"Thank you for the opportunity to testify on the State of Aviation Safety. On behalf of the world's largest non-governmental aviation safety organization, I can report that the view from the flight deck is that the state of safety in our skies remains sound. However, it is our organization's top priority to stay focused on continual improvement and judicious oversight to ensure that air travel is as safe as humanly possible.
"The pilots of ALPA express our deepest condolences to the families and loved ones of the victims of both the Ethiopian Airlines Flight 302 and Lion Air Flight 610 accidents. We cannot know the depth of the grief that they feel, but we can share in their determination to leave a legacy of a safer air transportation system for those they lost.
"As a 40-year airline pilot, achieving the highest standards of safety has been a personal commitment throughout my career. As the president of ALPA, the world's largest nongovernment aviation safety organization, I can tell you that all airline pilots share my dedication to advancing aviation safety and that safety has been the foundation of ALPA's work for more than 85 years. In fact, across town this week, we are hosting our 65th annual
"While aviation accidents are increasingly rare, ALPA has advocated and helped develop a forensic approach to accident investigation designed to identify every factor involved in an airline accident and develop corrective actions to address them, with the sole goal of preventing similar accidents from occurring in the future. In the
"Because of this commitment, ALPA is fully informed and involved in efforts to bring the
"ALPA has offered our airline pilot perspective on the issues related to the accidents, including the process and procedures used to certify aircraft in
"So to the families and loved ones who are here today, I can assure you that the 62,000 pilots of ALPA resolve to be vigilant in ensuring that the
"Based on current statistics, 14 Code of Federal Regulations (CFR) Part 121 airlines carry approximately 900 million passengers and 18 million tons of cargo annually.
"Strikingly, since 2009, there have been 93 fatal passenger airline accidents around the rest of world, which includes more than 4,700 fatalities.
"This Committees' continued focus on safety is to be commended, and we thank you for using your time and resources - including today - to shine a spotlight on safety. Unless we keep airline safety the top priority, we risk digression and an increase in accidents, which impact our ability to make progress on other important aspects of aviation such as investments in increasing airspace capacity and the introduction of new types of aviation and space operations into the National Airspace System.
Retention of Congressionally Mandated First Officer Qualifications
"The pilot training and qualifications regulations specifically require that all airline pilots flying under 14 CFR Part 121 must hold the air transport pilot (ATP) or Restricted ATP (R-ATP) certificate. The restricted R-ATP certificate pathway, can be obtained with fewer flight hours than the ATP, if the pilot applicant receives integrated academic and flight training from the military or an accredited aviation college or university.
"Today's training and qualification regulations emphasize significantly greater focus on academics and instruction, areas of knowledge, and flight experience in various weather and operational situations. The rules also require a type rating in the aircraft to be flown for the airline if operated in 14 CFR Part 121 service and increased experience in multi-engine aircraft. among other numerous safety improvements. The
Safety Regulations vs. Bad Airline Economics
"Despite the clear message sent by
"It is somewhat ironic that some who originally called for the changes in P.L. 111-216 have since become critical of the rules, arguing that the First Officer Qualifications have created a pilot shortage. Small communities which have experienced changes to the levels of airline services are also citing a pilot shortage. However, in both cases, there is no reliable data to support these positions and, in fact, the data says just the opposite.
"In 2018, the
Pilot Experience before Airline Flying is Critical
"The length of time from when a pilot obtains his or her commercial pilots license to when they have accumulated the hours and flight experience necessary to qualify for the ATP or R-ATP certificate is measured in months, not years or decades. Pilots who graduate from an accredited, structured university and are qualified for the R-ATP pathway can currently expect to spend 12 months or less flying in entry level commercial operations or flight instruction before transitioning to an airline.
