Warning – A ramble follows:-
Quandary - Night VMC – Unresolved.
The accident report – HERE – (page 9 on) and the Safety Recommendation – HERE – clearly identify the horns of a dilemma onto which any honest safety authority would hate to be tossed. The operation of aircraft at Night in Visual Meteorological Conditions (NVMC), is a not only curly, dangerous area, fraught with legal peril – for the authority but for aircraft operators as well. Several serious attempts have been made to iron out the kinks, without impinging on the latitude the notion provides; it presents a problem with which one could find some sympathy for the authority dealing. You can, very quickly find much comment related to the subject and many a good argument for both sides.
What you cannot find (I cannot find) is an analysis – by operational class of the fatal accidents which occurred after dark. The ATSB have provided a graph which aligns ‘private’ operations against fatal accident by hours operated, which is fine – if a little dramatic. The ‘private ‘kill ratio’ is compared to Airline operations and Charter operations. This – IMO – provides a slightly skewed picture, not by any means deceptive when carefully read, but IMO (again) it fails to isolate and define a true picture of the seemingly high death rate in ‘private’ operations. This I believe is unhelpful when trying to establish a true picture and a safety case.
There are two basic tenets which demand that legislatively there must be a facility which allows visual flight at night; pilot training being one; the freedom to make a visual approach to landing after dark being another; which saves vast sums of money for commercial operations, and the ability for a Visual Flight Rules (VFR) operator to complete a task after daylight ends. All of which, in principal is a fine idea which could be fully supported, without a worrying aftertaste. It is a safe, practical and very valuable allowance. So where does the wheel come off?
“On a Gin clear night” after a while in the cockpit, you can actually see the features on the ground quite clearly, towns normally unseen can be identified by their loom, lakes and rivers seem to glow in the dark; with just a little moonlight the picture becomes almost perfect. The other side of the coin ain’t such an idyll. There is an expression ‘black-hole approach’, the RFDS probably know more about this than any operator on the planet. A dark night, middle of nowhere, rudimentary runway lights and no guidance other than the compass and your watch. It is bloody tricky stuff, not taken lightly by those who are regularly confronted by such conditions, it takes training and practice (lots of) to become proficient – if not comfortable.
And it is the ‘comfort level’ I am rambling towards. At very best there must be compromise which increases the risk level for government, operators and aircrew. The simple solution is to ban the concept, make any flight after dark subject to the Instrument Flight Rules (IFR) while keeping ‘visual approach’ in the mix. Then one could consider providing clearly defined rules which prohibited night flight under certain conditions; which is fine provided those conditions can be measured and met and argued about, later in court.
I confess to not having bothered to read the Part 61 rule set relating to the matter; (a) it is impossible (b) I have no need to – mea culpa. (Bite me). But a separate rating system could be developed, based against operational requirements could be hammered out, not that it would please all – but there is a need to find a level of comfort for all. For instance; the amount of ‘instrument flying training’ required could be matched to the stated operational requirement – say return to a town base within 60 minutes after the End of Daylight (EoD); or departing a bush strip after EoD with more than a 90 minute flight to destination etc. The details are endless, but a systematic approach could/should be evolved. We do loose aircraft and lives in the dark skies when the weather is being unhelpful, that is a stark undeniable fact. Another fact is that pilots will push on without having a key to the backdoor on their shirt pocket – that is human nature and cannot be controlled by regulation. This is particularly true of the modern age where ‘navigation’ is done by GPS and auto pilots work. The problem with this fine innovative technology is those aids cannot think, but they do lend a false sense of security.
End of ramble I think – for mine, I’d like to see the NVMC rating ‘beefed up’ and at least an annual check ride, without auto pilot or GPS. I know ‘old school’ methodology but a vast improvement is ‘situational awareness’ – IMO. As said, a puzzle for the regulator to solve, but solve it they must. Shutting down Angel Flight will not achieve this goal.
Phew, a long winded ramble, but I do feel the very real, chronic 'problem’ is worthy of serious discussion and positive action. Perhaps AOPA or AF could present a proposed solution to start the ball rolling? All above my pay grade – handing over.
