Reassessment of the response to TSB Recommendation A19-05
Collecting activity data specific to the air-taxi sector
In May 2015, the Transportation Safety Board of Canada (TSB) launched an in-depth Safety Issues Investigation (SII) into the risks that persist in air taxi operations across Canada. This SII reviewed 15 years of data to identify safety issues in Air Taxi Operations in Canada that have not been sufficiently mitigated. This SII examined air taxi operations as a whole and considered safety issues that are germane to the entire air taxi industry and not just to one specific segment of the industry.
The Board concluded its SII and released report A15H0001 on 07 November 2019.
TSB Recommendation A19-05 (November 2019)
A key indicator of aviation safety is the aircraft accident rate, which is calculated as the number of accidents per hours flown or per number of movements (a movement can be a takeoff or a landing). Performing a trend analysis of accident rates for different types of operators can detect emerging safety issues associated with specific operator types and activities. In addition, accident rate data makes it possible to compare accident risk for different operator types, in different countries or on different continents. For example, the U.S. Federal Aviation Administration (FAA) compiles scheduled and non-scheduled flight hours and departures under Title 14 Code of Federal Regulations (CFR). Operators governed by Part 135 of Title 14 CFR include on-demand carriers, which are similar to Canadian air-taxi operators. The U.S. National Transportation Safety Board (NTSB) uses these activity data to compute accident rates and fatal accident rates across sectors.
Activity data (e.g., flight hours) broken out by operator typeFootnote 1 is required to calculate the accident rates that enable trend analysis of specific operator types over time, or comparisons across operator types or geographical regions.
Until 2010, TC provided activity data broken out by operator type, and the TSB used these data to calculate and publish accident rates across operator types. In 2010, however, TC informed the TSB that it would no longer provide hours-flown activity data breakouts by operator type, because it had concerns regarding the accuracy of those data. The data were reported to TC by the commercial operators who were allowed to report all hours under the most restrictive subpart of the CARs, even if they conducted operations under more than one subpart.
Reporting all hours for all subparts under a single total conflates and confounds airline and commuter activity, as well as the activity of many smaller aviation operators that may carry out operations under multiple subparts of the CARs (commuter, air taxi, and/or aerial work) and report their activity as a single total. Furthermore, the movement data as presently reported by Statistics CanadaFootnote 2 come from a survey that covers all aircraft movements at Canadian airports, with or without NAV CANADA air traffic control towers and flight service stations. Air-taxi operations are conducted at these locations, as well as in locations such as lakes, unprepared landing sites, remote locations, etc. where movements are not recorded by air traffic service providers.
Because hours-flown and movement data are currently not categorized by CARs subpart when collected by the government, the rate data calculated is for the commercial aviation sector as a whole; there is no differentiation between sectors (e.g., air-taxi operators versus airline operators) or between different types of aircraft (airplane, helicopter, floatplane). Therefore, the accident rate cannot be calculated for just the air-taxi sector.
Without hours-flown and movement data that are categorized by CARs subpart and aircraft type, it will be more difficult for sector stakeholders to assess risks and determine if mitigation strategies being carried out to improve safety are actually working.
Therefore, the Board recommended that
the Department of Transport require all commercial operators to collect and report hours flown and movement data for their aircraft by Canadian Aviation Regulations subpart and aircraft type, and that the Department of Transport publish those data.
TSB Recommendation A19-05
Transport Canada’s response to Recommendation A19-05 (January 2020)
TC agrees with the recommendation.
TC agrees that more precise activity data will help stakeholders in the air-taxi sector to assess risk and evaluate, to an extent, which mitigating strategies to improve safety are having a greater impact.
TC also recognizes that collecting these data would require significant investment, from both the industry who would be required to provide the data, and for TC who would be required to collect and analyse it.
To this end, TC will consult with industry by the end of 2020. Work will also be undertaken by TC to evaluate what has already been done regarding collection and reporting of data, determine what data/information is missing and consider the requirements and best approaches to obtain the activity data described in the recommendation. The consultations would be followed by an internal summary of what we heard from the consultations, which would likely be shared by means of the TC Let’s Talk Page. TC would be better positioned by summer/fall 2021 to determine whether or not a regulatory proposal would be appropriate.
TSB assessment of Transport Canada’s response to Recommendation A19-05 (March 2020)
In its response, Transport Canada (TC) indicated that it agrees with Recommendation A19‑05.
After it consults with industry and evaluates what was previously in place to collect and report data, TC will determine the best approach to obtain the data required by Recommendation A19-05. By summer or fall 2021, TC expects to be able to determine if a regulatory proposal is appropriate.
The Board is encouraged that TC has a strategy moving forward with regards to addressing the safety deficiency identified in Recommendation A19-05. However, at this time, the Board is unable to determine if these actions will result in specific solutions to address the safety deficiency identified in Recommendation A19-05.
Therefore, the Board is unable to assess the response to Recommendation A19-05.
Transport Canada’s response to Recommendation A19-05 (December 2020)
TC agrees in principle with the recommendation.
In its initial response to this recommendation in January 2020 (RDIMS 16234372), TC committed to carry out an initial policy assessment to: evaluate what has already been done regarding collection and reporting of data, determine what data/information is missing and consider the best approach to obtain these data. We further committed to consult with industry by the end of 2020.
Since TC’s initial response, we created a WG to conduct document reviews, meet with internal SMEs and explore current data collection options. Unfortunately, due to the global pandemic, work on this file in 2020 has been delayed. However, initial work is underway. A WG meeting was held in early October 2020 and a consultation paper is currently being developed that will be used to gather input from commercial operators in the air taxi industry in winter 2021.
As a next step, the WG will identify the requirements and best approaches to obtain activity data described in the recommendation by the end of fall 2021. Once the review and consultation are completed, TC will be in a position by fall 2021 to propose any regulatory and non-regulatory recommendations.
TSB reassessment of Transport Canada’s response to Recommendation A19-05 (March 2021)
In its response, Transport Canada (TC) indicated that it agrees in principle with Recommendation A19-05.
TC continues to be committed to an initial policy assessment to evaluate what was previously in place to collect and report data, determine what data is missing and determine the best approach to obtain the data required.
TC has created an internal working group to conduct the review and explore data collection options. This group’s work has been impacted by the current global pandemic; however, work is being done regarding plans for air-taxi sector consultations to take place in the winter of 2021. TC indicated that the working group will identify the requirements and best methods to gather the data by the end of fall 2021.
TC also indicated it will be in a position to propose any regulatory or non-regulatory approaches by the fall of 2021.
The Board is encouraged that TC has a more detailed strategy moving forward to address the collection of activity data specific to the air-taxi sector. These actions, when fully implemented, have the potential to substantially mitigate the risks associated with the safety deficiency identified in Recommendation A19-05.
Therefore, the response to Recommendation A19-05 is assessed as Satisfactory Intent.
Next TSB action
The TSB will continue to monitor the progress of TC's actions to mitigate the risks associated with the safety deficiency identified in Recommendation A19-05, and will reassess the deficiency on an annual basis or when otherwise warranted.
This deficiency file is Active.
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