Public Benefit Flying: Safety Efforts Recognized
The NTSB contacts the Air Care Alliance (ACA) and demands that it take action to increase the level of safety of Public Benefit Flying and Volunteer Pilot Organizations—the ACA does so and the NTSB says, “Well Done.”
For over 70 years general aviation pilots have volunteered their time, skills and airplanes to help others in need by giving free flights for everything from search and rescue through medical transport, environmental survey and research to disaster relief, animal transport and exposing kids to the world of flight. What has been termed Public Benefit Flying (PBF) has saved lives, exposed toxic polluters, allowed collection of valuable scientific data, saved pets from euthanasia and generally enriched the lives of hundreds of thousands of people. Volunteer pilots have spent thousands of dollars of their own money providing free flights to help others.
Those who have made volunteer flights say that those flights have been some of the most personally rewarding flying they have ever done.
Up front disclosure: I've been a volunteer pilot doing Public Benefit Flying for over 25 years, am on the board of the Air Care Alliance—more about that nonprofit organization in a bit —and had some involvement in helping develop the safety training course that is described below.
As might be expected, volunteer pilots are passionate about what they do (there’s my understatement for the month). They tend to be Type A types who are determined to make the flights for which they volunteer happen. Most pilots make their volunteer flights in conjunction with a volunteer pilot organization (VPO) that functions as a clearinghouse to match those who need a free flight with pilots who are willing to make such flights—and the VPOs want to have as many flights as possible take place. VPOs were formed to provide help to people—if they don’t provide that help in the form of completed flights, why do they exist? Their donors want to see evidence that their money is going to an organization that is accomplishing its goals.
For some years, an unspoken issue of concern within the public benefit flying community was that pilots put pressure on themselves to complete flights and VPOs did so as well—intentionally or unintentionally. Few volunteer pilots are, or have been, professional pilots. Most did not take recurrent training beyond the absolute FAA minimum requirement—a flight review ever two years. While volunteer flying never involves emergency transport, when a pilot gets word that a cancer patient is in need of treatment, that an aircraft is down and a search is being organized, that the scientists have arrived from all around the country for the aerial survey over the spawning grounds and the time window to gather data is closing or that 20 dogs are going to be euthanized unless they can be flown to a no-kill facility in 24 hours, the pressure is on.
Pilots who had not flown professionally had received little training in making the go/no go decision beyond what they learned while getting their rating(s), usually just some discussion of avoiding gethomeitis. A look at the general aviation accident record would show that pilots didn’t always make appropriate go/no go decisions.
VPOs varied widely in how they approached the matter of aeronautical decision-making for their volunteer pilots. Some had training and guidelines and made it clear to pilots that there would never be any adverse feedback if they postponed or canceled a flight—others did not. In addition, as might be expected, there are a lot of big egos in the world of volunteer flying—as is the case in the world of nonprofit organizations generally—and a certain attitude on the part of VPOs that they knew how to do things best and nobody could tell them what to do.
Enter the Air Care Alliance
In 1995, the Air Care Alliance (ACA) came into being. A nonprofit organization, its purpose was to be an umbrella organization for all VPOs. It holds an annual conference where it invites the approximately 70 VPOs to get together and exchange ideas for best practices and operational safety. Early on, Air Care Alliance board members recognized the concerns with aeronautical decision-making that were unique to public benefit flying and began working with VPOs to recognize and address the issue. During its annual conferences at which VPOs and volunteer pilots gather, the ACA had a number of seminars and open discussions on operational safety and aeronautical decision making, including one in 2008 at which the head of the AOPA Air Safety Foundation, Bruce Landsberg lead the safety best practices program.
In 2010 safety matters began to come to a head. In just over a year, there had been four high profile crashes involving pilots making a public benefit flight. In three of them passengers traveling for medical treatment were killed. The investigations uncovered evidence that the pilots had made very poor decisions regarding initiating or continuing their flights. In one, the pilot was in IMC, couldn’t intercept the localizer for an ILS and was being vectored around to try it again when he lost control of the airplane and crashed. He wasn’t even close to being current on instruments. The second fatal accident involved an 81-year-old pilot who decided to takeoff downwind. He managed to get the airplane into the air, but couldn’t maintain directional control and hit the glideslope antenna. The third accident killed a child who was being transported for medical treatment when the pilot flying a single-engine turboprop tried to takeoff downwind and couldn’t clear obstacles after takeoff. The fourth accident involved a pilot positioning to pick up a patient who decided to fly through convective activity, lost control of his airplane and crashed.
The accidents generated significant adverse publicity for public benefit flying with commentators criticizing amateur pilots carrying people who had no idea that the pilots didn’t operate at the safety level of charter flights, even going so far as to call volunteer pilots “Part 135 wannabees.”
In response to the accidents, the NTSB began looking at the safety of public benefit flying. The NTSB's mandate, by law, is to evaluate transportation safety. If it sees a problem, it sends a Safety Recommendation letter to the appropriate federal regulatory agency—for aviation, the FAA—recommending that the agency establish safety regulations to address the identified issue. It then keeps the heat publicly on the FAA to take action—and that heat often gets repeated by the media as it identifies safety issues the FAA should be addressing.
Once the word got out that the NTSB was looking at PBF, the concern was that the NTSB would call for the FAA to establish stringent regulations for public benefit flying, both affecting pilots and VPOs. Volunteer pilots had a right to be concerned—the FAA had established regulations under which a volunteer pilot could be reimbursed for her or his fuel expenses for a volunteer flight from the VPO, but the regulations were so onerous to comply with that it was often more expensive to comply than to pay for the fuel. Almost no volunteer pilots jumped through the myriad number of hoops required to get reimbursed for their fuel.