"Some regional airlines would like pilots to come pre-programmed directly from a flight training environment that is directly similar to the flying environment of that specific carrier's, without having to make any training adjustments. While accredited universities produce pilots with the fundamental skills and knowledge to obtain a commercial pilot certificate, pilots who bring a more holistic, real-world set of skills, including training in a variety of weather, terrain, and air traffic control environments is beneficial. In our view, this versatility of experience far outweighs a small amount of airline training that is specified to mold the pilot into a single airline's operation.
"It is important to note that airlines do not provide training to pilots (or allow them to take aircraft out to practice) so that they can obtain experience in factors such as weather (e.g., thunderstorms, snow, tropical storms), terrain (e.g., high altitude, mountain flying), and high-density air traffic (e.g.,
Taking the First Officer Qualifications Requirements to ICAO
"In response, Secretary Liu called an ad-hoc meeting at ICAO to discuss this topic, which was held this month at ICAO headquarters in
Promoting the Profession and Increasing Diversity
"ALPA continues to promote the airline pilot profession. This includes a team of ALPA pilots who promote the profession at several large aviation events including Women in Aviation; the
"All of these activities to promote the profession have included a focused effort to diversify the pilot community. This includes our efforts to reduce barriers to entry for minorities and women. We believe that there is no shortage of individuals who have the motivation, skills and aptitude to serve as airline pilots for a
"We were pleased to support provisions in the Aviation Safety and
Two Pilots Are Needed in Today's Airline Cockpit
"Even when the proposal for an
"Maintaining today's level of safety, security and efficiency is much more important than any dubious benefits of moving a pilot from the cockpit to a remote location. Further, the aviation industry's collective efforts to focus on higher priorities for the benefit of passengers and shippers, should not be distracted by the establishment of a federal program to evaluate or study this project at any agency or with any federal dollars.
Addressing All-Cargo Airline Safety
"Many of the safety and security layers working to protect our passenger airline industry are absent from all-cargo operations. Cargo airlines fly the same aircraft, takeoff and land from the same airports, utilize the same airspace, and fly over the same cities as passenger aircraft. From a safety and security standpoint, there is every reason to hold all-cargo operations to the same safety and security standards as passenger operations. All-cargo airline operations currently experience an accident rate that is seven times higher than passenger airline operations worldwide.
"While many of the same regulations are used for both commercial passenger and all-cargo airlines, there are lesser requirements placed on all-cargo operations in several very important areas, which result in unnecessary safety risk.
"One example of this safety double standard between cargo and passenger operations is flight crew flight, duty, and rest regulations. While updated science-based flight- and duty-time regulations for passenger operations were issued in 2011 and implemented in 2014, those rules apply only to flight crew members at passenger airlines and do not include all-cargo pilots. The
"Although there are other differences in all-cargo airline and passenger airline operations under 14 CFR Part 121, as discussed below, the correlation of reduced flight- and duty-time regulations and the tarnished safety record cannot be dismissed as a coincidence. With relatively few differences in the regulations between all-cargo and passenger airline operations, the differences in flight- and duty-time regulations are an obvious area that needs to be addressed.
"However, unless we make meaningful changes soon, all-cargo airline operations will likely continue to have preventable accidents and fatalities at elevated levels relative to 14 CFR Part 121 passenger operation.
"Another example of a significant safety gap is that all-cargo operations are exempted from Aircraft Rescue and Fire Fighting (ARFF) requirements contained in 14 CFR Part 139. This means that ARFF is not required to be staffed or even present at airports during operations of all-cargo aircraft.
"Further, cargo aircraft carry very hazardous cargo, such as blood-borne pathogen, chemical, and radioactive material. Not only should ARFF be staffed during all-cargo operations, but ARFF personnel must be trained for dealing with fires on all-cargo airliners. Measures need to be developed and implemented that will properly prepare firefighters for dealing with a cargo aircraft fire. There is a lack of proper ARFF equipment needed to fight all-cargo aircraft fires at some airports, including nozzle tips designed for penetrating cargo airliner hulls, and a lack of funding, because the exemption of cargo from 14 CFR Part 139 requirements interferes with fire departments' ability to get the resources they need for staffing, equipment, training, and developing strategy for cargo-specific events.
