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NTSB · Safety Recommendation

Safety Recommendation A-21-005

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Require the use of appropriate simulation devices during initial and recurrent pilot training for Title 14 Code of Federal Regulations Part 135 helicopter operations to provide scenario-based training that addresses the decision-making, skills, and procedures needed to recognize and respond to changing weather conditions in flight, identify and apply mitigation strategies for avoiding adverse weather, practice the transition to the use of flight instruments to reduce the risk of spatial disorientation, and maintain awareness of a variety of influences that can adversely affect pilot decision-making.

Safety Issue and Context

This report discusses the January 26, 2020, accident involving a Sikorsky S-76B helicopter, N72EX, being operated by Island Express Helicopters Inc. as a Title 14 Code of Federal Regulations (CFR) Part 135 on-demand flight, that crashed into terrain in Calabasas, California. The pilot and the eight passengers died.

Safety issues identified in this report include the pilot’s preflight weather and flight risk planning, the flight’s entry into instrument meteorological conditions and the pilot’s inadequate adverse weather avoidance, the pilot’s spatial disorientation, influences on the pilot’s decision to continue the flight into adverse weather, Island Express’ incomplete implementation of its safety management system (SMS), the benefits of a mandatory SMS, the benefits of flight simulation devices for pilot training in adverse weather avoidance, the benefits of a flight data monitoring program, and the value of crash-resistant flight recorder systems in preventing future accidents.

As a result of this investigation, the National Transportation Safety Board makes two new safety recommendations each to the Federal Aviation Administration and Island Express.

Response History

May 23, 2024 · NTSB Correspondence · FAA

We note that the Air Carrier Training Aviation Rulemaking Committee’s (ACT ARC’s) Spatial Disorientation Training Workgroup has completed its research and that you are reviewing its recommendations, which include 23-1, Simulation Training Devices Suitable for Spatial Disorientation Training, and 23-2, Part 135 Helicopter Operations Spatial Disorientation Training. Pending our review of a plan for requiring the recommended initial and recurrent training, Safety Recommendation A-21-5 remains classified OPEN-- ACCEPTABLE RESPONSE.

We also note that the ACT ARC evaluated spatial disorientation simulation technologies and that this information is included in its submission ACT ARC Recommendation 23-1, which is available on your website. We believe these actions satisfy the intent of Safety Recommendation A-21-6, which is classified Closed—Acceptable Action.

September 15, 2023 · Recipient Response · FAA

-From Kathryn B. Thomson, Deputy Administrator: The Air Carrier Training Aviation Rulemaking Committee (ACT ARC) approved two recommendations submitted by its Spatial Disorientation Training Workgroup during the January 25-26, 2023, ACT ARC Meeting. The Federal Aviation Administration (FAA) received these recommendations, which include:

1) ACT ARC Recommendation 23-1, Simulation Training Devices Suitable for Spatial Disorientation Training, which is available at the following website: https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs200/afs280/ act_arc/act_arc_reco/ACT_ARC_Rec_23-1_Simulation_Training

2) ACT ARC Recommendation 23-2,

Read Recommendation

Recommendation Facts

Status
Open - Acceptable Response
Issued
February 25, 2021
Priority
CLASS II
Recipient
FAA
Adopted
February 9, 2021
Related Investigation
DCA20MA059
Related Report
AAR-21-01
Part 135
Helicopter Operations Spatial Disorientation Training, which is available at the following website: https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs200/afs280/ act_arc/act_arc_recoACT_ARC_Rec_23-2_Part_135_Helicopter_Operations

The FAA is reviewing the ACT ARC’s recommendations to determine an appropriate action plan.

I will keep the Board informed of our progress on Safety Recommendations A-21-5 and -6 and anticipate providing an update by August 31, 2024.

September 6, 2023 · NTSB Correspondence · FAA

On August 4, 2023, the Federal Aviation Administration (FAA) announced the publication of draft Advisory Circular (AC) 136-B048, Supplemental Information for the Creation of Operating Procedures and Pilot Training Subjects Related to OpSpec [operations specification]/LOA [letter of authorization] B048, and invited public comment on the document. The NTSB has a longstanding interest in air tour safety in the state of Hawaii, having investigated numerous Hawaii air tour accidents and issued many related safety recommendations and we offer our comments below.

