The Air Passenger Safety Group
Transport 2000 Canada
Suite 100 - 117 Sparks Street
P..O. Box 858, Station B
Ottawa, Ontario KIP 5P9

Wednesday, 30 June 1999


The Honourable Benoit Bouchard, P.C.
Chairman
Transportation Safety Board of Canada
200 Promenade du Portage
4th Floor
HulI,QC KIA 1K8


Re: Suggested Aviation Safety Improvements:
      Reporting of Statistics and Emergency Response Services


Dear Mr. Bouchard:

On behalf of the Air Passenger Safety Group, I respectfully submit the
following two recommendations aimed at further improving aviation safety in
Canada:

              99-01 That the Transportation Safety Board of Canada measure
the accident rate using the number of aircraft accidents and fatal aircraft
accidents on the basis of 100,000 or 1,000,000 departures, versus the
current use of per 100,000 flight hours.

              99-02 That the Transportation Safety Board of Canada reach an
agreement with Transport Canada on how Moshansky Commission Recommendation
3l is to be implemented. MCR 31 reads: That whenever a crash fire fighting
and rescue (CFR) unit responds to an aircraft crash, Transport Canada, as
part of its post crash response, objectively review and analyze the actions
of the CRF unit forthwith, in order that deficiencies in CFR response can be
corrected and useful information on both positive and negative aspects of
the response may be passed onto other CFR units.

RATIONALE:

1. 99-01 Aircraft Accident Statistics

One of the primary objectives of aviation safety statistics is to determine
trends in aviation safety. An annual capture of the accident rate provides
part of this comparison. Naturally, the denominator over which the measurement
is made is of critical importance. The TSBC and other investigative agencies around
the world have traditionally used the number of aircraft accidents (fatal or
total) over a metric based on flight time, such as per 100,000 hours. While
this approach has enjoyed wide acceptance in the past, there is good reason
to instead consider the number of accidents (fatal and total) per number of
departures. This would be more representative of aviation safety, because
people take a flight consisting of one or more equal number of take-offs and
landings, rather than going for a flight of x hours. The present hourly
metric unduly penalizes short haul flights and correspondingly gives an
undeserved benefit to long-haul flights. We note, in a study prepared by
GRA, Incorporated for the FAAs Office of System Safety, that Professors
Arnold Barnett and Clinton V. Oster, both internationally recognized experts
on aviation safety statistics, state that "most researchers prefer to use
the number of flights (measured as departures) for normalizing data rather
than hours or miles flown, because the risk of accident for an aircraft is
greatest during take-off or landing."1

We would also like to draw your attention to statistics compiled by Mr. Sy
Levine and reported in the 17 May 1999 issue of Air Safety Week. Mr. Levine
suggests that on a mileage basis, death by air travel is 6 times more likely
than by bus and almost twice as likely as by car. We have not yet been able
to independently verify Mr. Levine s work, but, if true, this figure
represents a major challenge to the aviation community. Thus, in addition to
using the aforementioned departure-based metric, the TSB might wish to
consider adopting a common measurement system that allows the comparison of
safety performance across the various transportation modes.


2.  99-02 Investigation of Emergency Response Services

Although legal definitions say that a flight  ends with the aircraft coming
to a stop, from a passenger's perspective, a flight only ends when he or she
can safely exit the aircraft. In an emergency, the egress of passengers can
depend heavily on the rapid and effective provision of Rescue and Fire
Fighting services.

You will recall that during their two landmark Inquiries, both Commissioners
Charles L. Dubin and Virgil P. Moshansky spoke to the importance of what is
known internationally as Rescue Fire-Fighting. In 1982, Mr. Justice Dubin,
stated, "Emergency Services personnel are an integral part of the overall
safety system. "Ten years later, Mr. Justice Moshansky, emphasized 'The need
to recognize [emergency services ] importance as part of the overall safety
net at airports where carriers operate on a frequent and regular basis."

