Safety Recommendations Fall Short

For the pretense of progress, look no further than the recommendations submitted by an advisory committee and breathlessly endorsed by the Secretary of Transportation. Really, we could eliminate the committee and save tens of thousands, if not hundreds of thousands, of taxpayer dollars.

On 9 December 2010 the Future of Aviation Advisory Committee (FAAC) presented 23 recommendations to Transportation Secretary Ray LaHood on how to ensure the strength, competitiveness and safety of aviation. The committee’s 19 members came from airlines, airports, manufacturers, labor, academia and general aviation stakeholders. With members like Glenn Tilton, president and CEO of United Airlines, the line-up was a guarantee for conventional, status quo thinking. This was evident in the FAAC’s recommendations on “lap children” aboard airliners, in which the committee recommended more “education” of the flying public about the dangers of flying with lap children. The committee could have called for regulatory action to end the practice of “lap children” and properly restraining them in their own seats. (See Aviation Safety Journal, “Advisory Group Punts on ‘Lap Children’ in Airliners”)


LaHood waxed appreciation for the FAAC’s report, saying, “This committee has provided a valuable service to all members of the aviation community with this blueprint for the industry.” But did LaHood carefully review the FAAC’s recommendations? Apparently not, because in the next breath he said, “I look forward to thoroughly reviewing the recommendations.”

We will save him the time, focusing on the FAAC’s specific safety recommendations (other than lap children restraints discussed in elsewhere in this publication):

Item:Delivering the benefits of NextGen. The Secretary should fully endorse and focus on ensuring that FAA delivers the operational capabilities, procedures, and approvals necessary for operators to realize the benefits from the NextGen air traffic control system as quickly as possible..” The discussion goes on for more than a page in this vein, with not one word about the improved safety the system is supposedly going to provide.

Comment: NextGen rests on the capabilities of ADS-B (automatic dependent surveillance, broadcast) to cram more airplanes into the nation’s crowded skies and airports. The system is automatic in the sense that airplane avionics do not have to be queried by radar. Rather, the system on the aircraft relies on navigation signals from global positioning system (GPS) satellites in space, and other on-board avionics, to automatically generate key elements of the airplane’s location, altitude, speed, and so forth.

It is dependent, in the sense that ground stations rely on the aircraft to reliably broadcast its navigation solution and other identifying parameters. Many of these factors, such as the aircraft’s horizontal (i.e., lateral/longitudinal) position have heretofore been determined by ground radar.

The term surveillance refers to the need for ground control to know where airplanes are in relation to each other.

The term broadcast refers to the airplane’s new role in providing this information, making the airplane a much more active – as opposed to traditionally passive – participant in the air traffic “solution,” as it were.

“ADS-B Out” refers to transmissions from the aircraft to air traffic control to enable aircraft to be spaced closer together in the air routes. But “ADS-B In” would enable an ADS-B equipped aircraft to receive information from other aircraft and from the airport. This “ADS-B In” capability is not being required. Thus, operators have until 2020 to equip their aircraft with “ADS-B Out” but “ADS-B In” will be addressed in separate rulemaking.

Nor has the FAA appear to have addressed the vulnerability of ADS-B to jamming of the GPS signals. It has been demonstrated that a 1-watt jammer will block GPS signals for many miles around an airport, disrupting ADS-B’s central role in descent and landing under the NextGen concept.

There are stacks of reports issued by the Government Accountability Office (GAO) and the Department of Transportation Inspector General (DOT/IG) indicating that NextGen is in trouble. Here are just four comments:

GAO, November 2010: “FAA has yet to make many key decisions reqired to shape and determine the future direction of NextGen.”

GAO, July 2010: “Without specific goals and metrics for the performance of NextGen as a whole … it is not clear whether NextGen technologies, systems, and capabilities will achieve desired outcomes and be completed within the planned time frames.”

DOT/IG, April 2010: “Key multibillion dollar programs have experienced problems, and the FAA has yet to fully determine their NextGen-specific requirements.”

DOT/IG, March 2009: “To highlight trnsition issues and establish requirements, FAA must complete its ongoing ‘gap analysis’ of the current and vastly different NextGen systems and refine the NextGen mid-term architecture.”

This is a program in mounting technical difficulty, with plenty of potential for cost overruns and performance deficiencies. The FAAC limited itself to generalized fretting, along the lines of “fully leveraging … ADS-B” and “the Secretary should require the FAA to develop and commit to a timetable when requirements will be set …”

One gets the impression that the FAAC was not even aware of the absence of “ADS-B In” during initial implementation, or the vulnerability of building the whole NextGen edifice on GPS signals that are easily jammed.

The safety improvements the NextGen is hoped to bring, in terms of incidents or accidents avoided, has yet to receive even token discussion.