It was widely felt that FAA regulations on PBF would cripple it due to increased costs for pilots to comply as well as disqualifying a significant portion of the volunteer pilot pool because of more strict rating and flight time requirements to qualify to do PBF.
The NTSB’s Unexpected, and Challenging, Action
Instead of sending Safety Recommendations regarding PBF to the FAA, the NTSB—recognizing the value of PBF—on June 9, 2010, sent its Safety Recommendation letter to the Air Care Alliance calling for it to act. To anyone’s knowledge, the NTSB had never asked a non-governmental organization—which had no regulatory authority—to take action.
At first, what the NTSB asked the Air Care Alliance to do—require all VPOs to take steps regarding operational safety—seemed impossible because the Air Care Alliance cannot tell VPOs to do anything, each is an independent entity.
The Air Care Alliance board members (all volunteers themselves) made the decision to step up and see if it they could find a way to satisfy the NTSB as they knew that the NTSB’s next step would be to go the FAA. They, and others, felt PBF was at risk if the NTSB wasn’t happy with what the Air Care Alliance did and went to the FAA.
The NTSB’s letter identified three specific areas of concern: pilot currency; passenger awareness that the flights were not conducted under the same standards of a commercial flight; and safety guidance for pilots on aeronautical decision-making, preflight planning, pilot currency and self-induced pressure.
Air Care Alliance board members Rol Murrow, Lindy Kirkland and Jeff Kahn formed a working group and reached out to all VPOs of which the Alliance was aware (whether or not the VPO was a member of the Alliance) to pass along the specific NTSB recommendations. In addition, they immediately responded to the NTSB’s letter outlining what the ACA had already done at its conferences and in communication with VPOs to address safety issues for PBF—including having worked with the AOPA’s Air Safety Foundation. They provided the NTSB with information about the nature of VPOs and volunteer flying in general and outlined their plan to work with AOPA to create an interactive, on-line safety, training course directed at volunteer pilots and VPOs that the ACA would encourage VPOs to require that their pilots complete.
The NTSB’s response was to recognize that the Air Care Alliance could encourage, but not require, VPOs to comply with the NTSB’s recommendations and state that the actions the ACA was taking were moving in the right direction.
Slowly and Steadily
The ACA conducted polling of VPOs regarding their safety practices and, over the next six years, kept the NTSB informed of the results.
The ACA raised the $50,000 necessary to create an interactive PBF safety training course for volunteer pilots in conjunction with the AOPA to become one of the AOPA’s well-respected training courses on its website.
The online, multi-media, interactive safety course “Public Benefit Flying: Balancing Safety and Compassion,” was created. Nearly all VPOs instituted requirements that their pilots complete the course. As of last week, more than 10,000 pilots had done so, with a current rate of 100 pilots taking it each month.
Most VPOs also established requirements that its pilots take recurrent training annually and certify to the VPO prior to making a flight that the pilot was current for the flight.
Over the course of the next few years, the ACA continued to collect data from VPOs regarding their actions—including early disclosure to potential passengers that the flight would not conducted under the commercial aviation regulations.
The NTSB Approves
In February of this year, the Air Care Alliance reported to the NTSB that the majority of VPOs were requiring their pilots to complete the online safety course that included aeronautical decision-making, self-induced pressure to complete a flight and safety issues specific to volunteer flying; were requiring pilots to self-certify prior to making flights and disclosing the non-commercial nature of flights to potential passengers.
On April 25, 2016, Christopher Hart, Chairman of the NTSB, sent a letter to the Air Care Alliance to state that the Board had reviewed the Air Care Alliance’s response to the three specific safety recommendations the NTSB had made in 2010, including the online, interactive safety course, and had formally found that the actions the ACA and the VPOs had taken satisfied the demands of the specific Safety Recommendations and the matter was closed.
Chairman Hart concluded his letter to the Air Care Alliance with unusually warm language in a federal agency document: “Thank you for your efforts to address these recommendations and for your commitment to aviation safety. We were pleased to read that, although you believe your actions satisfy the recommendations, you consider improving flight safety an effort that is always ongoing, and that you are committed to continuing to remind and urge VPOs and their member pilots to implement these recommendations.”
In my opinion, the actions of the Air Care Alliance and its board members Rol Murrow, Lindy Kirkland and Jeff Kahn have not only increased the level of safety of public benefit flying through effective education but also prevented it from being hamstrung by onerous regulations. That seemed to be the consensus of the VPOs and volunteer pilots who attended the most recent ACA annual conference in Denver over this last weekend when the NTSB’s findings were announced.
The issue of pressure to complete a volunteer flight is ongoing, however, the training program generated by the Air Care Alliance, VPOs and the AOPA may be one reason that the safety record for public benefit flying appears to have improved (it’s impossible to identify accidents that haven’t happened) and the positive culture of safety among VPOs has been recognized by the NTSB. More effort is necessary as not all VPOs require training in recognizing the pressures on a pilot to complete a flight and not all volunteer pilots are aware of the safety training program that is available. There was recently a magazine article by a volunteer pilot worried about pressure to complete flights and unaware of the safety training program created by the ACA and AOPA. The NTSB has recognized the tremendous amount the Air Care Alliance and VPOs have done to increase the level of PBF safety, yet the need for outreach and education continues.
Rick Durden has been a volunteer pilot for LightHawk for over 25 years, is a member of the board of directors of the Air Care Alliance and is the author of The Thinking Pilot’s Flight Manual or, How to Survive Flying Little Airplanes and Have a Ball Doing It, Vols 1 & 2.