AA5342 mishap investigation
| Dear NTSB Investigators: Important points related to AA 5342 mishap investigation: 1. From the time the CRJ flight crew accepted and was assigned the River visual Approach to RW 1, and later Circling to RW 31, FAA ATC no longer considered the flight to be operating under FAR IFR rules, meaning that the Reagan Local Controller no longer had ATC IFR separation and handling responsibilities, or authority over AA Flight 5342 for separation. That shifted then to VFR procedures. Therefore, all of the 60 passengers on board AA5342 were on a VFR flight rules flight, now being operated legally under FAR ATC See & Avoid Procedures for separation. This means that full accountability for acft separation shifted from FAA ATC Reagan Local to the two PSA CRJ flight crew members, as PF and PM, as soon as they were assigned and accepted the visual. 2. This also means that the AA 5342 flight crew, under VFR were pretty much cleared to operate at any altitude within the Reagan Class B airspace, so as to arrive at, and land on RW 31. This essentially means that they were cleared to fly safely from the floor of Class B airspace, i.e. below 300 feet or even at 200 feet, to the airspace ceiling, as needed even up to 5000 feet at their discretion. 3. This therefore means that the published VFR Helo Routes and the River Visual Circling RW 31VFR route lead acft in Reagan Class B airspace directly to a conflict point, off the end of RW 31, and to exactly where the mishap occurred, and leads them there under VFR rules, day or night. 4. This means that if FAA ATC clears two acft onto these two conflicting, and published VFR routes, wherein each acft having VFR authority, each acft could fly at 200′ and/or cross that point to be at 200′ . The fact that the H-60 helo was 100 ft high at 325ft is of special interest, but not controlling as a cause of the mishap, because AA 5342 was authorized to be at 200′ by virtue of VFR rules, which is the max altitude for the Helo Route, and could have just as easily hit the helo at 200 feet. 5. Therefore, acft separation between helos on the low altitude Helo Routes around Reagan, and acft cleared for the VFR River Arrival circling any runway, can no longer be considered de-conflicted by altitude separation, because they are both authorized to be at 200′. 6. Instead, FAA ATC must now create written procedures to separate acft on all of these routes by distances horizontally. Further, FAA ATC must not relinquish control under VFR, to flight crew using See & Avoid Procedures, when the lives of as many as 250 or more passengers may be riding on arriving scheduled airline flights. 7. I just do not think it is fair to the traveling public to subject them to VFR See & Avoid at Reagan on a FAR Part 121 operation, in my opinion, when other VFR aircraft are given clearance into the same airspace and altitude. 8. I further believe that ALPA Safety should advocate that all DOD acft operating in Class B airspaces, such as at DCA, where See & Avoid Procedures are regularly assigned by FAA ATC, should be equipped with, and be required to operate on VHF ATC radio bands, to raise Situational Awareness for all flights operating in that Class B airspace. Again, the safety of the public is at stake and these additional radios are not very expensive. I’d be happy to hear back. $afetyPay$ Captain Paul Miller, retired SafetyForecast.com |
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