A Report on Issues Related to Public Interest in Aviation Safety Data,
dated January 20,1997, GRA, Incorporated, pp. 5-6
Commissions made numerous observations and recommendations to this effect.
Indeed, Moshansky Commission Recommendation 31 reads: That whenever a crash
fire fighting and rescue (CFR) unit responds to an aircraft crash, Transport
Canada, as part of its post crash response, objectively review and analyze
the action s of the CRF unit forthwith, in order that deficiencies in CFR
response can be corrected and useful information on both positive and
negative aspects of the response may be passed onto other CFR units.

Whether by policy, omission or a lack of resources, Transport Canada is not
reviewing ERS performance in aircraft accidents, as called for by MCR 31.
This means the considerable value of this insightful recommendation that
accrues to fire-halls across the country and indeed around the world is
being lost. APSG firmly supports MCR 31 and requests that it be implemented
immediately, either by TSB or TC. This MCR is all the more needed, due to
certain weaknesses, not only in Canadian ERS regulations (CAR 303), but also
by weaknesses in ERS units at both designated and non-designated airports
across Canada.

Although the sequence and causes of aircraft accidents are analyzed in
commendable detail, APSG is concerned that much less effort is directed to
investigating ERS performance even though ERS is "an integral part of the
overall safety system." We note that NTSB Chairman Jim Hall has made
numerous pronouncements on the need for more aggressive aircraft Rescue and
Fire-Fighting services in the last two years, in light of the United Express
accident at Quincy, Illinois and the FedEx accident at Newburgh, NJ. We
further note the detail into which accident the US NTSB and UK AAIB have
addressed ARFF issues, especially the Manchester and Kegworth 737 accidents,
promoting considerable learning and improved ARFF practices around the
world.

Given the relative infrequency of catastrophic ERS events, a thorough and
objective investigation of each is important and their public dissemination
performs a valuable worldwide service. With divestiture of airports in
Canada, not only has Transport Canada retreated from its MCR
responsibilities in this area, but a new set of problems has been created:
investigations conducted by the airport will understandably be less
objective than those done by TC or TSB since there is very little incentive
for the airport to investigate and report that it may be in non-compliance
with CAR 303, since to do so would be to expose itself to monetary penalty
or loss of their airport certificate.

The travelling public has also lost the ability to obtain safety information
they need to make informed choices, as ATIP legislation does not apply to
divested airports. Passengers are being told that commercialization of
airports will only serve their interests and that market forces are superior
to public policy. However, passengers are less able to obtain information
needed to make informed choices, one of the key assumptions in market
theory. This would leave regulatory authorities open to future criticism of
having failed in its primary responsibility to the traveling public. Only the
documented and publicly accessible investigation by TC or TSB can correct
this pernicious Catch -22 situation. The APSG thus looks to the TSB or TC
to provide the same degree of high caliber investigation to events surrounding ERS
as it does with the aircraft accident itself.

We note with appreciation that the recent TSB report on the Air Canada RJ
accident at Fredericton addressed ERS, but feel obliged to comment that it
did not address issues such as:

     . The fact that the aircraft was outside the critical rescue and
fire-fighting access area (CRFAA)
. The degree to which access roads within the CFFRAA were available
. The off-road capability of the ERS vehicles at the Fredericton airport
. The advantage of having trained snow blower operators and equipment to
provide egress to ERS vehicles in the winter and heavy equipment operators
and a bulldozer during the summer.
. The need for ERS vehicles to have VHF-DF capability with which to detect
ELT-equipped aircraft in low visibility conditions.
. The need for airport ERS vehicles to have the extraction equipment and the
trained staff to operate it.

Although not a part of this recommendation, as you know from previous
correspondence, Canadian ERS regulations fall short of international
standards in several areas, notably in the tack of rescue capability,
response times and remission standards. The APSG has taken an active
interest in correcting these deficiencies and is, to this end, convening a
public symposium in Ottawa on 19 August 1999 to put this issue, before the
traveling public. Naturally, you and your staff are most welcome at this
event. I attach information to this effect.

Should you or your officials require any further elaboration of these two
recommendations, please contact me at my own office (613) 829-0602 or that
of my vice chair, James T. Lyon, QC, at (613) 730-1504.

Sincerely,





Michael Murphy

Chairman