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The U. This paper reviews the government and industry response to four specific areas of air tour safety concern: surveillance of flight operations, pilot factors, regulatory standardization, and maintenance quality assurance. It concludes that the government and industry have successfully addressed many of these tenet issues, most notably by: advancing the operations surveillance infrastructure through implementation of en route, ground-based, and technological surveillance methods; developing Aeronautical Decision Making and cue-based training programs for air tour pilots; consolidating federal air tour regulations under Part ; and developing public-private partnerships for raising maintenance operating standards and improving quality assurance programs.
However, opportunities remain to improve air tour safety by: increasing the number and efficiency of flight surveillance programs; addressing pilot fatigue with more restrictive flight hour limitations for air tour pilots; ensuring widespread uptake of maintenance quality assurance programs, especially among high-risk operators not currently affiliated with private air tour safety programs; and eliminating the mile exception allowing Part 91 operators to conduct commercial air tours without the safety oversight required of Part operators.
Scheduled air carriers, including major airlines, operate under the governance of Part From through , air tour operators in the United States flew an estimated average , h annually with an average air tour industry crash rate of 2. Approximately one-fourth of these air tour crashes involved at least one fatality and, among fatal crashes, an average of 3. The air tour industry crash rate is more than 10 times that of large commuter airlines 0.
Not only are commercial air tour flights more likely to crash than other similar commercial operations, the air tour flights conducted by Part 91 operators are more likely to crash than those conducted by Part operators Table I.
Develop operator policies and guidance for operations near high-traffic areas Operators. Regulate crew rest: min break after 3 consecutive hours of flight and limit to eight air tour flights per day FAA.
Air tours frequently operate in locations with unique geographic, meteorological, and environmental phenomena that present hazards during flight In order to improve pilot performance under these conditions, the NTSB recommends that air tour operators develop policy and guidance for operations near prominent attractions, parks, and other hazardous or high-traffic areas Finally, the NTSB recommends mandating a min break after 3 consecutive hours of flight, as well as limiting air tour pilots to a maximum of eight air tour flights per day Currently, operating standards for air tours differ by geographic region, CFR Part categorization, and federal tax status.
Additionally, companies governed by CFR Part 91 have less stringent operations, maintenance, and training specifications than those governed by Parts and 14 — In order to further standardize operations in the industry, the NTSB recommends eliminating data collection disparities, abandoning the mile exception for Part 91 operators, and reevaluating the Hawaii minimum altitude requirements 35 , 40 , Although no studies have reported the combined proportions of helicopter and fixed-wing air tour crashes due to improper maintenance, the NTSB has identified improper maintenance as a precipitating factor in many rotary- and fixed-wing air tour crashes In response to this safety threat, the NTSB recommends that operators develop mechanisms for maintenance performance evaluation, implement maintenance inspection and quality assurance programs, and ensure that maintenance personnel receive model-specific maintenance training at regular intervals In addition, the NTSB recommends strengthening partnerships between the FAA and private air tour safety programs in order to improve the oversight of air tour maintenance programs Over the past two decades, the FAA has taken several steps to increase its surveillance of commercial air tour operations.
In , it established special geographic units at the Las Vegas and Honolulu Flight Standards District Offices to oversee sightseeing operations in the Grand Canyon and Hawaii, respectively It also conducted public meetings in Niagara Falls to discuss air tour industry oversight there and, in , instituted ground-based surveillance of Hawaii air tour operations that lasted until In , the FAA revised Order Similarly, in , the FAA revised Order In , it issued Notice The FAA is also collaborating with Hawaiian operators to draft memoranda of agreement that promote the voluntary early uptake of the ADS-B technology, which was originally scheduled to be operational March However, despite these improvements in air tour operations surveillance and the expansion of the General Aviation and Air Taxi Activity survey to include data from air tours operating under Part , the FAA has yet to develop a comprehensive mechanism to monitor Part 91 air tour operations, or collect corresponding safety data.
The FAA has addressed many aspects of pilot training in order to improve safety among commercial air tour pilots. In , it published Operations Specification B, mandating annual training meetings for Part 91 and air tour operators in Hawaii Also, as previously mentioned, FAA Order Despite NTSB opposition, the FAA has neither promoted rule changes that restrict air tour pilots to a maximum of 3 consecutive flight hours before a mandated min break, nor has it imposed a maximum of eight air tour flights per pilot per day, as recommended by the NTSB Part recently mandated the implementation of alcohol and drug screening programs for Group 2 pilots, which expanded the existing scope of drug screening in the air tour industry; all Part operators were previously required to submit to screening Requires each Part 91 operator conducting nonstop commercial sightseeing flights within a statute-mile radius of an airport to obtain an FAA letter of authorization LOA.
Allows charitable, nonprofit, and community event flights to continue operating under Part 91 without having to comply with FAA drug and alcohol testing requirements. Raises the minimum number of hours required for private pilots conducting charity, nonprofit, and community event fundraising flights from to Limits community event sponsors and their pilots to one event per calendar year.
