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NTSB · Safety Recommendation

Safety Recommendation A-21-049

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Notify principal operations inspectors and frontline managers about the circumstances of this accident and emphasize the importance of existing Federal Aviation Administration guidance for detecting and mitigating the safety risks that can result when certificate holders experience significant organizational change, such as high personnel turnover, a reduction to route structures or flight schedules, bankruptcy, acquisition, and merger.

Safety Issue and Context

This report discusses the October 17, 2019, accident involving a Saab SA-2000 airplane, operated by Peninsula Aviation Services Inc. d.b.a. PenAir flight 3296, which overran the end of runway 13 at Unalaska Airport, Unalaska, Alaska. The airplane was substantially damaged during the runway overrun; as a result, of the 3 crewmembers and 39 passengers aboard, 1 passenger sustained fatal injuries, and 1 passenger sustained serious injuries. Eight passengers sustained minor injuries, most of which occurred during the evacuation.

Safety issues identified in this report include the potential for cross-wiring of airplane antiskid brake systems; insufficient Federal Aviation Administration (FAA) guidance to identify safety risks for air carriers experiencing significant organizational changes, including bankruptcy, acquisition, and merger; lack of FAA consideration of runway safety area dimensions during the process of authorizing an air carrier to operate its aircraft at a specific Title 14 Code of Federal Regulations Part 139 certificated airport, and the benefits of safety management systems for design, manufacturing, and maintenance organizations.

As a result of this investigation, the National Transportation Safety Board makes six new safety recommendations to the FAA, three new safety recommendations to the European Union Aviation Safety Agency, and one new recommendation to the Saab Group.

Response History

July 30, 2026 · NTSB Correspondence · FAA

Aviation Investigation Report AIR-26-05 “In-Flight Loss of Control and Impact with Pack Ice Bering Air Flight 445 Textron Aviation 208B, N321BA, Near Nome, Alaska February 6, 2025” published on July 30, 2026:

2.4.2 Federal Aviation Administration Oversight

Oversight of the Bering Air certificate was performed by a certificate management team of three inspectors out of the Fairbanks FSDO, located about 520 miles from Nome. At the time of the accident, Bering Air had 54 pilots and 40 aircraft (30 airplanes and 10 helicopters), reflecting a period of growth that began in 2020 following the bankruptcy of its primary competitor carrier, Ravn Alaska.

FAA Order 8900.1, Volume 10, “SAS Policy and Procedures,” requires reassessment of a Part 135 certificate holder’s risk profile at least once a year and specifically identifies operational complexity and rapid growth or downsizing as risk factors that could affect a risk profile. The NTSB’s review of SAS data for Bering Air indicated that multiple CHAT assessments were performed between 2022 (when the front-line manager and POI assumed their respective oversight roles for the operator) and 2025, and that none identified operational complexity or rapid growth as risk factors despite both being present.

Every assessment during this period indicated no action was required, and Bering Air’s risk profile remained unchanged. Footnote: During postaccident interviews, the POI framed Bering Air’s growth as “solidification of their existing route structure” rather than expansion and regarded it as “responsible, measured.” The front-line manager for the certificate management team described being aware of the company’s growth as a feature but not necessarily a specific focus.

Bering Air’s president and the director of safety both described the period of growth in the context of the 2020 pandemic and bankruptcy of Ravn Alaska. Becoming the only passenger-carrying operator in the region, the company strove to meet increased demand for cargo service while also accommodating increased passenger demand as travel restrictions eased. These pressures required additional personnel in all departments, new types of aircraft, and new facilities.

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Recommendation Facts

Status
Closed - Unacceptable Action
Issued
November 18, 2021
Priority
CLASS II
Recipient
FAA
Adopted
November 2, 2021
Closed
February 26, 2025
Related Investigation
DCA20MA002
Related Report
AAR-21-05

All of these changes introduced operational risk. The NTSB’s identification of underreported weight data across several load manifests for flights using the accident airplane (compared to recorded flight data and the company’s GOM) is one example of such risk. Once introduced into the system, that risk led to the accident airplane being operated while overweight for several flights, including the accident flight, in the week before the accident. The POI stated postaccident that he did not believe flight 445 was the first on the Bering Air certificate to fly overweight.

As described by the POI, his weight and balance surveillance primarily involved manual review of Bering Air’s voluntarily maintained archive of load manifests. Footnote: As discussed later in this section, single-engine aircraft are excluded from the load manifest requirements of 14 CFR 135.63(c). If they passed the “smell test,” there was typically “no reason to dig deeper.” The POI reported that because inaccurate weight recordkeeping had not been identified as a risk indicator—consistent with a SAS principle—verifying weight and balance by more “invasive” means (for example, offloading passengers and cargo) “rarely” happened as part of his surveillance activities.

