NTSB's Hudson Recommendations: Mixed
Continuing its let's-really-jump-the-gun-on-this-one response to the Hudson River midair collision on August 8th, the board last week issued a set of recommendations to the FAA. This was done well before any conclusions about the cause of the accident have been reached, making me wonder if the board has become more politically charged than it used to be. All government agencies make administrative decisions based on politics, some more than others. Generally, the NTSB has knee-jerked to local legislators and the White House far less than other agencies, but things change.
Looking over the NTSB's recommendations, I see a mixed bag, but the kernel of one good idea, if it's executed correctly. Thus far, the agency's investigation has revealed that the Piper and helicopter slipped into a tiny crack in what has proved to be a good system for the Hudson. When the Piper pilot departed Teterboro, he asked for VFR advisories through the Class B—so he rightfully assumed traffic calls and separation from other Class B traffic would be provided. (That is, if he understood basic separation requirements.) What he perhaps didn't understand is that all that traffic buzzing down the river under the Class B floor self-separates via an agreed-upon CTAF and by eyeball. Some are talking to ATC, but most aren't. The NTSB observed that the Piper pilot wasn't participating in the self-separate program and being between frequencies with ATC, he wasn't getting advisories, either. He was betwixt and between.
The NTSB thinks ATC ought to verbally advise pilots who are dropping down below the floor of the Class B to use the CTAF frequency. Not a bad idea. They also want the CTAF procedure to be placed on tower ATISs in the region. Bad idea. Those ATISs are already clogged with too much verbiage and only a small portion of pilots transitioning the corridor will even hear them.
The NTSB also wants the FAA to establish a special flight rules area or SFRA. This would require pilots to have dedicated training before entering the airspace. LAX's VFR flyway has such an SFRA as does the Washington, D.C. area. The board thinks the training required of pilots entering the D.C. area would serve as model. This is an easy-to-complete online course and if it's done right, it could actually be beneficial at zero cost to the industry or pilots. If it could impose a little order in the chaos that occasionally surrounds the Statue of Liberty, again, not a bad idea and relatively benign as regulation goes.
But it won't fix the problem because there is no problem. And the NTSB concedes as much. In some 30 years of operation, there have been no midairs in the Hudson corridor and the FAA says about 200 aircraft transition daily. (I bet the number is higher, because I don't think anyone is counting.)
So let's put some numbers on that. Figuring 200 airplanes a day, it works out to an accident rate of .047 per 100,000 operations. Let's see, it takes maybe 15 minutes to fly the corridor from the Tappan Zee to Sandy Point, so presently, we stand at 0.18 accidents per 100,000 flight hours or something like 35 times lower than the GA overall GA accident rate of about 7/100,000 and even a little lower than the air carrier rate of .22/100,000.
It's a delusion to think procedures are going to move that rate downward. What they can do, however, is give pilots more knowledge and comfort in flying in this airspace and that's not a bad thing. But frankly, I won't be disappointed if the FAA does nothing with the NTSB recommendations. Other than mollifying the squalling political class, they won't accomplish much.