspots already; and we have shared a lot of count data offline and online, including through eBird and in national media. It is therefore somewhat surprising that we have not yet been contacted by airport proponents to share any of our data; and we have not been asked to provide any advice as part of any consultative process. This appears to be contrary to guidance provided by ICAO (1987), Section 2.2, which advises that, “it is essential that the master planning team co-ordinate its efforts and seek the advice of these interest groups prior to and during the critical stages of the master plan.”
3. Development of Wildlife Hazard Management Plans
ICAO (2020) provides detailed guidance on the development of Wildlife Hazard Management Plans, including an assessment of the bird strike risk for “existing and new aerodromes, including expansion projects” (Section 1.3.8).
As stated in ICAO (2020) Section 1.1.3. “Wildlife risks fluctuate with the daily and seasonal cycles of wildlife activity. The species and number of wildlife at and around aerodromes may vary over the years due to land use and environmental changes (e.g. agricultural practices, urbanization, conservation and climate change). Aerodromes have site-specific characteristics regarding their habitat, climate and surroundings that should be reflected in their respective Wildlife Hazard Management Programmes (WHMP). Increased air traffic and the development of quieter aircraft engines may increase the likelihood of a wildlife strike. Wildlife hazard management methods and techniques should therefore be reviewed annually and updated regularly to ensure that effective control methods are implemented.”
In this understanding, ICAO (2020) advises:
- Wildlife Hazard Management Plans should extend out to at least 13km from airport operations;
- Research should be conducted on “the type of wildlife activity and movements (for example: direction and altitude)” (Section 2.2.4.3 a);
- “Wildlife surveys should cover the entire year to account for seasonal changes and should also consider different phases of the day. The survey should also consider aircraft movements, runways in use and wildlife behaviour” (Section 2.2.4.6);
- “The aerodrome should keep a record of areas with wildlife attraction or concentration in the aerodrome and its vicinity. This inventory should lead to an analysis of the existing habitat and include reasons why wildlife species may be attracted. Certain habitats attract species for food, water or shelter. Examples include…large bodies of water that attract shorebirds and waterfowl…” (Section, 2.2.4.18).
We do not have access to any of the Wildlife Hazard Management Programmes or Master Plans of any of the proposed or existing airports in the ROK. However, we do – along with everybody else – have access to the environmental impacts assessments for several of these projects.
Based on our reading of ICAO materials, we would have assumed that the research for the EIA or EIS for each of these airport projects will have been organized to identify potential alternative sites; to have gathered all available literature; and then thoroughly investigated the bird strike risk once the airport site had been decided.
As ~90% of all bird species in Korea are migratory, we would also have assumed that research on birds would have been conducted through one or more annual cycles; and that a multitude of research approaches would have been taken, including long periods of fieldwork spent recording the movements of birds flying across the proposed runway area and employment of radar (to record height and direction of flight, especially at night).
None of the four EIA I have so far independently reviewed contain such research.
In the case of the Muan International airport, bird surveys for the original EIA were conducted for a total of about 12 days (August 26th-28th 1997; November 6th-8th 1997; and June 1st to 3rd 1998). Although there are references to ICAO in some places, on page 194 the commentary includes the observation that it would be “unreasonable to grasp the overall site based on the short survey period”. Based on this, the commentary on page 229 then asserts that, “The number of birds does not appear to be very large, so if you pay attention to preventing collisions with some birds during operation it is judged that there will be no significant impact” (EIASS 1998; EIASS project number ME1999H003).
A follow-up EIA was conducted for the runway extension (EIASS 2022: project number YS2021H001). This included literature review, which included the winter census data but for only two winters, and did not include the Korea Shorebird Network counts (p. 154). This literature review, combined with six more days of field work, indicated the presence in the wider region of 27 bird species which are either nationally threatened or which are national monuments (Table 7.1.1-15). The fieldwork found 745 Tundra Bean Geese, as well as large-bodied soaring species including White-tailed Eagle and Oriental Stork, the latter within about 100m of the runway (Figure 7.1.1-15, p. 155).
This research similarly (and it appears, correctly) asserted that, “When flocks of geese and storks move to arable land, wetlands or the coast near the airport area, collisions with aircraft are expected” (p. 162).
Even though this assertion was based on very limited survey, it is an obvious conclusion that should have raised deep concerns for aircraft carriers and airport managers. All along the west coast of the ROK and on islands like Baengnyeong, flocks of geese during migration and winter roost in open areas, usually on or very close to water. Before and at sunrise, they then flight out to feed in rice-fields. Many will try to feed in nearby fields; others will fly further. Our own research in Hwaseong suggest that some geese likely commuted 20km or more one-way. During the morning, many of the geese will then rest in the same fields, or fly back to their preferred roost area, to drink water (helping with digestion) and to rest, before flying back out to feed again in the afternoon.