We note that, based on the contents of the draft AC, it appears that the FAA’s intent is that it will replace FAA document AWP13-136, the Hawaii Air Tour Common Procedures Manual (HATCPM), which the FAA issued in 2008 for use by operators that obtained authorization (through OpSpec B048 or LOA B548) to deviate from the minimum altitude specified in 14 Code of Federal Regulations (CFR) Part 136, Appendix A. For those operators that obtained authorization through OpSpec B048/LOA B548, compliance with the provisions of the HATCPM was mandatory.

In our 2022 report on our investigation of the December 26, 2019, fatal air tour helicopter accident in Kekaha, Hawaii, we noted that the HATCPM had not been revised since it was issued and that the FAA informed us that it had been working on a replacement for about 7 years.

During our investigation, an air tour subject matter expert from the FAA’s Air Transportation Division, [14 CFR] Part 135 Air Carrier Operations Branch, informed us that the FAA’s vision for the new document was for it to be up to date; incorporate NTSB safety recommendations, congressional input, and National Park Service input; and be simpler, safer, and easier to manage. They also said that the document would likely address the use of Hawaii weather camera systems and operator implementation of safety management systems (SMSs).

We have examined the draft AC and are providing comments related to these issues and open NTSB recommendations related to air tour safety in Hawaii. We note that, although ACs, generally, are not regulatory documents, we presume that operators that obtain authorization through OpSpec/LOA B048 will be required to comply with the AC’s provisions (similar to the mandatory compliance with the HATCPM for those operators that held deviation authority).

Additional Recommendations Not Addressed in the AC In addition to the recommendations discussed above, we have identified the following NTSB safety recommendations to the FAA that are relevant to Hawaii air tour safety but whose subject matter is not discussed in the draft AC:

Safety Recommendation A-21-5: Require the use of appropriate simulation devices during initial and recurrent pilot training for Part 135 helicopter operations to provide scenario-based training that addresses the decision-making, skills, and procedures needed to recognize and respond to changing weather conditions in flight, identify and apply mitigation strategies for avoiding adverse weather, practice the transition to the use of flight instruments to reduce the risk of spatial disorientation, and maintain awareness of a variety of influences that can adversely affect pilot decision-making. (Open—Acceptable Response)

April 19, 2023 · NTSB Correspondence · FAA

We note that, in March 2022, the Air Carrier Training Aviation Rulemaking Committee (ACT ARC) formed the Spatial Disorientation Trianing Workgroup, which has been tasked with evaluating both of these recommendations. Pending our review of the ACT ARC’s reports and completion of the recommended actions, Safety Recommendations A-21-5 and -6 remain classified OPEN-- ACCEPTABLE RESPONSE.

September 21, 2022 · Recipient Response · FAA

From Billy Nolan, Acting Administrator, Federal Aviation Administration: The Federal Aviation Administration chartered the Air Carrier Training Aviation Rulemaking Committee (ACT ARC) in January 2014. The ACT ARC’s Spatial Disorientation Training Workgroup was officially formed in March 2022, with its first meeting in May 2022. The workgroup was tasked to:

1) Evaluate spatial disorientation simulation technologies to determine which applications are most effective for training pilots to recognize the onset of spatial disorientation and successfully mitigate it; and 2) Examine current training for spatial disorientation in Part 135, specifically helicopter operations, to make recommendations for developing scenario-based training in both initial and recurrent training that includes consideration for simulation technologies.

Through its workgroup and steering committee, we anticipate that the ACT ARC will provide recommendation reports addressing the above tasks early in calendar year 2023. Information regarding the ACT ARC can be located at: https://www.faa.gov/regulations_policies/rulemaking/committees/documents/index.cfm/document/information/documentID/5243.

I will keep the Board informed of our progress on Safety Recommendations A-21-5 and -6 and anticipate providing an update by September 30, 2023.

