Tuesday, March 1, 2011
Public? Aircraft Operations
The past two presidents of HAI, Roy Resavage and Matt Zuccaro, must be complimented for promoting a balanced approach to public aircraft operators. In the early 90’s some of the folks in HAI were … less than gracious to public aircraft operators. It was during this time of “the troubles” as the Irish would call them, that a meeting attended by public aircraft operators and representatives of both the FAA and HAI focused on the issue of tracking “Public Aircraft” accidents. The public aircraft operator’s position was that aircraft owned and operated, by a political subdivision of the U.S., should be tracked separately vs. those aircraft flown by a commercial company on contract to a government entity.
For the purposes of this article, let’s call the first group “government public aircraft” and the second group “contracted public aircraft.” The opinion expressed by the “government public aircraft” operators was that their safety record should stand on its own—good, bad or indifferent. HAI personnel attending this meeting were insistent that the two groups be combined into one. A cynic would suggest that HAI wanted to cook the books. Eliminating the high-risk missions inherent in “public aircraft” operations such as firefighting, geodesic survey and game counts, and that this action would enhance commercial operator’s accident profile. HAI’s argument prevailed and to this day, both sides of the public aircraft accidents are recorded together. Safety is a product of culture within each operation. “Government public” and “contracted public” aircraft involve two different cultures. Until these groups are separated in terms of accident statistics, effective action to mitigate casual factors for accidents within these groups is a pipe dream.
In 2006, one of the first International Helicopter Safety Team (IHST) meetings was held in Carmel, Calif. In its effort to reduce accidents by 80 percent over a 10-year period, IHST recognized that it was imperative to start from a good statistical base. The shorthand version of IHST’s course of accident mitigation is to isolate similar safety cultures and identify and correct the highest risk factors in that culture. The fellow who was assigned to do the statistical analysis of these figures did exactly what the “government public aircraft” operators had feared; he presented the data as collected and combined the two groups into one. When observers pointed out that this really involved two separate cultures, he noted that this data was, in fact, corrupt and there was no way to correct it. Furthermore, NTSB’s findings concerning public aircraft accidents over the last 15 years have consistently complained that the data being used to compile accident rates is suspect. One NTSB quote indicates that the hours flown by public aircraft operators may be underrepresented by as much as 19 percent. This falls back onto FAA, which is responsible for tracking these numbers. If you think that’s going well, read the December 2010 articles where FAA admits that it has lost track of the registration of 119,000 aircraft in the U.S. Not only does FAA need to separate the two distinct groups of public aircraft, it also needs to do a much better job of collecting the data necessary to evaluate accident trends.
On Oct. 12, 2010, USA Today published an article titled “NTSB finds lapses in smoke jumper crashes.” In my opinion, this article is wrong from its title forward. There were no smoke jumpers involved in the accidents listed. The article attempted to point out deficits in U.S. Forest Service oversight of the Carson Helicopters crash of Aug. 5, 2008. Two of the accidents cited were wing separations on air tankers, and the reality is I don’t think enhanced oversight by the USFS or the FAA would have foreseen these accidents. One of the accidents occurred in Afghanistan. I don’t know how many trees there are in Afghanistan, looks like a lot of rocks to me. Using a war zone accident to criticize the USFS seems a bit of a stretch. In the article, Jim Hall, former NTSB chairman, stated that aircraft operated on behalf of the government “are orphans of the safety system.” Really, notice the words “on behalf,” the majority of accidents causing these problems fall into my definition above “contracted public aircraft.” I would use an actual figure of merit to define “majority” in the sentence above, but guess what, those figures are not available, see paragraphs one and two above. Here is my take on this; Carson Helicopters is an FAA certificate holder under several different sections of the FARs to include operations, manufacturing and maintenance. Carson Helicopters’ culture of safety is generated in that environment. The casual factors noted by NTSB were in place while the aircraft was under FAA jurisdiction. The weight calculation of the aircraft, the seats and harnesses installed in the aircraft, the fuel cell in the aircraft, the filters on the engines of the aircraft, the performance charts used by the pilots, the way the supplemental type certificates were worded—all of these were criticized by NTSB. Dear reader, does any of this sound to you like the USFS had any input on these issues? As we go forward to do a better job in safety, what we don’t need is a hit piece by somebody trying to sell newspapers, or public officials making sweeping remarks that aren’t focused on specific issues that can be identified and corrected.
A commercial helicopter operator exists to generate profit while providing a service to its clients. Government flight operations inherent reason for existence is to enhance the governance, safety—or both—of its constituents. For the purposes of this argument, I am defining risk as the risk imposed by actual in-flight operations, exclusive of financial and other real risks to the commercial company. Commercial operators should only accept the risk that is consistent with appropriate profit. The commercial operator should always seek out those contracts with the maximum profit for the least risk involved. But inherent in this statement is the realization that potential profit and risk are on a sliding scale and hopefully as contracted flight services go up in risk, the profit to the company improves. The government’s regulatory agencies function to protect the public good. Since the general public doesn’t have the knowledge base to assess the risk component of any given flight, they must rely on the government to set boundaries consistent with the public good. Let me state that the term “profit” as defined by the operator and the public good are two mutually exclusive terms. Profit is not in the FAA’s dictionary and probably shouldn’t be. We must realize even in strictly commercial operations, the federal regulations operate on a sliding scale between inherent risk and public good. Think of the nature of the regulations that govern scheduled airline service, on-demand charter operations, external load work and finally agricultural operations. Starting with the least risk-intensive, scheduled airlines and onto the most risk-intensive, agricultural flying, two elements are present; those individuals being subjected to the inherent risk of the operation are assumed to have a better understanding of risk as it grows, and the perceived gain to society is enhanced as the risk goes up. One hour of scheduled airline operations equals small risk and gain to the public good. One hour of agricultural flying has a much higher risk with the potential to feed many—much greater public good. “Government public aircraft” risk vs. gain assumptions should be driven by the enhancement of governance, public safety or both. If a government public aircraft is performing missions outside this scope, then in my opinion they have exceeded the intent of the law. The risk factor inherent to some “government public” mission profiles lay outside of the normal structure of the FARs and need to remain so. For example: swift water rescue as practiced in Southern California by multiple “government public aircraft” agencies involves hovering over rushing water in a cement channel with a rescuer retained on a 35-foot rope off of a non-certified rigging system. Propose that to the FAA and see what happens.
Finally, to clarify the scope of public aircraft operations, I suggest the following additions to Part 1 of the FARs: “Search and rescue is any flight operation by a public aircraft where a person is flown out of harm’s way to an appropriate collection point or medical receiving facility. All flights conducted to enhance governance or public safety will be considered SAR during periods of declared emergency by any political subdivision of the U.S.”