The most significant changes to accident reporting in years have generated mostly a negative reaction from the industry.
The challenge to the proposer, the National Transportation Safety Board (NTSB), will be to see if industry concerns can be accommodated while still achieving the spirit of the announced changes.
On Dec. 27, 2004, the NTSB suggested a number of alterations to the existing rules, specifically to broaden the definition of substantial damage (see ASW, Jan. 3, 2005). While this may yield more reports of breakage and breakdowns, it also may mean the NTSB would have to grow beyond its present budget to be able to cope with the added commitment associated with analyzing or investigating the incidents.
Among other things, the NTSB was proposing an expanded reporting of traffic collision and reporting system alerts known as resolution advisories (recommended escape maneuvers to either increase or maintain the existing vertical separation between aircraft). In addition, the NTSB proposed reporting of loss of information from a majority of an aircraft’s electronic primary flight displays, failure of an internal turbine engine component that results in the escape of debris other than out of the exhaust path, and to include damage to helicopter tail and main rotors that occurs on the ground (on the rationale that rotors provide the equivalent lift of wings, and therefore even ground damage to them should be reported).
The nay-sayers certainly make their point. For smaller helicopter operators, and most notably where aero medical evacuation is involved, bureaucratic airframe downtime may put lives in jeopardy. Crop-sprayers could lose irreplaceable time and contracts at the peak of their season. Both individual pilots and company accident records could be affected, and in many cases their new accident “history” would reflect a higher incidence. The dire economic consequences of reporting might well start breeding a genus of lawlessness within the industry. The cynicism generated by that attitude can severely erode attitudes toward safety and its bureaucratically generated economic consequences (loss of airframe utilization, added paperwork, hiked insurance premiums, contracts unable to be tendered due to “accident history,” identifiable data-base entry, etc.).
Reclassifying incidents as accidents would skew insurance and safety board statistics worldwide, leading to the sort of confusion that is always generated by officialdom “moving the goal posts.”
While the industry generally holds the NTSB in high regard, the National Air Transportation Association (NATA) questions whether any effective industry impact analyses have been carried out. The Helicopter Association International (HAI) refutes the analogy of rotor blades equating to aircraft wings, pointing out that rotor damage that extends to the drive train (mast or tail-rotor drive-shaft) is already an accident. However, rotor blades are changed frequently because of minor damage and erosion, unlike aircraft wings.
The views expressed on resolution advisories (RA) are especially relevant because of:
- Reduced vertical separation minima, as of Jan. 20, 2005, and the ease with which RAs can now be generated (see ASW, Nov. 3, 2003). Dr. Andrew Zeitlin (principal engineer at the Center for Advanced Aviation System Development) and United Airlines [UALAQ], below, suggest a solution whereby the Federal Aviation Administration (FAA) would, at its air traffic control centers, record the Mode-S returns. This would be a way out, but would require the FAA to implement a system whereby any RA report would trigger a data collection process.
- NetJets, Inc. makes the valid point that its RA reporting alone would produce 24,000 pilot reports a year. NetJets guess is that the U.S. aviation industry altogether would generate 250,000 RA reports per year. That number would inundate the industry and the NTSB with a huge mass of reports where safety may not be compromised.
- The Regional Airline Association (RAA) claims that unless there were the type of disclosure protection afforded in the Aviation Safety Action Program (ASAP) or flight operations quality assurance (FOQA) schemes, pilots would simply fail to comply.
- Perhaps RAs should be regarded as just another back-stopping safety tool (like wind-shear alerting, radar altimeter warning systems, weather radars, undercarriage alerts, overspeed clackers and enhanced ground proximity warning system alerts).
Clearly, the NTSB has much to consider as it wrestles with RAs, in addition to its other proposals.
Of the roughly 50 comments it received, we present below selected comments on RAs and on the loss of information from flight displays. Significantly, the NTSB has received no comments from the FAA.
Report all airborne collision and avoidance system (ACAS) resolution advisories when an aircraft is operating on an instrument flight rules (IFR) flight plan:
FromNetJets:
“In situations where the aircraft is operating under the direct control of Air Traffic Control (ATC), the current regulations require notification to the controlling ATC facility for clearance deviations. As a result, the notification and capture of data related to a RA can be achieved through the current ATC facilities and procedures without imposing an additional reporting burden on crewmembers or operators.
“All of NetJets flight operations are conducted while operating on an IFR flight plan, however many RAs occur while on a visual segment of the flight such as arrival at an uncontrolled airport.
“Noting the title of Board Form 6120.1/2 is ‘Pilot/Operator Aircraft Accident Report,’ it would appear that the use of this form would be appropriate.
“If the requirement to report RAs is implemented, a method for easy submission of data … is essential. A proposed modification of the current Form 6120.1/2 is included … that eliminates the data capture of irrelevant information.” From United Airlines:
“TCAS [traffic alerting and collision avoidance] RAs are relatively common events, especially on closely spaced parallel approaches, and along common arrival/departure corridors, where aircraft level off with 1,000 feet of vertical separation. Flight data recorders and Flight Operations Quality Assurance (FOQA) programs do not record any data regarding the geometry of the encounter or separation distance. This aircraft based data would be useful in determining pilot reactions to the RA, but not in determining what caused it.
“United suggests that a more useful method of gathering data on TCAS RAs is to use ground-based Mode-S sensors to record RA downlink reports. Every TCAS II-equipped aircraft transmits an RA downlink report any time an RA is generated. The FAA currently operates 23 long-range Mode-S sensors and 121 terminal area Mode-S sensors. Each of these secondary surveillance radars is capable of receiving RA downlink reports. The advantage of collecting data this way is that ground-based radar can provide information on the geometry and separation distance that cannot be obtained from aircraft-based data.
