How granularly should we regulate?

For decades, pilots have been taught the following hierarchy when it comes to flying: Aviate, Navigate, Communicate (A-N-C). Those three words are ranked by priority.

First: Fly the aircraft. Aviate.

Next: Make certain you know where you are. Navigate.

Last: Tell others, in the air and on the ground, what you need them to know. Communicate.

A recent NTSB recommendation to the FAA has the potential to turn Aviate, Navigate, Communicate on its head.

Hyperbole? Yes. 

But, bear with me while I think this through.

The Ask

The NTSB wants the FAA to “Require Common Traffic Advisory Frequency Areas in Alaska.” That’s the headline of AIR-22-03.

Specifically, the NTSB wants the FAA to require all pilots to monitor and communicate their positions on the designated common traffic advisory frequency (CTAF) when entering and exiting dedicated CTAF areas throughout Alaska, as well as near established reporting points and airport traffic patterns within the CTAF area, unless already communicating with air traffic control.

A tragic July 31, 2020, midair collision (NTSB Report ANC20LA074) between a de Havilland DHC-2 Beaver and a Piper PA-12 resulted in seven fatalities (both pilots of each aircraft and five passengers on the DHC-2).

The Beaver had departed from Longmere Lake, the PA-12 from Soldotna Airport (SXQ). They collided just a few miles from their respective departure points.

From AIR-22-03:

• 21 airports are within a 30-mile radius of SXQ with five different frequencies (one Air Traffic Control tower, four CTAF)
• Only 13 airports have Air Traffic Control towers in Alaska
• From 2005-2020, there were 14 midair collisions in Alaska with 35 fatalities and 15 serious injuries.
• After three midairs in the summer of 2011, a working group was formed to find ways to mitigate this hazard. Recommendations included:
  • Discrete CTAF zones for Matanuska-Susitna Valley, the Cook Inlet area, and the Knik Glacier area
  • Depiction of zones on appropriate charts
  • Changing all CTAF within these areas to the same frequency

“If the multiple frequencies at these 12 airports within a 15-mile radius are already congested, how is forcing everyone onto a common frequency going to solve any problem?” asks reader Jim Carter, who commented on our story on the NTSB recommendation.

“If there is this much traffic in such a small space with both controlled and uncontrolled fields involved, why not establish a TRSA (yeah, I know I’m dating myself),” he continued, referring to a Terminal Radar Service Area. “Even if there are no towers operating, a TRSA could provide traffic alerts and separation. It doesn’t sound like pilots in the area are refusing to use radios, just too many uncoordinated frequencies in a high traffic area.”

I agree with Jim with regards to radio congestion. Others voiced similar sentiments.

The Odds

There were 5,844 days between the start of 2005 and the end of 2020. Searching NTSB data from Alaska, I found no example of multiple midair collisions on any single day.

That means that on 5,830 out of 5,844 days, no midair collisions occurred in Alaska. As a percentage, 99.76% of those days were free of midair collisions.

For something as dynamic as flying, that is a positive statistic. And that is using days. How many 9s would follow the decimal point if we use flights? 

Another Alaska accident, ANC09LA011, was a collision between a Cessna 152 and a Cessna 182R in the traffic pattern at Fairbanks International Airport (PAFA), while both pilots were in radio contact with the control tower. Thankfully, both pilots were able to safely land.

Go back to the top and re-read what the NTSB wants the FAA to require. I’ll wait.

The Reality

Sometimes accidents happen.

Layering on another regulation, I believe, is not the answer. Especially with something as rare as a midair collision.

The FAA already recommends, via Advisory Circular 90-66B, that pilots should “monitor and communicate, as appropriate, on the designated CTAF.”

The recommendations of the working group cited above are solid: Discrete CTAF zones, charting those zones, and aligning CTAF frequencies. Great.

Perhaps FAA Safety Enhancement Topic 18-07, “Fly the Aircraft First,” says it best: “It doesn’t matter if we’re navigating and communicating perfectly if we lose control of the aircraft and crash. A-N-C seems simple to follow, but it’s easy to forget when you get busy or distracted in the cockpit.”

Wouldn’t it be more effective it the FAA just prohibited pilots from getting “busy or distracted” while in the cockpit?

A recent report from the Aviation Safety Reporting System is an example of a traffic pattern communication breakdown. A student and instructor were in the pattern for touch-and-goes. They dutifully reported their position around the pattern. 

“After landing, a Cessna 208B calls in the CTAF and states that they are taking off. As we accelerated for takeoff, we see the Caravan coming straight towards us from the departure end of the runway.”

The ASRS report, written by the instructor, continues, “On the upwind, I ask if the Cessna heard us on frequency, and they stated that they did not, as they were not listening.”

Merriam-Webster defines the verb monitor as “to watch, keep track of, or check usually for a special purpose.” Alas, the definition doesn’t say anything about listening.

We can’t regulate every potential scenario. And we shouldn’t try.