Metropolitan Nashville Airport Authority MEMORANDUM TO:

Robert R. Wigington, President and CEO

CC:

Doug Kreulen, Senior Vice President and COO Stan Van Ostran, Vice President and CFO Aaron Evans, Director of Operations Chris Ricketts, Operations Airside Manager

FROM:

Julie Zwicknagel, Internal Audit Coordinator

DATE:

April 8, 2015

SUBJ:

Wildlife Hazard Management Plan Audit Report

Background The Metropolitan Nashville Airport Authority’s (“Authority”) Operations department is required by FAR Part 139.337 to have a Federal Aviation Administration (“FAA”) approved Wildlife Hazard Management Plan (“WHMP”), which was approved in April 2013. Part 139.337 also requires Operations personnel responsible for the implementation of the plan to attend initial and recurrent wildlife training conducted by an FAA approved airport wildlife biologist. These requirements are addressed in the FAA approved Airport Certification Manual (“ACM”) for the Nashville International Airport. In accordance with FAR Part 139, the Authority recognizes the threat wildlife pose to aircraft operations and takes measures to minimize those threats. The WHMP presents recommendations and procedures for preventing or reducing wildlife hazards at the Nashville International Airport.

Objectives The objectives of the audit were as follows: 1. Determine compliance with the WHMP; and 2. Document and evaluate existing internal controls.

Testing In order to satisfy the audit objectives, the following tests were performed: 1. Determined wildlife population control and management recommendations identified during the Wildlife Hazard Assessment have been implemented or addressed on a continual basis, including but not limited to the following: a. Grass management. b. Removing brushy areas. c. Construction projects. 2. Reviewed onsite wildlife population monitoring and management processes. a. Determined Operations personnel were performing daily inspections. i. Determined Operations personnel were checking the airfield for wildlife activity on a daily basis. ii. Determined Operations personnel were conducting full length inspection of active runways on a daily basis. b. Determined Operations personnel were inspecting the perimeter fence line once per week to monitor the population of large mammals and the presence of wildlife on the airport. 3. Reviewed offsite wildlife population monitoring and management processes. 4. Determined Operations personnel were documenting wildlife strikes as required by the FAA. 5. Determined Operations vehicles were not properly equipped to address wildlife hazard management activities. 6. Determined compliance with the US Fish and Wildlife Service migratory depredation permit requirements. a. Verified a written application was submitted at least 30 days prior to the expiration date of the permit. b. Verified annual report was submitted to the Regional Migratory Bird Permit Office. c. Verified shotguns used to take migratory birds were no larger than 10-gauge. 7. Determined Operations was not complying with the annual review of the WHMP representative requirements. 8. Determined Operations personnel attended annual wildlife training. 9. Determined compliance with the WHMP Tools Inventory and Training Manual. a. Determined Operations was not following proper purchasing procedures when purchasing ammunition. b. Reviewed inventory control procedures surrounding weapons and ammunition. c. Determined internal controls surrounding the security of equipment and inventory items should be strengthened. i. Verified ammo boxes were secured with two locks per box. ii. Verified weapons were secured in gun cases when they were not in use in the Operations vehicles. iii. Verified other weapons were stored in the gun safe when they were not in use.

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10. Through inquiry and observations, reviewed the existing internal controls in place.

Conclusion Based upon the audit, the following was determined with respect to the stated objectives: 1. Operations vehicles are not properly equipped with fire extinguishers, as noted in finding #1. 2. Operations is not complying with the annual review of the WHMP representative requirements, as noted in finding #2. 3. Operations is not following proper purchasing guidelines when purchasing ammunition, as noted in finding #3. 4. Internal controls surrounding the security of equipment and inventory items needs to be strengthened, as noted in finding #4.

Finding #1 Observation Operations vehicles are not properly equipped with fire extinguishers. Background The WHMP requires Operations vehicles regularly operating on the airfield to be equipped with the following equipment items: • • • • • • • • • • •

Bird strike collection kits Bird identification book Binoculars Computer Fire extinguisher Gloves Pavement brooms Pyrotechnic launchers Safety glasses Screaming and exploding pyrotechnics Two-way radio

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An objective of the audit was to determine Operations vehicles were properly equipped to address wildlife hazard management activities. Through audit testing, Internal Audit inspected both Operations vehicles and determined both vehicles were properly equipped with all the aforementioned equipment with the exception of fire extinguishers. Recommendation Operations should ensure both Operations vehicles are properly equipped with fire extinguishers. Management Response Fire extinguishers have now been placed in both Operations vehicles.