Item:Legal Protection of Voluntary Safety Data and Information. The Secretary of Transportation should seek comprehensive legal protections for voluntary and mandated safety data programs and information to ensure their continued benefits to safety … the development, analysis, documentation and availability of shared safety information will be inhibited if there is potential that it may be used for other purposes such as out-of-context exposure through the media, admissions in criminal or administrative prosecution, or use in civil litigation.”

Discussion: It is a classic industry ploy to decry “out-of-context exposure through the media” when in truth the agenda here is to keep embarrassing information out of the newspapers and TV news. It should be noted that Aviation Safety Action Program (ASAP) reports are fully available to outside sources and there has never been a concerted industry complaint that media exposure took things “out of context.”

Recall the FAA argument on reporting bird strikes:

“The agency is concerned that there is a serious potential that information related to bird strikes will not be submitted because of fear that disclosure of raw data could unfairly cast unfounded aspersions on the submitter… [and] The complexity of the information warrants care with its interpretation; releasing this information without benefit of proper analysis would not only produce an inaccurate perception of the individual airports and airlines but also inaccurate and inappropriate comparisons between airports/airlines.”

Secretary LaHood overrode these concerns and ordered that bird strike data be made publicly available. These same tired arguments are being raised again about safety programs, and LaHood’s response – contrary to the FAAC views – should be the same as it was for bird strike data.

Moreover, if the FAA were to mandate programs such as Safety Management Systems, rather than encourage their voluntary adoption, and let the results speak for themselves, the public would get a better appreciation for the industry’s commitment to safety.


Item:Predictive Analytic Capabilities for Safety Data and Information. Beginning with the FY2012 budget for the FAA, the Secretary should provide focus, priority, and resources to develop improved tools and methods in order to provide a robust aviation system predictive safety risk discovery capability.”

Discussion: Such a program has already been developed and was actively suppressed by the FAA and the aviation industry. In 2007, under the imprimatur of the National Aeronautics and Space Administration (NASA), a program was developed known as the National Aviation Operational Monitoring Service (NAOMS). It was an innovative attempt to identify emerging risks through structured interviews of pilots, air traffic controllers, flight attendants and mechanics.

NASA was criticized by the FAA and industry for releasing the data, which contained a far greater number of incidents of safety problems than reported elsewhere. For example:

  • Hundreds of incidents where aircraft had uncommanded movements of rudders, ailerons, spoilers, speed brakes, etc., in flight.
  • 2,339 incidents where Air Traffic Control refused pilot requests to alter course due to severe weather.
  • Over 4,000 occasions where reserve fuel was required to remain flying.

Industry representatives claimed they already have the ASRS (Aviation Safety Reporting System) reports, and therefore NAOMS was not necessary. But ASRS features only reports submitted and is not a valid measure of system safety or system wide problems.

NAOMS provided just the type of “forward-looking analytical capabilities” called for by FAAC, as it uncovered safety threats that had not yet culminated in an accident. But it died prematurely because its data discomfited the FAA and the aviation industry.

The FAAC obviously did not even look at the NAOMS effort and how it would provide useful information on emerging threats to air safety.


Item:Expanding Sources of Voluntary Safety Data. The Secretary and the FAA Administrator, working with aviation system partners and other industry and government advisory committees, should identify potential new and valuable sources of safety data, and establish criteria for when/how those sources would begin to be included.”

Discussion: See remarks above concerning the stillborn NAOMS project. The FAA also has the Service Difficulty Report (SDR) database, but reporting under this required program varies by airline, from non-compliance (0%) to full compliance (100%). Moreover, SDR reports are only required of problems in flight, not on the ground. The industry has resisted FAA efforts to expand SDR reporting to include ground events, rendering the entire SDR database rather arbitrary.

Before going out and reinventing the wheel, the existing problems with SDR reporting should be cleaned up and promising programs like NAOMS should be exploited.


Item:Identification of Safety Priorities. The Secretary should quickly review the existing regulatory and safety initiative calendar [and] provide parameters and criteria or the FAA to prioritize its current and future rulemaking program. This review should include industry, or at a minimum seek industry input, and the results should be made publicly available … A fresh identification of priorities is needed to ensure that safety priorities are, in fact, driven by data and information and that there is an overarching sense that the government and industry are focused on the right issues first.”

Discussion: Note the admonition that the FAA should seek industry participation. One might point out that the FAA is a regulatory body providing oversight. Industry participation may lead to obfuscation and delay of efforts deemed discomfiting to the status quo.

A listing of data-driven priorities already exists. It’s the “Most Wanted” safety recommendations published annually by the National Transportation Safety Board (NTSB). It’s definitely data-driven, in that its safety recommendations come out of accidents. It is also an urgent list that is “slow rolled” by the FAA; the “Most Wanted” recommendations are either ignored by the FAA, rejected outright or implemented half-heatedly and belatedly.

most wanted

The FAA does not need a “fresh identification” of priorities; the “Most Wanted” list is the considered opinion of the NTSB based on accident investigation. The recommendations are written in blood; what additional incentive does the FAA need?