May 26, 2022 · NTSB Correspondence · FAA

From Aviation Investigation Report AIR-22-05 “Collision into Terrain Safari Aviation Inc. Airbus AS350 B2, N985SA Kekaha, Hawaii, December 26, 2019” published on May 26, 2022: 2.8.2 Simulation Devices for Pilot Training

As discussed in section 2.3.2, the NTSB has long recognized the value of cue-based and scenario-based pilot training to help reduce the risk of accidents involving inadvertent encounters with IMC. Such training could be enhanced through the use of simulation technologies, which can present pilots with representations of deteriorating weather conditions that cannot be realistically duplicated during flight training conducted in helicopters in visual weather conditions.

This can provide opportunities for pilots to safely practice the decision-making, skills, and procedures needed to recognize and respond to changing weather conditions in flight, identify and apply mitigation strategies for avoiding adverse weather, and maintain awareness of a variety of influences that can adversely affect pilot decision-making.

In 2020, the USHST encouraged the greater use of simulation at all levels of fidelity, including aviation training devices, flight training devices, and full flight simulators, during both initial and recurrent helicopter training (USHST 2020). The USHST has also established goals for promoting the wider use of spatial disorientation simulation technology, among other initiatives, to improve the effectiveness of spatial disorientation recognition and recovery training for helicopter pilots (USHST 2019).

Further, industry developments in simulation technology continue to advance beyond the research stage, including options such as head-mounted augmented reality devices. These types of helmets or visors provide visual simulations of changing weather conditions to enable the pilot to practice weather decision-making and avoidance procedures during training flights in an actual aircraft. Training performed in an actual helicopter enables the pilot to experience the vestibular sensations associated with actual accelerations, banking, and other maneuvers during flight.

This type of flight training is beneficial because it allows pilots to experience the adverse effects of vestibular and visual illusions, which can help them develop the skills needed to detect the onset of spatial disorientation and apply flight control corrections and other response mitigations.

During the NTSB’s investigation of the fatal 2020 accident involving a Sikorsky S-76B helicopter that descended rapidly into terrain in Calabasas, California, we determined that the pilot became spatially disoriented following an inadvertent encounter with IMC and lost control of the helicopter (NTSB 2021a), As a result of our investigation, on February 25, 2021, we issued two safety recommendations to the FAA related to the use of simulation technologies in pilot training, as follows:

Require the use of appropriate simulation devices during initial and recurrent pilot training for Title 14 Code of Federal Regulations Part 135 helicopter operations to provide scenario-based training that addresses the decision-making, skills, and procedures needed to recognize and respond to changing weather conditions in flight, identify and apply mitigation strategies for avoiding adverse weather, practice the transition to the use of flight instruments to reduce the risk of spatial disorientation, and maintain awareness of a variety of influences that can adversely affect pilot decision-making. (A-21-5)

Convene a multidisciplinary panel of aircraft performance, human factors, and aircraft operations specialists to evaluate spatial disorientation simulation technologies to determine which applications are most effective for training pilots to recognize the onset of spatial disorientation and successfully mitigate it, and make public a report on the committee’s findings. (A-21-6)

On April 29, 2021, the FAA responded that it was determining the necessary objectives and selecting the appropriate experts before tasking the air carrier training aviation rulemaking committee to address our recommendations. As a result, we classified Safety Recommendations A-21-5 and -6 “Open—Acceptable Response.”

In our investigation report for the Calabasas accident, we noted that the use of appropriate simulation devices in scenario-based helicopter pilot training has the potential to improve pilots’ abilities to accurately assess weather and make appropriate weather-related decisions and that the use of spatial disorientation simulation technology to supplement pilot training shows potential for helping pilots develop skills to detect and recover from vestibular illusions that could lead to spatial disorientation.

Thus, the NTSB concludes that the use of simulation technologies in helicopter pilot training has the potential to help reduce accidents involving inadvertent encounters with IMC by enhancing the weather-related decision-making and assessment aspect of scenario-based training and providing opportunities for pilots to develop skills to detect and recover from vestibular illusions that could lead to spatial disorientation. Therefore, due to the relevance of these safety recommendations to the circumstances of this accident, the NTSB reiterates Safety Recommendations A-21-5 and -6.