Toot - toot
Quandary - Night VMC – Unresolved.
The accident report – HERE – (page 9 on) and the Safety Recommendation – HERE – clearly identify the horns of a dilemma onto which any honest safety authority would hate to be tossed. The operation of aircraft at Night in Visual Meteorological Conditions (NVMC), is a not only curly, dangerous area, fraught with legal peril – for the authority but for aircraft operators as well. Several serious attempts have been made to iron out the kinks, without impinging on the latitude the notion provides; it presents a problem with which one could find some sympathy for the authority dealing. You can, very quickly find much comment related to the subject and many a good argument for both sides.
What you cannot find (I cannot find) is an analysis – by operational class of the fatal accidents which occurred after dark. The ATSB have provided a graph which aligns ‘private’ operations against fatal accident by hours operated, which is fine – if a little dramatic. The ‘private ‘kill ratio’ is compared to Airline operations and Charter operations. This – IMO – provides a slightly skewed picture, not by any means deceptive when carefully read, but IMO (again) it fails to isolate and define a true picture of the seemingly high death rate in ‘private’ operations. This I believe is unhelpful when trying to establish a true picture and a safety case.
There are two basic tenets which demand that legislatively there must be a facility which allows visual flight at night; pilot training being one; the freedom to make a visual approach to landing after dark being another; which saves vast sums of money for commercial operations, and the ability for a Visual Flight Rules (VFR) operator to complete a task after daylight ends. All of which, in principal is a fine idea which could be fully supported, without a worrying aftertaste. It is a safe, practical and very valuable allowance. So where does the wheel come off?
“On a Gin clear night” after a while in the cockpit, you can actually see the features on the ground quite clearly, towns normally unseen can be identified by their loom, lakes and rivers seem to glow in the dark; with just a little moonlight the picture becomes almost perfect. The other side of the coin ain’t such an idyll. There is an expression ‘black-hole approach’, the RFDS probably know more about this than any operator on the planet. A dark night, middle of nowhere, rudimentary runway lights and no guidance other than the compass and your watch. It is bloody tricky stuff, not taken lightly by those who are regularly confronted by such conditions, it takes training and practice (lots of) to become proficient – if not comfortable.
And it is the ‘comfort level’ I am rambling towards. At very best there must be compromise which increases the risk level for government, operators and aircrew. The simple solution is to ban the concept, make any flight after dark subject to the Instrument Flight Rules (IFR) while keeping ‘visual approach’ in the mix. Then one could consider providing clearly defined rules which prohibited night flight under certain conditions; which is fine provided those conditions can be measured and met and argued about, later in court.
I confess to not having bothered to read the Part 61 rule set relating to the matter; (a) it is impossible (b) I have no need to – mea culpa. (Bite me). But a separate rating system could be developed, based against operational requirements could be hammered out, not that it would please all – but there is a need to find a level of comfort for all. For instance; the amount of ‘instrument flying training’ required could be matched to the stated operational requirement – say return to a town base within 60 minutes after the End of Daylight (EoD); or departing a bush strip after EoD with more than a 90 minute flight to destination etc. The details are endless, but a systematic approach could/should be evolved. We do loose aircraft and lives in the dark skies when the weather is being unhelpful, that is a stark undeniable fact. Another fact is that pilots will push on without having a key to the backdoor on their shirt pocket – that is human nature and cannot be controlled by regulation. This is particularly true of the modern age where ‘navigation’ is done by GPS and auto pilots work. The problem with this fine innovative technology is those aids cannot think, but they do lend a false sense of security.
End of ramble I think – for mine, I’d like to see the NVMC rating ‘beefed up’ and at least an annual check ride, without auto pilot or GPS. I know ‘old school’ methodology but a vast improvement is ‘situational awareness’ – IMO. As said, a puzzle for the regulator to solve, but solve it they must. Shutting down Angel Flight will not achieve this goal.
Phew, a long winded ramble, but I do feel the very real, chronic 'problem’ is worthy of serious discussion and positive action. Perhaps AOPA or AF could present a proposed solution to start the ball rolling? All above my pay grade – handing over.
Toot - toot