"ALPA has maintained a strong stance that all-cargo operations must have the same level of safety as passenger airlines. The facts, however, speak for themselves. There have been five (5) fatal all-cargo 14 CFR Part 121 accidents in the
Missing Cockpit Doors on All-Cargo Aircraft
"Today, however, a significant number of all-cargo airliners are still operated without the benefits of hardened flight deck doors, leaving them without a means of adequately separating the flight crew from personnel riding aft of the bulkhead, and potential cargo-hold stowaways. In fact, new wide-body cargo airplanes such as the B777 and the B767 are being built and delivered to all-cargo operators without the protections afforded by the reinforced door. The potential for a significant lapse in security due to these conditions is magnified by the fact that all-cargo airliners frequently carry third-party, non-crew personnel (known as "supernumeraries"), such as couriers and animal handlers, who are not subject to criminal history-based security background checks required of other airline employees. These animal handlers carry strong sedatives and syringes that can be used on the animals if necessary during flight. There is a significant concern by our members that these improperly-vetted individuals are able to use these sedatives or otherwise take hostile actions against the flight crew absent the protections of a primary door. This situation is exacerbated by the fact that all-cargo airliners and their cargo are not afforded the same security protections as their passenger-carrying counterparts while on the ground.
"The lack of a mandate for reinforced flight deck doors on cargo aircraft is hard to justify when the
"In order to ensure one level of security of all 14 CFR Part 121 operations, all-cargo flight decks must be clearly delineated and physically protected in the same fashion as the flight decks of passenger airliners. This includes the provision of reinforced flight deck doors and the associated flight deck access procedures for crewmembers.
Secondary Barriers Delayed
"Reinforced flight deck doors, mandated on passenger airliners by the
"At the behest of this Committee, section 336 of P.L. 115-254 requires "not later than 1 year after the date of the enactment of this Act, the Administrator of the
"However, with a deadline in 3 months, the
"Clearly, this is a move to slow down or otherwise not fulfill the obligations
"Some may argue there are questions about how to implement the legislation. However, these questions were answered years ago by request from the
"RTCA Special Committee (SC)-221 developed and published these guidelines in
"We urge the Committee to continue to monitor this situation, and to ensure that the
Safe Shipments of Hazardous Materials
"ALPA has long advocated for improved transport requirements for hazardous materials both as a member of IFALPA, and here in
"Although lithium batteries represent a significant technological improvement over older battery technology, their high energy density and flammability make these batteries more prone to failure, resulting in fire and explosion. The lack of comprehensive hazardous materials regulations for the carriage of lithium batteries as cargo onboard commercial aircraft, both passenger and cargo, continues to pose risks to air transportation.
"New standards implemented by ICAO on
"While the harmonization of the US regulations to ICAO limitations is a good first step, it does not go far enough in addressing the safety risk created by lithium batteries. Work must continue to develop and mandate performance-based packaging standards that will prevent and/or contain a lithium battery fire. These standards must also address the threat from external fires.
Undeclared Hazardous Materials Pose a Threat
"We are pleased that undeclared hazardous materials were addressed by Section 583 of the
"Hazardous materials, comprised of liquids, flammables, and other materials, shipped as cargo without being identified by the shipper are considered undeclared hazardous materials. There are no official estimates of what percentage of parcel shipments contain undeclared hazardous materials; however, the
Training with Simulation - There are Limits
"As is well recognized, the
"While they may be acceptable to train pilots on checklist execution, or to help pilots learn the basic flow of cockpit procedures, there are some airlines that desire to begin to use non-movement simulators to evaluate pilots in training. The safety benefits of using simulation with full-motion are well documented and the use of motion-based simulation is mandated for some airline pilot training. We question the viability and benefit of re-introducing non-motion simulators for anything beyond basic initial aircraft cockpit orientation and procedures development.
