Open letter to SACAA regarding General Aviation (GA) Safetyby Charlie Marais
Dear madam DCA, please find this open letter to you with the sole intent of suggesting a course of action and by no means to lure you into a public debate. The reason for an open letter is to excite thought on the subject, with the intention to get well-reasoned inputs from those with a true intent to affect change in GA safety statistics. At best you will respond to me in private to initiate change and at worst you will find this nonsensical and stick to tried and tested ways of GA safety management which have none to very little effect on its effectiveness in changing the statistics.
It is definitely not that you are neglecting your job to see to GA safety, nor am I implying this; it is merely that I am of the opinion that the road shows and safety drives till now have had little impact on the said statistics. It has drawn immense interest and the drives have excited many of those who are already on the side of safety. The teachings so dispersed have true value and the content is more than relevant to the poor safety situation in GA. I have supported and enjoyed every effort till now and will do so in future. Please see the following not as changing direction, but rather as an opportunity to place authority behind your efforts.
I would firstly like to comment on the safety results when the comparison between GA, Part 91 operations, and all other commercial applicable Parts was made. The following needs to be said when comparing the different camps: "The more regulated the environment, the better the safety footprint." Please view the comparison below: To clarify the term GA, the following definition according to CAR (2011) Part 1 is applicable: (Definitions and "Abbreviations: 'general aviation operation' means an aircraft operation other than a commercial air transport, corporate aviation, air ambulance or aerial work operation;"
|No||General Aviation||Commercial Operations|
|1||Mixture of NPL, PPL, CPL, ATPL.||CPL and ATPL only.|
|2||Only partly subjected to direct oversight as PPL and NPL have little to absolutely no oversight. The training parts have oversight, but the released pilot after training no direct oversight.||CPL and ATPL through all Parts such as 121, 135, 127 and so on, have heavy oversight.|
|3||No requirements such as CRM, DG and SEPT.||CRM, DG and SEPT, to mention the basic few, if not up to date, attracts a finding or a fine.|
|4||Flight takes place in controlled, but mainly in uncontrolled airspace.||Flight mostly takes place in controlled airspace.|
|5||Flights such as routing or ferry flights are not regulated by flight levels.||All flights are regulated as far as the route and the flight levels are concerned. Only specialised applications will deviate from conventional flight planning and procedures.|
|6||Almost all flights will only have minimum instrument and electronic aid required for operations.||All flights are automated to a level where man becomes a manipulator of systems and monitoring of equipment a main function. This is, however, not so for smaller aircraft and specialised application aircraft.|
|7||Most GA flights are manual flights in areas where danger exists due to the restriction to visual flights.||All flights are autopilot assisted and stick time per sector down to only a few minutes, airline flying and most corporate flying, but excludes specialised applications.|
|8||As little as 45 hours total, or even less when training accidents is considered, forms the basic flight requirement.||Very few airlines will accept less than 1000 hours in flight time and many have the privilege of only picking from the ATPL pool, as there are many to choose from. The non-airline type flying will have less restrictive recruiting criteria, but hours are mostly built during training or Africa Operations.|
|9||Most flights during work or pleasure take place without ATC.||ATC is a must and performs a crucial service. Only certain specialised applications will work without ATC.|
Note: The specialised applications incorporate flights during Game Operations, Helicopter operations other than transfers, but are not excluded in all cases, and agricultural operations, but to mention a few.
I chose the above few differences and without further discussion, I think the point that the comparison between GA and Commercial type flying, as far as flight safety is concerned, holds absolutely no weight. However, I am not suggesting that GA must come up to the flight skills standard of the regulated flying operations.
I know this could be slightly confusing, so for clarity's sake, let me please continue. Commercial type flying is strictly controlled, not only as far as the operator's administrative part is concerned, but also to the safety training of its crews and then also the SOPs for all applications declared in TPMs or MOPs. For example a game pilot flies only in the three dimensional world when performing his task, whereas the airline pilot only flies in a three dimensional world during the first 150 feet after take-off and the last 150 foot during the approach. However, this is all preceded by strict training and then maintained by strict oversight, LOFT schedules, recurrent training, route checks, six monthly competency check rides, or yearly testing to name but a few. The point is that any pilot when not flying under an operator, can fly as he sees fit with very little to give account for. Let us say that a PPL holder takes off from a remote farm and then flies to another destination. The transit takes place without any administrative oversight; no route oversight or help and no ATC to regulate potential dangers. In GA this is mostly the case.
No, I am not suggesting that you mandate all flights to be controlled regarding the route, ATC and so on, however, there are a few instances where we can step in to start levelling the playing field, or rather the assistance in levelling the oversight field.
I find it disturbing that we all fly in the same sky. We are concerned about our low time and lonely PPL pilots, yet we do not correct this deficiency. Pretty words cannot do this, but action can. Could I dare to suggest that all CPLs must obtain CRM for single crew (SRM) annually? Yes, I have heard that the resistance concerning this is that the CAA should not be seen to become too restrictive and spoil all the fun. This is indeed a laissez-fair attitude. You cannot witness poor performance and have no actionable plan to combat it. To hide for the fear of attracting criticism will only leave you with great inspirational road shows and no decrease in accidents caused by poor oversight. To perform oversight you must have an oversight vehicle, and at the moment you have none for the PPL and lower levels of licence holders.
