Comedian George Burns once said, “Too bad all the people who know how to run this country are busy running taxis or cutting hair.” The comedic centenarian was poking fun at the abundance of opinionated folks who felt that they knew more about politics than the politicians. Unfortunately, there is a list of others who would place themselves at the forefront of the aviation safety opinion peddlers, claiming their own knowledge of aviation far exceeds that of the Federal Aviation Administration (FAA). That list would include self-described aviation experts and the National Transportation Safety Board (NTSB). The self-described authors cannot change; the NTSB can.
An FAA friend of mine asked me if I really did dislike the NTSB. I said, “I don’t, I really don’t.” What I do find to be the NTSB’s weakness is their inability, after fifty-three years, to explore Root Cause Analysis and comprehend its benefits. The NTSB, instead, ‘bangs the table,’ criticizing aviation concepts that they can’t understand to move agendas which are paths to nowhere.
On February 20, 2020, the NTSB called, “for a comprehensive effort to improve aviation safety in Alaska,” due to Alaska’s high accident rate. The NTSB titled its aviation recommendation: ASR-20/02, “Comprehensive Alaska Aviation Safety Approach Needed”. ASR-20/02 was written to revise the FAA’s processes for overseeing Alaskan operators, particularly Part 135 operators, but it won’t
Per the NTSB report, “From 2008 to 2017, the total accident rate in Alaska was 2.35 times higher than for the rest of the United states. The fatal accident rate in the state was 1.34 times higher, according to NTSB statistics.” The NTSB have taken this track before, particularly when the Sunshine meetings are held. NTSB Board Members exaggerate statistics; they spout half-truths in feigned disgust. As with sunshine meetings, ASR-20/02, unfortunately, is deceptive; it is a chance for Board Members to get camera time, not address a problem. NTSB Chairman Member Sumwalt is a very intelligent man; I do believe his intentions are sincere. However, ASR-20/02 is a mischaracterization of facts; it serves little purpose in proposing solutions.
First, to suggest that fatalities are a product of some gruesome numbers game is a stretch, like comparing apples to orangutans. Fatal accidents are a product of two things: opportunity and occupants. Opportunity means that if an aircraft’s engine quits over hundreds of square miles of forest, as opposed to over hundreds of square miles of clear fields, chances are the landing will not be survivable. Occupants means if a widebody passenger jet crashes with 300 souls onboard it would take 75 four-passenger single engine aircraft accidents to equal that fatality number. This is deceptive; fatality rates are not a product of safety. Fatality rates only elicit emotional responses from the public.
The concept that Alaska presents many distinctive aviation safety problems is not new; no one argues that Alaska’s unique environment makes for unique challenges. To get some perspective, Alaska’s land area is 571,951 square miles, roughly 20% the land area of the ‘lower forty-eight’, the contiguous United States, which has a total land area of roughly 3,000,000 square miles. The FAA oversees the state of Alaska’s non-major air carriers with a few offices with perhaps 100 inspectors.
In addition, Alaska has glaciers, thousands of square miles of forests and lakes; numerous scattered towns that are not accessible by roads – including the capital, Juneau – but are only accessible by water or air. Hundreds of aircraft pilots operate in these extreme conditions, flying into areas that challenge the rules just so as to supply native Alaskans with basic essentials.
The Alaska FAA inspectors cannot provide constant on-site oversight; they have limited resources, e.g. transportation, to reach these places or help establish safe alternatives. The FAA has restrictions to how they can visit these hundreds of operators’ pilots and their maintenance facilities. These inspectors are subject to extreme weather conditions, the same that dictates how Alaskan aviation folks operate, how they can reach their customers. Oil fields in some of the human-challenging locations, test the mettle of the Alaskan aviation community. These are the realities of the Alaskan environment. People working in Washington, DC cannot grasp these challenges.