Limits pilots to 12 d of flying in charity events or 3 d of flying in community events per calendar year. Requires all sightseeing operators to comply with new passenger briefing and life preserver for over water flights requirements. Requires helicopter operators to be equipped with fixed floats or an inflatable flotation system if the over-water flight is conducted beyond power-off gliding distance to the shoreline. Requires helicopter operators to complete a performance plan before each flight that considers the effects of density altitude, weight, and center of gravity limits on takeoff, landing, and hovering in ground effect.
The FAA made strides to standardize air tour regulations in the Part Final Rule; however, it strayed from this goal in several regards.
Additionally, the Part Final Rule maintained the mile exception for Part 91 operators despite numerous opposing NTSB recommendations 35 , 40 , This allows Part 91 operators to continue conducting air tour operations without the surveillance and safety data collection requirements of Part operators. The Aircraft Maintenance Division of the FAA is responsible for maintenance policy and performance standards nationwide These instructional documents provide information for operators about how to improve maintenance quality assurance and, although currently voluntary in nature, they outline minimum standards for maintenance programs.
The air tour industry has been heavily involved in the safety process and rulemaking efforts over the past 20 yr. The Part Notice of Proposed Rulemaking elicited more than responses from air tour industry stakeholders during its comment periods, which necessitated two extensions d total , two public meetings Washington, DC, and Las Vegas , and two 2-wk virtual public meetings on the internet to accommodate the volume of public response Despite the enhanced capabilities of weather detection, communication, and tour-route tracking associated with the proposed ADS-B system implementation, Hawaiian air tour operators remain opposed to the system, asserting that the system would introduce more FAA interference with operations They have also cited supplemental concerns about the cost of the components, added weight to the aircraft, and not enough space in the aircraft for modification Despite being the most expensive Part element to implement, the standardized personal flotation and aircraft float system requirements have been generally well accepted by air tour operators 14 , Industry stakeholders such as the Hawaii Helicopter Operators Association, Helicopter Association International, and individual pilots and operators continue to claim that this requirement inadvertently degrades safe maneuverability in an operating environment characterized by unstable meteorological conditions Concern also remains among stakeholders that the minimum altitude requirement is a result of local politics rather than safety concerns; suspicion toward the FAA and its local staff in Hawaii are cited as interfering with federal rulemaking by the Hawaii Helicopter Operators Association in its correspondence with the NTSB Since its inception, TOPS has addressed several maintenance issues that have been at the forefront of NTSB recommendations for the air tour industry It also participated in the Commercial Air Tour Maintenance Working Group, collaborating with the FAA to develop maintenance quality assurance program standards to meet the needs of a range of operators and to establish formal model-specific maintenance training requirements for members, along with an annual audit program for these requirements This crash rate is alarming because it suggests that there may be a few high-risk commercial air tour operators that contribute disproportionately to the air tour crash rate of 2.
Further, TOPS membership is only open to helicopters and there is no equivalent maintenance organization for fixed wing air tour operators. The recent publication of commercial air tour crash rates provides context for previous reports highlighting the hazards of light aircraft flights for travelers 5 , 25 , The Part 91 air tour crash rate of 3. Prior to , the Hawaiian helicopter air tour crash rate of 3. Similarly, the Helicopter Emergency Medical Services crash rate of 3.
Unlike air tours, however, these emergency medical flights operate under extremely challenging conditions, oftentimes at night. Likewise, the extremely hazardous activity of over-water ferrying of personnel and heavy-load supplies to off-shore drilling sites reported a national crash rate of all turbine powered civilian helicopters of 5.
Both the government and the air tour industry have responded successfully to many of the NTSB-identified safety concerns. To begin with, the publication of 14 CFR Part provided much-needed clarification of many of the ambiguous terms in the regulations, allowing them to be interpreted more clearly 14 , The new requirements for passenger safety briefings, preflight center of gravity calculations, and personal flotation devices also appear to have improved air tour safety according to one study This is consistent with early emergency evacuation demonstration data that show preflight briefings improve passenger understanding and execution of aircraft egress procedures in the event of an emergency 1 , Concurrently, members of the helicopter air tour industry developed TOPS, which aims to reduce maintenance-related crashes through standardized maintenance safety auditing, complaint reporting, and evaluation programs However, there are several safety issues that have not been adequately addressed by either the government or the industry itself.
The allowance of the Group 3 charity pilots to fall outside the guidance for mandatory enrollment in drug and alcohol misuse prevention programs should be corrected Drug and alcohol misuse by air tour pilots poses a threat to the safety of patrons.
These results are similar to studies from previous periods 7 , 9 , For example, a study of aviation employees who were tested for drugs as part of the post-accident testing program from through found that the odds of accident involvement for employees testing positive for drugs was almost three times the odds of those who tested negative This suggests that drug and alcohol misuse, including prescription drug misuse, contribute to Part 91 aviation crashes.