Finding #2 Observation Operations is not complying with the annual review of the WHMP representative requirements. Background According to the WHMP, Review of WHMP – 14 CFR Part 139.337 (f) (6): Periodic evaluation and review of the WHMP. “One meeting per year will be held with representatives from the following parties to evaluate the WHMP. The results of the review will be documented and submitted to the FAA. • • • • •

Airport Manager or Designated Representative Director of Operations Operations Department Maintenance Department Other Agencies as needed”

An objective of the audit was to determine the WHMP has been reviewed on an annual basis and results of the review were submitted to the FAA. Through audit testing, it was determined that on January 16, 2014, the WHMP was reviewed and the results of the review were properly submitted to the FAA. However, not all of the required representatives were present for the annual review of the Plan. In attendance were the Operations Airside Manager and an Operations Specialist. Therefore, only 2 out of 7 Operations personnel were present. Additionally, no one from the

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Maintenance Department or Airport Manager/Designated Representative was in attendance for the annual review of the WHMP. Recommendation Operations should ensure all required representatives are present for the 2015 annual review of the WHMP. Management Response Operations conducted the annual WHMP review meeting on April, 7, 2015. All required representatives were present for the meeting. These representatives included the Director of Operations (airport manager designated representative also), Operations staff, Maintenance Grounds team leader, and USDA Wildlife Services airport biologist.

Finding #3 Observation Operations is not following proper purchasing guidelines when purchasing ammunition. Background According to Section 4, Prohibited Use for P-Cards, of the P-Card Policy, “Examples of prohibited purchases include: • • • • • • • • • •

Personal use Any transaction of $10,000 or more shall be directed to the Purchasing Department to follow the approved policy/process #301-1 Split transactions of multiple like or unlike purchases from the same vendor (recurring or serial purchases used to avoid bidding process). Cash advances Cash refunds from returned card purchases P-Cards cannot be taken and used for meals when traveling for business Firearms/ammunition (need to be purchased on a purchase order) Gift cards (a check request through Finance must be completed for gift cards) IT items to include laptops, iPad, cell phones, etc. Entertainment purchases”

An objective of the audit was to determine Operations was following proper purchasing procedures when purchasing ammunition. Through audit testing, it was determined that there

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was a P-Card purchase on July 14, 2014, for 12 gauge ammunition for wildlife control, which is a violation of the P-Card policy. A copy of the receipt is provided below.

In addition, the ammunition purchase was coded to the environmental/energy services (510550) expense code instead of the wildlife management (510380) account. It should be noted that this same issue of purchasing ammunition with a P-Card was identified in the P-Card audit report dated April 23, 2014. Recommendation Operations should follow proper purchasing guidelines when purchasing ammunition and code ammunition purchases to the wildlife management expense code.

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Management Response Operations will now utilize the check request process to purchase ammunition for the wildlife program. These expenses will be coded to the wildlife management expense code. P-Cards will no longer be used to purchase ammunition for the wildlife program in accordance with the P-Card policy.

Finding #4 Observation Internal controls surrounding the security of equipment and inventory items needs to be strengthened. Background According to Security of Equipment and Inventory, of the WHMP Inventory and Training Manual, "The Operations Department maintains equipment and inventory in a secure location in a storage room utilized by Operations only. A gun safe is utilized to secure shotguns and the pellet air rifle when they are not in use. Normally there is a shotgun in each Operations vehicle to conduct wildlife activities. When weapons are not in use in the Operations vehicles they are secured in cases. In the event vehicles need to be serviced or utilized for other purposes the weapons are removed and stored in the gun safe. Ammunition and other dispersal inventory are stored in one of two ammo boxes approved by the United States ATF for ammo storage. These boxes are also located in the Operations storage room and are secured by two locks per box." An objective of the audit was to determine the security of equipment and inventory items the Operations department maintains in a storage room utilized by Operations personnel. Through audit testing, Internal Audit observed an Operations Specialist retrieving keys for the gun safe and ammunition boxes from the bottom drawer of an unlocked filling cabinet. It should be noted that the gun safe and ammunition boxes were properly locked but the internal controls surrounding the security of the equipment and inventory items needs to be strengthened. Recommendation Operations should install a lock box in the Operations storage room to properly secure the keys for the gun safe and ammunition boxes.

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Management Response Operations has purchased and installed a key lock box in the secure Operations storage room to store keys to ammunition boxes and the gun safe.

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