Then one must understand the FAA as it exists today. Programs have been implemented, such as the FAA’s Safety Assurance System (SAS) program, one of many effective safety programs honed over years to improve safety and communication between the FAA and industry. The FAA introduced the SAS program with the commercial air operators, e.g. major air carriers, using its established industry to fine tune SAS – then called the Air Transportation Oversight System (ATOS) – before incorporating the smaller industry air carriers and repair stations into a next generation program.
The safety of Part 135 Air Taxis, On-demand operators, which the NTSB has placed on its Most Wanted List, now falls into this SAS program. Other successful FAA programs have been developed, e.g. Safety Management System (SMS), Aviation Safety Action Program (ASAP), Suspected Unapproved Parts (SUP) and the Voluntary Disclosure Reporting Program (VDRP). It would have been a welcome sight if, in my years of teaching at the FAA Academy, I had seen NTSB investigators taking these FAA classes to learn how ASAP, SUPs, SAS, VDRP or SMS programs work; how FAA inspectors oversee Part 135 operators; how the FAA’s success with the industry has increased safety. Why? Because the NTSB cannot improve safety if the average NTSB investigator does not understand how the FAA works.
When will the NTSB employ Root Cause Analysis instead of Probable Cause, aka Probable Guess? One has only to review past accidents in Alaska to understand how the NTSB missed important issues with the Alaskan Part 135 industry, e.g. the Ryan Air Services, flight 103 accident investigation, #DCA88MA004. Part 135 is so very different from major air carrier; in Alaska those differences are magnified. Part 135 issues focusing on paperwork or weight and balance, were overlooked completely. These mistakes resulted in Alaskan Part 135 aviation safety not being improved.
If, by being unaware of FAA programs, the NTSB will continue to miss opportunities, they will pass up numerous chances to improve safety and fail to spot the true threats to aviation safety. By focusing on Probable Guess instead of common sense, the aviation industry will be stuck in pushing ineffective agenda items, e.g. cockpit video cameras.
What, then, would be proactive measures that would improve safety in Alaska? The NTSB could use their influence with the United States Congress to put forth proposals to increase the budget for the FAA in Alaska, hire more inspectors and place them strategically so that they are more effective in the unique environment there. Push Congress for more inspectors to be hired, to supplement the need in Anchorage and Juneau. Those are ideas that would improve safety, common sense ideas that would work.
It would also prove productive if the NTSB hired investigators that were up to the challenge of the FAA’s jurisdiction; hire investigators that worked in the specific transportation industry, not just for Aviation, but for Rail, Highway, Marine and Pipeline, as well. Don’t limit the hiring of investigators to engineers who have no fundamental experience of working airplanes in an air operator or repair station capacity. Have these investigators take an FAA class, work side-by-side with an FAA inspector. Before ASR-20/02 came out, the NTSB should have had NTSB investigators work in the field with Alaskan FAA inspectors, in the most challenging months of the year when the inspecting conditions are most difficult.
It does nothing for safety if the recommendations coming from the Board have no teeth, no insight, no thought put into them. Chairman Sumwalt stated, “We need to marshal the resources of the FAA to tackle aviation safety in Alaska in a comprehensive way. The status quo is, frankly, unacceptable.” One expects the Chairman to add, “Harumph! Harumph!” Instead, the statement, “We need to marshal …,” suggests the NTSB is in this fight, shoulder-to-shoulder, with the FAA, but they’re not. The NTSB needs to be shoulder-to-shoulder, but more importantly, they must be supportive. The NTSB must understand what is going on; they must become experienced; they must be quick to aid with, not just words, but actions.
Is the constant condescension of the FAA’s work really necessary? Nothing is learned if the critic does not know that from which he or she speaks. While it is true that taxi drivers and barbers have opinions, they know can’t accurately judge politicians because they are not politicians. The NTSB does not hire FAA inspectors or the experienced. ASR-20/02 cannot be taken seriously; it won’t make us safe.