November 16, 2021 · NTSB Correspondence · FAA

We note that you are taking the necessary first steps before assigning these recommendations to the Air Carrier Training Aviation Rulemaking Committee. Pending our review of a plan for addressing the specific concerns discussed in these recommendations, Safety Recommendations A-21-5 and -6 are classified OPEN-- ACCEPTABLE RESPONSE.

April 29, 2021 · Recipient Response · FAA

-From Steve Dickson, Administrator: The Federal Aviation Administration (FAA) is determining the necessary objectives, work statement, and selecting the appropriate experts, and once complete will task the Air Carrier Training Aviation Rulemaking Committee to address these safety recommendations. The FAA is also continuing to assess the larger scope of work necessary to respond fully to these safety recommendations.

I will keep the Board informed of our progress on Safety Recommendations A-21-5 and -6, and anticipate providing an update by May 31, 2022.

February 25, 2021 · NTSB Correspondence · FAA

The attached letter from the NTSB Chairman provides information about the NTSB’s February 9, 2021, report Rapid Descent Into Terrain, Island Express Helicopters Inc., Sikorsky S 76B, N72EX, Calabasas, California, January 26, 2020, AAR-21-01. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-21-5 and -6). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

This letter provides information about the National Transportation Safety Board’s (NTSB) February 9, 2021, report Rapid Descent Into Terrain, Island Express Helicopters Inc., Sikorsky S 76B, N72EX, Calabasas, California, January 26, 2020, AAR-21-01. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.

As a result of this investigation, we identified the following safety issues:

• The pilot’s preflight weather and flight risk planning. • The flight’s entry into instrument meteorological conditions and the pilot’s inadequate adverse weather avoidance. • The pilot’s spatial disorientation. • Influences on the pilot’s decision to continue the flight into adverse weather. • Island Express’ incomplete implementation of its safety management system (SMS). • The benefits of a mandatory SMS. • The benefits of flight simulation devices for pilot training in adverse weather avoidance. • The benefits of a flight data monitoring program. • The value of crash-resistant flight recorder systems in preventing future accidents.

Accordingly, the NTSB makes the following safety recommendations to the FAA. Additional information regarding these recommendations can be found in the noted sections of the report.

• Require the use of appropriate simulation devices during initial and recurrent pilot training for Title 14 Code of Federal Regulations Part 135 helicopter operations to provide scenario-based training that addresses the decision-making, skills, and procedures needed to recognize and respond to changing weather conditions in flight, identify and apply mitigation strategies for avoiding adverse weather, practice the transition to the use of flight instruments to reduce the risk of spatial disorientation, and maintain awareness of a variety of influences that can adversely affect pilot decision-making. (A-21-5) (See section 2.5.)

• Convene a multidisciplinary panel of aircraft performance, human factors, and aircraft operations specialists to evaluate spatial disorientation simulation technologies to determine which applications are most effective for training pilots to recognize the onset of spatial disorientation and successfully mitigate it, and make public a report on the committee’s findings. (A-21-6) (See section 2.5.) In addition, the NTSB reiterates the following recommendations to the FAA:

• After the action in Safety Recommendation A-16-34 is completed, require all 14 Code of Federal Regulations Part 135 operators to establish a structured flight data monitoring program that reviews all available data sources to identify deviations from established norms and procedures and other potential safety issues. (A-16-35) (See section 2.6.) • Require all 14 Code of Federal Regulations Part 135 operators to establish safety management system programs. (A-16-36) (See section 2.4.2.)

In the same report, we also classified two previously issued safety recommendations:

• Require all 14 Code of Federal Regulations Part 135 operators to install flight data recording devices capable of supporting a flight data monitoring program. (A 16 34, classified “Open—Unacceptable Response” in section 2.6) • Require all existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with a flight data recorder or cockpit voice recorder and are operating under 14 Code of Federal Regulations Parts 91, 121, or 135 to be retrofitted with a crash-resistant flight recorder system.

The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.” (A 13 13, classified “Open—Unacceptable Response” in section 2.7)

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (Safety Recommendations A-21-5 and -6. We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If

your reply, including attachments, exceeds 20 megabytes, please e mail us at the same address for instructions. Please do not submit both an electronic copy and a hard copy of the same response.