How about this; flying clubs must be registered aviation institutions that are governed by an association of some kind. In short I suggest that the days of having a beer hall talking about aviation needs to be expanded to a beer hall where we talk, teach and regulate aviation safety. Yes, the fun must be there, but the responsibility must shift a little.
Now I can bring the two together in that when all flying clubs are subjected to some form of oversight, it can exercise oversight on the licence holders that are not coupled to an operator. Every PPL, for example, must belong to a club. This is possible as there are sufficient clubs across the country. The club must then ensure the following: The individual must receive a CRM session at least once a year; that the individual attends at least 4 safety meetings per year, and finally, that a safety meeting is held every month at the club. Safety meetings, as well as SRM must contain proper safety content. To just watch a video clip ripped from YouTube with comments by enthusiasts that are not qualified, will again be better than nothing, but we can make this quite a bit more worthwhile.
Then there is the question of testing. Accident after accident I see that the candidate has flown very little during the last 90 days. The importance of "recency" is not understood, never mind applied. Why is it that the least skilled is tested the least? Where does this argument originate from? Okay, I do understand that 60 years ago the machines where less complicated and if you can fly a little one, then you can probably fly any little one. This, however, does not apply any more. Helicopters and light aircraft are becoming more complex and wing structures less forgiving. Power is quite a bit more and handling, exceeding the Vne and the lack of the understanding of the flight envelope makes for more accidents to come. I do not test a CPL or ATPL pilot every year to see if he or she can fly. They can fly. But can they do the procedures and more importantly, what can I add to the candidate's arsenal of flight capability. I can teach Game pilots new techniques, different emergency handling due to a unique environment. Non-airline type testing as a rule, are very diverse in skills, techniques to suit different conditions and the approach to task accomplishment. So why not test everyone every year?
I see, now the money becomes an issue. If the government tests each commercial driver on our roads on an annual basis, coupled to a road rules quiz, the road accidents will decrease sufficiently to justify the costs of prevention with some to spare. But we do it sporadically and the rest of the time, Laissez-fair. In other words we leave it to the individual to be diligent. Really?
In short madam DCA, I suggest the following as actionable routes to combat our dismal GA safety statistics:
- PPL and other non-commercial class licence holders must one and all be tested on an annual basis.
- PPL and lower class licence holders must all belong to a member club.
- Flying clubs must be regulated by an external association.
- Flying clubs must ensure that a safety meeting is held once a month relevant to the types represented in the club.
- Flying clubs must ensure that members attend at least one meeting every quarter.
- Flying clubs must organise one SRM every year.
- Flying clubs must ensure that all members attend a SRM annually.
- The association will regulate the clubs on behalf of the CAA, like the RAASA already does to a certain extent in certain sectors of the aviation fraternity. I am not suggesting RAASA.
- CAA in turn will apply oversight on the association.
Now, the main criticism concerning this proposal would most probably be; "You are trying to kill aviation as this is going to cost more money and future aviators will be scared away."
My answer is simply; who in fact is killing aviation? Is it those that make their living from aviation? Every time an aircraft or helicopter goes down, the insurance premiums escalate. As the premiums escalate, CAA levies escalate, fuel escalates and air vehicle prices escalate, yet I have to make a living. If it would be possible to address just one of the prime drivers of the above stated, we in the industry may have a chance to deliver the much needed aviation services.
Do you really and truthfully feel that the above mentioned suggestions would not save a few lives? What is your argument then? Rather save a little money and let the GA guys and girls die? Is it all about the short or long term financial investment?
Please feel free to communicate with me… perhaps not on social media, as only those that can apply the following truths will be welcome to: Aristotle around 350 BC said that there are three truths if you want to enter into a constructive argument. The first truth is a fact; the fact of existence. The fact is we are human and we need to acknowledge and respect it. He had in mind that we should not argue as to our existence, but I add that we should understand that we are flesh and blood and that Human factors when required to interface with a complex environment is a truth. We are all mortal, but money is only a result of the time we were born with. Money is a spinoff of life itself, so we cannot bargain with time or money because without life it does not exist.
The second truth, according to Aristotle, is a principle; the principle of non-contradiction. He said that in any true argument you cannot argue for and against the same issue. I interpret this as that we must take a stance based on truths. Truth is represented by the law. Our entire life is governed by truths. To ignore the facts can only be substituted by emotion. Emotion has been the cause of so many deaths. If reason was known, and reason was properly used, why then do we profess one thing and do another? We are contradicting the known truth to save a buck. So when you argue this case, please do not contradict the existing laws or the existing facts.
The third truth was a condition; the condition of the knowledge of right and wrong. This may be instinctive knowledge, but also quite surely professional knowledge. If you want to argue then you must have the credentials to. The facts used must be understood and the argument well-reasoned with facts such as statistics, aerodynamics, safety drivers and many more, to support your stance.
A mere opinion because it represents an emotional outburst is simply not going to get safety where it belongs. On the contrary, it will aid our relaxed and non-accountable attitude towards safety. "Safety for all as long as it suits me," no, this cannot be acceptable anymore.
I believe there are many "holes" in my arguments, but my motive is not self-gain. I believe that all those genuinely concerned must work in leaving a legacy of safety enhancement and stop our laissez-fair attitude. Take responsibility.