"Conversely, there are others who believe that nearly all the training needed to become an airline pilot can be conducted with motion-based simulation. They argue that a pilot's basic skills can be taught using carefully scripted "real world" scenarios to teach pilots basic knowledge and to leap-frog critical operating experience in the airspace system. An example of this simulation-based licensing scheme is an ICAO licensing option called the multi-crew pilots license, or MPL. Pilots flying for airlines with an MPL do not pass through the individual licensing levels such as the private pilot license, the instrument rating, the commercial pilot license, a multi-engine rating, high-altitude operations endorsement, etc. Instead, MPL pilots "hit the sim" on day number one of their training and within a very short time, without adequate real-world experience, they are placed into a transport category aircraft flying for an airline. They are essentially apprentice pilots, requiring the captain to overcome any training and experience shortcomings that the first officer may have, alone.
"From our view, both of these "extremes" need to be carefully monitored. Expanding the motion-based simulation technologies as a replacement for tried-and-true real-world flying is nearly impossible to achieve. And permitting airline pilot training and testing to be conducted with non-motion simulators will not give pilots the added benefits that have long been documented for a suitable training environment. We urge the committee to engage the
Safe Integration of Unmanned Aircraft Systems and Drones
"With the rapidly growing use of UAS for any number of applications and uses, the safety risks to airline operations need to be monitored very closely. We applaud this Committee's commitment to ensure UAS safety, by holding a hearing earlier this year that focused on aviation in 2050. Clearly, at some point in the future, UAS will be integrated into the national airspace system (NAS), interacting with other aircraft in a manner similar to "pilot on board" aircraft today.
"Recently, a company approached the
"Granting this petition for exemption would allow the petitioner to bypass the
"As required under 14 CFR Part 11.35 (b), the
"We must not allow pressure to rapidly integrate UAS into the NAS without appropriate safeguards in place. This process must be focused on safety as the highest priority. Risk mitigation plans, which have yet to be fully developed, combined with consensus-based technology standards that will ensure interoperability with manned aircraft, must be in place before a UAS can occupy the same airspace as manned aircraft or operate in areas where it might inadvertently stray into airspace occupied by airliners. When UAS operate in the same airspace as airline aircraft, the pilots will need to be able to see them on cockpit displays, and air traffic controllers will also need to see them on their displays to safely separate air traffic. Further, the UAS must be equipped with active collision-avoidance technology. We will oppose any integration that does not include collision avoidance systems that are interoperable with airline collision avoidance systems.
"If a UAS operator does not intend to fly in the same airspace as airliners, then limitations that ensure that the UAS stays out of the airspace must be programmed into the UAS in a way that cannot be overridden.
sUAS Identification and Tracking Technologies are Needed
"As has been widely reported, a drone collided with a
"If an identification and tracking system had been in place prior to the
Integrating Commercial Space Operations Improves Safety
"Commercial space operations are not new. In fact, it has been more than 30 years since
"These are truly exciting times for America as we experience innovation and advancements that are literally blasting off before our eyes. However, we must continue to make commercial aviation part of the discussion on commercial space. Future growth and success of
"One thing is clear: expanded markets and technology advances in space are enabling new commercial companies to access these limited resources, which has become a critical challenge for the aviation community. Air traffic management, airports, and the NAS are regulated and managed according to strict operational and safety regulations, which will not sufficiently accommodate the projected growth and evolution of space transportation, without enhancements to how space flight is accommodated by the NAS. There must be a means to safely integrate with existing aircraft operations and infrastructure without decreasing the level of safety or efficiency for existing operations. Full integration will allow space operations to plan and execute launches without extensive coordination like they do now, and full integration will also eliminate the need for segregation of space operations from commercial airline flights. Bottom line: commercial space integration improves safety and efficiency of the NAS for all airspace users. A strategy to fully integrate commercial space operations into existing NAS operations is a critical first step to achieving this important goal.