Reducing drug- and alcohol-associated crash risks by mandating participating in drug and alcohol prevention programs could improve air tour safety among Part 91 operators. The impact of the ft AGL minimum altitude requirement in Hawaii 22 , which has been a long-standing safety concern for operators, still requires further investigation. Following the implementation of Special Federal Aviation Regulation 71, which included a ft AGL minimum altitude requirement for Hawaiian air tour operators, the crash rate of sightseeing helicopter flights decreased from 3.
It is not clear whether the decreased crash rate is due to the ft AGL minimum requirement or due to secular trends in air tour operations during this period. However, it is plausible that the increased incidence of VFR-IMC crashes could be related to helicopters flying at higher altitudes, where exposure to cloud cover is likely 23 , 28 , Studies have demonstrated that VFR-IMC crashes are associated with high mortality rates such as those that occurred in Hawaii after the implementation of the ft AGL requirement 3 , Given the strained relationship between Hawaiian operators and the FAA, an independent organization might be best suited to evaluate the impact of the minimum altitude requirement on air tour safety in Hawaii Fatigue is an important influence on pilot performance and safety.
Commercial air tour pilots are exposed to multiple takeoffs, landings, and maneuvers, resulting in a more demanding workload throughout the day relative to long-haul pilots. Further, most U. Studies have suggested that fatigue is problematic among pilots conducting multiple short flights throughout the workday 6 , 27 , Duty length, time of day, number of flight legs, prolonged duty periods, early wake-ups, and the need to perform an originally unplanned additional leg significantly influence pilot fatigue among these pilots 6 , To mitigate the risk of fatigue, Part limits the number of flight hours flown for single pilot crews to 8 h of total flight time within a h period.
Crew rest requirements and limitations on flight hours by week, month, and year are also outlined in Part Pilots flying under Part 91, however, do not have flight hour restrictions or crew rest requirements. Given the known risks of fatigue and the high crash rate of Part 91 air tour operators, addressing human fatigue in this population through flight time limitations could be beneficial. Furthermore, reporting Part 91 helicopter- and airplane-specific air tour crash counts, flight hours, and crash rates using information collected from the General Aviation and Air Taxi Activity survey is imperative for the evaluation of safety regulations in this population.
Since , the survey has distinguished between Part air tour operations and Part 91 sightseeing operations However, the paid sightseeing flight data reported by the NTSB includes data from balloons and gliders, which have different flight characteristics, crash risk factors, and regulatory oversight than air tours conducted in helicopters and airplanes 4 , 11 , In order to better monitor the safety of commercial air tour flights, the reported data must be stratified by type of aircraft, CFR Part, and purpose of flight.
In order to improve safety and standardization in the air tour industry, the FAA should eliminate the mile exception for Part 91 operators and further tailor the Code of Federal Regulations to accommodate air tours. By reducing some of the inapplicable Part requirements for air tour operators, such as cargo training and capability requirements for international flight, the FAA may be able to lessen the economic burden of additional air tour regulations under this governance.
In conclusion, the government and industry have successfully addressed many of these tenet issues, most notably by advancing the operations surveillance infrastructure through implementation of en route, ground-based, and technological surveillance methods; developing aeronautical decision making and cue-based training programs for air tour pilots; consolidating federal air tour regulations under Part ; and developing public-private partnerships for raising maintenance operating standards and improving quality assurance programs.
However, opportunities remain to improve air tour safety by increasing the number and efficiency of flight surveillance programs; addressing pilot fatigue with more restrictive flight hour limitations for air tour pilots; ensuring widespread uptake of maintenance quality assurance programs, especially among high-risk operators not currently affiliated with private air tour safety programs; and eliminating the mile exception allowing Part 91 operators to conduct commercial air tours without the safety oversight required of Part operators.
The author would like to thank Susan P.
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The U. This paper reviews the government and industry response to four specific areas of air tour safety concern: surveillance of flight operations, pilot factors, regulatory standardization, and maintenance quality assurance. It concludes that the government and industry have successfully addressed many of these tenet issues, most notably by: advancing the operations surveillance infrastructure through implementation of en route, ground-based, and technological surveillance methods; developing Aeronautical Decision Making and cue-based training programs for air tour pilots; consolidating federal air tour regulations under Part ; and developing public-private partnerships for raising maintenance operating standards and improving quality assurance programs. However, opportunities remain to improve air tour safety by: increasing the number and efficiency of flight surveillance programs; addressing pilot fatigue with more restrictive flight hour limitations for air tour pilots; ensuring widespread uptake of maintenance quality assurance programs, especially among high-risk operators not currently affiliated with private air tour safety programs; and eliminating the mile exception allowing Part 91 operators to conduct commercial air tours without the safety oversight required of Part operators. Scheduled air carriers, including major airlines, operate under the governance of Part From through , air tour operators in the United States flew an estimated average , h annually with an average air tour industry crash rate of 2.
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The U.S. Commercial Air Tour Industry: A Review of Aviation Safety Concerns
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