It is this approach that resulted in no related data being entered into SAS and no associated risk indicator being identified.

The NTSB’s investigations of the February 2009 accident involving Colgan Air flight 3407 and October 2019 accident involving PenAir flight 3296 similarly found that significant organizational change created operational risks that oversight did not detect or mitigate. Regarding Colgan Air, we found that, at the time of the accident, the FAA’s surveillance standards for oversight at air carriers undergoing rapid growth and increased complexity of operations did not guarantee that any challenges encountered by the carriers as a result of these changes would be appropriately mitigated.

Footnote: Among the organizational changes at Colgan Air that the NTSB’s investigation evaluated was the significant increase in its Bombardier Q400 fleet (in addition to its existing Saab 340 fleet), which required increased pilot upgrades and training. As a result, the NTSB issued Safety Recommendation A 10 26, which asked the FAA to do the following:

Develop more stringent standards for surveillance of Part 121, 135, and 91K operators that are experiencing rapid growth, increased complexity of operations, accidents and/or incidents, or other changes that warrant increased oversight, including the following: (1) verify that inspector staffing is adequate to accomplish the enhanced surveillance that is promulgated by the new standards, (2) increase staffing for those certificates with insufficient staffing levels, and (3) augment the inspector staff with available and airplane-type-qualified inspectors from all FAA regions and Part 142 training centers to provide quality assurance over the operators’ aircrew program designee workforce.

In response, the FAA issued Notice 8900.236, “ATOS Resource Management,” on September 13, 2013, amending policy and procedures specified in FAA Order 8900.1, “Flight Standards Information Management System.” The amendments allowed managers of certificate management teams to use personnel from other offices to assist with oversight, as necessary, and to streamline the process for requesting that assistance. In an April 17, 2014, response, the NTSB noted that, to satisfy Safety Recommendation A-10-26, the improved policies and procedures in Notice 8900.236 had to be incorporated into SAS before the notice expired in September 2014.

After the FAA confirmed completion within the indicated timeframe, we classified Safety Recommendation A 10 26 Closed—Acceptable Action in November 2015.

Concerning the PenAir flight 3296 accident, we found that the FAA’s oversight of PenAir during the 2 years before the accident was insufficient to identify safety risks resulting from the company’s bankruptcy, reduced route structure, loss of experienced pilots, acquisition, and merger (NTSB 2021). As a result, we issued Safety Recommendation A-21-49, which asked the FAA to do the following:

Notify principal operations inspectors and frontline managers about the circumstances of this accident and emphasize the importance of existing Federal Aviation Administration guidance for detecting and mitigating the safety risks that can result when certificate holders experience significant organizational change, such as high personnel turnover, a reduction to route structures or flight schedules, bankruptcy, acquisition, and merger.

Footnote: At the time Safety Recommendation A-21-49 was issued, the FAA’s existing guidance for detecting and mitigating the safety risks that can result from organizational change was contained in Order 8900.1, volume 6, chapter 2, section 18, Safety Assurance System: Evaluation of a Certificate Holder’s Management of Significant Changes Parts 121, 135, and 91 Subpart K.

Following its initial response indicating intent to take responsive action, the FAA informed the NTSB in September 2023 that a Daily Broadcast published before the recommendation was issued notified POIs and front-line managers about the circumstances of the PenAir accident. Our February 2025 response noted that the broadcast did not emphasize the importance of existing guidance for detecting and mitigating the safety risks that can result when certificate holders experience significant organizational change, as recommended, and classified this recommendation Closed—Unacceptable Action.

Both Safety Recommendations A-10-26 and A-21-49 were i

February 26, 2025 · NTSB Correspondence · FAA

We note that, on October 18, 2019, before this recommendation was issued, you published a daily broadcast that was distributed to all FAA employees, including POIs and FLMs, about the circumstances of this accident. Although the daily broadcast was distributed to POIs and FLMs and included information about this accident, it did not emphasize the importance of existing FAA guidance for detecting and mitigating the safety risks that can result when certificate holders experience significant organizational change, such as high personnel turnover, a reduction to route structures or flight schedules, bankruptcy, acquisition, and merger.