"Neither industry would be successful today without the other. Each sector generates hundreds of billions of dollars in annual economic returns for
"An important reason to keep the commercial space industry a part of the aviation discussion is that there are going to be innovations in safety and efficiency that will likely find their way into commercial aviation. For example,
"ALPA is very interested in supporting the commercial space industry's efforts to advance through the full integration into the NAS. To fully articulate the complementary nature of commercial space and commercial aviation, we published a white paper, "Addressing the Challenges to Aviation from Evolving Space Transportation" that documents the role of the government agencies and industry, both historically as well as today. That whitepaper can also be found at www.alpa.org/whitepapers.
Safety Data Analysis is Critical to Ensure Risks are Proactively Identified
"When thinking about aviation advancements over the next several years, there is one aspect above all others that needs our full support in order to continue to improve: aviation safety. The efforts of the Commercial Aviation Safety Team (CAST) combined with Aviation Safety Information Analysis and Sharing (ASIAS) have led to dramatic improvements. Data analysis by CAST and ASIAS has resulted in a proactive safety culture that cuts across all airlines and stakeholders with unprecedented levels of collaboration, even when those same stakeholders disagree about many other aspects of industry policy. The predictive risk analysis conducted by the CAST and ASIAS allows the aviation community to collectively reach heightened levels of safety without waiting for a single drop of blood to be shed. We believe that the resource needs for the ASIAS activity are likely going to increase in order to keep up with the accelerated pace of operations. We urge
Necessary Resources to Ensure Safety of our Skies
"A safe airline industry is only possible when the
"The partial government shutdown earlier this year has perhaps faded from the memories of most Americans. But the shutdown has not faded from the memories of ALPA pilots, who found themselves faced with new and different types of risks than they had experienced in the past. The
"But the realities of work without pay started to set in quickly, and our airspace system was put at risk for no good reason whatsoever. Political gamesmanship put our national transportation system at risk. Fortunately, the system's safety net worked, and the shutdown ended without serious ramifications to air travel.
"ALPA was pleased to be among the first to support Chairman DeFazio's legislation that will allow the
"The new types of operations the
Strengthening Voluntary Safety Reporting Programs
"Voluntary safety reporting programs such as the Aviation Safety Action Program (ASAP) and Flight Operations Quality Assurance (FOQA) are important, collaborative tools that enhance aviation safety through the analysis of voluntarily reported safety events and discrepancies that lead to the prevention of accidents and incidents. The purpose of ASAP and FOQA is to encourage and use voluntarily reported safety information provided by frontline employees and airlines, respectively, to identify safety risks. Without these valuable safety reports, unidentified risks go unmitigated and remain within the system.
"For example, more than a decade ago the implementation of stabilized approach technology and procedures became a top safety priority upon discovering the frequency of non-stabilized approaches being reported by pilots. More recently, data sources have been combined to identify potential risks that are initially identified through the voluntary safety programs. Ground radar data, historical weather information, and other data sources were used to identify instances when aircraft traffic and terrain warning systems were repeatedly alerting to false alarms. These voluntary safety programs triggered studies of these alarms, which ultimately led to the discovery that improvements to airspace and procedures design would reduce the false alarms. These examples prove that the underlying voluntary safety program reporting by the operators is the best source to identify potential risk areas and to investigate and ultimately mitigate these risks.
"We were pleased to see that Section 320 of the
Fair and Open Skies - Ensuring that Aviation in America Remains Safe and Strong
"ALPA would like to thank Chairman DeFazio and Chairman Larsen, as well as
"We appreciate the Committee's invitation to offer our insights and perspectives on these important aviation safety issues today. More importantly, we appreciate the leadership that continues to be demonstrated by the Committee to advance these high-priority safety issues. The airline industry is best positioned to fully meet the needs of all passengers and shippers when safety levels remain at, or exceed, their current levels. It is in our collective best interest as legislative leaders, labor organizations, companies, and regulators, to ensure the foundation of safety is solid, and continues to lead the rest of the world. We look forward to working on these issues with you in the coming months as we strive to make meaningful safety improvements to aviation."