“If the NTSB were to set up a program to monitor Mode-S sensors for potential near misses, they could classify the severity of the events and, at the same time, quantify the performance of TCAS. Additionally, in cases where it is warranted, the NTSB could notify the airline/operator of the event and request flight recorder data, FOQA data, and/or pilot reports. This approach would be very useful in quantifying the number of near misses, TCAS performance and provide useful data to analyze the root cause(s) of the event. It would also limit reporting to those events deemed necessary and would not burden either the NTSB or airlines/operators with collecting unproductive data.”
From the Air Transport Association (ATA):
“Based on airline experience … we recommend that the Voluntary Aviation Safety Information-Sharing Process (VASIP) lead this effort. VASIP is a joint initiative by FAA and NASA to expand the information-sharing opportunities presented by burgeoning Aviation Safety Action Programs (ASAPs) and Flight Operational Quality Assurance (FOQA) programs … Utilizing this process, a focused approach for the collection and analysis of ‘hazardous and/or significant’ TCAS RA data could easily be developed and implemented.”
From the Regional Airline Association:
“ASAP RA data reported by pilots typically does not identify the flight number, registration, time/date/altitude and airway position/fix. If the NTSB is interested in further details of how/when RAs occur, the air carriers would need to invest considerable man hours to provide details before such events could be reported.
“Given the potential for significant reporting requirements and investigative disruptions, RAA requests that this proposal to report RA data be withdrawn. If our request is denied, then we request that the proposal be resubmitted … with an accompanying cost benefit analysis and an OMB [Office of Management and Budget] control number for the data to be reported.”
From the Aerospace Industries Association (AIA):
“There are already numerous safety initiatives and programs addressing TCAS Resolution Advisories. Programs such as the Voluntary Aviation Safety Information Sharing Program (VASIP) established by the FAA and the aviation industry have already been analyzed to identify specific risk areas and how best to implement strategies to manage those risks.
“The mandatory reporting of TCAS RAs … threatens the very spirit of voluntary reporting programs … [The airborne collision and avoidance system] RA system is functioning as it was designed to do, and we do not feel that adding another reporting item to the NTSB will benefit the industry.”
From the Air Line Pilots Association (ALPA):
“ALPA does not concur with the proposal to make every ACAS RA a reportable event, and strongly urges the Board to consider withdrawing that specific proposal.
“The FAA is the agency that would provide the critical, objective information (ATC voice communications and radar data) to the NTSB if the proposed change were implemented. The FAA is already the first in the notification chain when an RA occurs, and represents the most logical agency and the most efficient path for collecting the required information.”
From Dr. Andrew Zeitlin with the Center for Advanced Aviation System Development (CAASD):
“The purpose of ACAS is collision avoidance, not the provision of separation. As the senior member of the team that developed the ACAS collision avoidance logic, I can offer assurance that the design of ACAS logic is based on predicted time to collision, and its warning parameters are decoupled from ATC separation standards. A substantial fraction of ACAS RAs are issued when there is no actual loss of separation. Moreover, some RAs are merely preventive in nature, warning the flight crew against a particular vertical maneuver that could jeopardize vertical separation.
“It would appear that requiring the reporting of all RAs would result in a need to search many ‘haystacks’ of data in the hope of finding a ‘needle,’ i.e., an event indicating a safety problem.”
Report the loss of information from a majority of an airplane’s electronic primary displays (excluding momentary flickering):
From NetJets, Inc.:
“If an aircraft equipped with four (4) PFD/MFD displays experiences the loss of two (2) such displays, would it be a reportable event if the information is not able to be displayed on one of the remaining displays?
“If an aircraft equipped with four (4) PFD/MFD displays experiences the loss of two (2) such displays would it be a reportable event if the information is able to be displayed on one of the remaining displays?
“It would appear that the intent of the proposed rule is to require reporting of events in which the availability of information necessary to operate the aircraft is significantly reduced.
“As such, it would seem that [the] more appropriate data capture would be the reporting of occurrences involving the loss of two or more displays that result in total loss of primary flight or engine information, due to the inability to display the information elsewhere in the cockpit.
“A suggested amendment to the proposed change to 49 CFR 830.5(a)(9) is as follows:
“US dollars49 CFR 830.5(a)(9) Loss of Information, excluding momentary inaccuracy or flickering from display systems that are certified installations, from two or more of an aircraft’s certified electronic displays used to display primary flight or engine information, where all of the information lost cannot be reverted to a secondary display and is not available on a secondary instrumentation display.”
From the General Aircraft Manufacturers Association (GAMA):
“If the NTSB has identified a problem with the current reporting system for failures or malfunction of more than one attitude, airspeed, or altitude instrument (such as those displayed on an aircraft’s certified electronic display), GAMA believes that the NTSB should issue a Safety Recommendation to the FAA highlighting the problem.”
From the Aircraft Owners and Pilots Association (AOPA):
“The NTSB’s failure to adequately characterize the meaning of these terms [e.g., ‘majority’ and ‘electronic primary displays’] may lead pilots to unnecessarily report malfunctions of certain electronic displays that are inconsequential to the safe operation of the aircraft.
“For example, a pilot, while flying under visual meteorological conditions (VMC), experiences a malfunction in the aircraft’s primary navigation display and loses all available Global Positioning System (GPS) information, according to the proposed rule, the pilot would have to report the loss of information to the NTSB. Safety was never compromised by the loss of GPS information; the pilot simply reverted to an alternate means of navigation consistent with [his] training.” (The full set of comments may be viewed at http://www.ntsb.gov/alj/NPRM/default.htm)