We continue to believe the FAA should notify POIs and FLMs about this specific safety issue. However, because you have not taken or planned any actions to address this concern, the Board has classified Safety Recommendation A-21-49 CLOSED-- UNACCEPTABLE ACTION.

September 14, 2023 · Recipient Response · FAA

-From Kathryn B. Thomson, Deputy Administrator: The Federal Aviation Administration (FAA) employed the agency’s FAA Daily Broadcast to notify all its employees, including principal operations inspectors and frontline managers, about the circumstances of this accident. Attached is the October 18, 2019, broadcast highlighting this accident. The information linked in the Daily Broadcast is available at the following website:

https://www.alaskasnewssource.com/content/news/Plane-off-runway-at-Unalaska-Airport-563346322.html

The FAA distributes accident information through our Daily Broadcast as a common practice, aimed at enhancing safety awareness. Furthermore, FAA employees can access additional information about accidents and incidents through numerous agency portals, including, but not limited to, the FAA’s Aviation Safety Information Analysis and Sharing system and the Safety Performance Analysis System.

September 1, 2022 · NTSB Correspondence · FAA

We note that you intend to take the recommended action. Pending our receipt of future updates and completion of the recommended action, Safety Recommendation A-21-49 is classified OPEN-- ACCEPTABLE RESPONSE.

January 25, 2022 · Recipient Response · FAA

-From Steve Dickson, Administrator: The FAA agrees with the importance of notifying the principal operations inspectors and frontline managers about the safety risks that can result when certificate holders experience significant organizational change and intends to adopt the complete recommendation following additional review and coordination.

November 18, 2021 · NTSB Correspondence · FAA

The attached letter from the NTSB Chairman provides information about the NTSB’s November 2, 2021, report Runway Overrun During Landing, Peninsula Aviation Services Inc. d.b.a. PenAir Flight 3296, Saab 2000, N686PA, Unalaska, Alaska, October 17, 2019, NTSB/AAR 21/05. 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-21-46 through -51). 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) November 2, 2021, report Runway Overrun During Landing, Peninsula Aviation Services Inc. d.b.a. PenAir Flight 3296, Saab 2000, N686PA, Unalaska, Alaska, October 17, 2019, NTSB/AAR-21/05. The details of this 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:

• Potential for cross-wiring of airplane antiskid brake systems • Insufficient Federal Aviation Administration (FAA) guidance to identify safety risks for air carriers experiencing significant organizational changes, including bankruptcy, acquisition, and merger • Lack of FAA consideration of runway safety area dimensions during the process of authorizing an air carrier to operate its aircraft at a specific Title 14 Code of Federal Regulations Part 139-certificated airport • Safety management systems for organizations that design, manufacture, and maintain aircraft.

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.

• Identify all currently certificated transport-category airplanes for which system safety assessments for landing gear systems did not consider human error that could lead to cross-wiring of antiskid brake system components, including the wheel speed transducers, and require manufacturers of transport-category airplanes without such assessments to perform the assessments and then implement mitigations to prevent cross-wiring of antiskid brake system components. (A-21-46) (See section 2.3.4.1.)

• Require the submission and consideration of system safety assessments addressing the landing gear antiskid system for the certification of future transport-category airplane designs. The certification should ensure that the system safety assessments are consistent with the intent of Advisory Circular 25.1309, System Design and Analysis, and that the assessments evaluate and mitigate the potential for human error that can lead to a cross wiring error. (A 21-47) (See section 2.3.4.1.)

• Require organizations that design, manufacture, and maintain aircraft to establish a safety management system. (A-21-48) (See section 2.3.4.2.)

• Notify principal operations inspectors and frontline managers about the circumstances of this accident and emphasize the importance of existing Federal Aviation Administration guidance for detecting and mitigating the safety risks that can result when certificate holders experience significant organizational change, such as high personnel turnover, a reduction to route structures or flight schedules, bankruptcy, acquisition, and merger. (A-21-49) (See section 2.5.1.)

• Revise Order 8900.1, Flight Standards Information Management System, to include a formalized transition procedure to be used during a changeover of certificate management team personnel responsible for overseeing a certificate holder that is undergoing significant organizational change (for a reason described in volume 6, chapter 2, section 18 of the order) to ensure that incoming personnel are fully aware of potential safety risks. (A-21-50) (See section 2.5.1.)

• Include the runway design code for runways of intended use among the criteria assessed when authorizing a scheduled air carrier to operate its airplanes on a regular basis at an airport certificated under Title 14 Code of Federal Regulations Part 139. (A-21-51) (See section 2.5.2.)

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-21-46 through -51). 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.