Based on this behaviour at other sites in the ROK, it therefore seems highly probable that Tundra Bean Geese in Muan would try to use Muan Reservoir immediately to the southeast of the runway for roosting. If there was disturbance at the reservoir, however, they would then likely congregate instead at low tide on the adjacent tidal flat. From there, the geese would then commute to rice-fields to feed, initially at sunrise, and then through the day in smaller flocks. Either way, this means that several hundred geese would likely commute across the runway on multiple dates between October and March. As Tundra Bean Geese have substantial mass, collision with a flock could be predicted to be very harmful to aircraft during take-off or landing.
Formal assessments for the proposed new airports on Jeju, at Saemangeum and at Gadeokdo in Busan are similarly flawed.
The Saemangeum EIA (MLIT 2021) lacked proper literature review and claimed throughout that there would be few impacts. Bird research, however, was conducted in only ten months (October 2020-July 2021); and appeared to be conducted largely by five counters, who apparently tried to survey 52 areas (at furthest >13km from the airport), over only 30 days in total (p. 405). Three nocturnal surveys were also conducted. Although valuable in establishing baseline data on abundance, distribution and species richness, the research effort is inadequate to assess the bird strike risk.
Instead of fixed point counts over or near the proposed runway area, wildlife camera traps were deployed (which cannot capture flocks of birds in flight) and tracks from GPS telemetry or a similar method of remote tracking were included (Section 11.1.1.1 – 54). Only 27 birds were tagged. None were captured within 3km of the proposed airport. Instead, based on coordinates, they were tagged 4.66km-12.5km from the proposed runway area, so if tagged in preferred habitat might reasonably be expected to remain largely in that area, and away from the proposed airport area.
Fortunately, ten Great Cormorant Phalacrocorax carbo were tagged. Five of these flew directly across the proposed Saemangeum New International Airport area, presumably between feeding and breeding sites. Great Cormorant has a mass of at least 2.3 kg (Hatch et al. 2020), up to 2.6–3.7 kg (Birds of the World 2025) and often forms flocks of thousands in the Saemangeum area. The table on page 501 lists counts of 13,330 Great Cormorant in November and 16, 353 in July within 3km of the proposed airport, and Oh Dong Pil reports that he has counted 38,000 there (unpublished data). Bird strike involving a flock of Great Cormorant Phalacrocorax carbo and a military aircraft has also already been documented, on October 5th 2021 at 35.92976111, 126.60893611 (within approximately 700 m of the proposed runway). Great Cormorant therefore poses an obvious very high safety risk to aircraft. Remarkably, however, generalized descriptions of safety risk posed by different species groups given on pages 830 onwards in MLIT (2021) exclude cormorants.
As at Muan, the risk of bird strikes with geese at Saemangeum seem to be expected, especially at dawn and dusk (p. 830).
In Busan, the Strategic Environmental Impact Assessment for the proposed Gaeokdo International airport similarly contains a lot of information on birds within a 13km radius of the proposed airport. However, data are not interpreted in ways that facilitate an assessment either of the likely impacts on biodiversity at the national or regional level, or of the real bird strike risk. Apart from 15 dates in May of survey of six species of raptors >1km from the proposed runway, there is no research which can be used to assess either the scale of bird migration through the proposed airport area or provide an evidence-based assessment of bird strike risk.
In my opinion, the terrible inadequacy of these Environmental Impact Assessments is not, in most cases, due to the poor level of the researchers. Some of the research is excellent. Instead, it is much more a result of the extremely tight deadlines imposed on research; and the result of what appears to be a general lack of interest in or concern about the bird strike risk.
Finally, we do not yet know what the investigation into the Muan air crash will find. Two things do seem certain, however. The first is the prolonged suffering of all those impacted by the Muan air crash – our sincerest condolences to them. The second is that if safety really is the priority, then a review of airport safety needs to consider not only aircraft maintenance and permanent hazards. It also needs to include a comprehensive and transparent reassessment of the bird strike risk.
As always, please let us know if you see any errors in the above. Thank you.
Further Reading
Gadeokdo:
“Eleven dates of Fixed Points Counts overlooking the runway area of the proposed Gadeok Do airport, Busan: an independent evidence-based assessment of bird migration and bird strike risk.”
Saemangeum New Airport: Initial Opinion Statement, March 2024, submitted to the court in May-June 2024
Acknowledgements
Sincere thanks to Dr Kim Nahee for sharing documents on the Muan International airport; and to those on Jeju, in Busan and at Saemangeum for providing information for earlier posts.
Background to this post: Birds Korea is an independent NGO. I have a PhD in the conservation of avian biodiversity; field experience at all nine sites shown in Figure 1, ranging from 2-3 dates at sites like Muan and in affected parts of Ulleungdo, to more than 200 days of fieldwork at both Saemangeum and Baengnyeong; I have led peer-reviewed papers on two of the sites; and for Birds Korea and local groups, I have independently reviewed four Environmental Impact Assessments for airports (proposed Jeju Second, proposed Saemangeum New International, proposed Gadeokdo and Muan International). In 2024, I gave expert testimony in an ongoing legal challenge to the Saemangeum New International airport, to express grave concerns about the bird strike risk and impacts on biodiversity and to highlight flaws in the EIS.
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