AA5342 mishap investigation
| Dear NTSB Investigators: Important points related to AA 5342 mishap investigation: 1. From the time the CRJ flight crew was assigned and accepted the River Visual Approach to RW 01, and later cleared and accepted the Circling to RW 31 clearance, there is a procedural question as to whether the FAA ATC at that point in time considered the flight to be still operating under FAR IFR rules, since it was cleared for a visual approach, meaning operate under VFR. Doesn’t this mean that the Reagan Local Controller no longer had to adhere to ATC IFR separation and handling responsibilities, or even control authority over AA Flight 5342 for separation from other VFR traffic? Didn’t that change in clearance from IFR to VFR shift AA5342 to VFR procedures? Therefore, were not all of the 60 passengers on board AA5342 from that point on a VFR flight rules flight, now being operated legally under FAR ATC See & Avoid Procedures for separation? Didn’t this mean that full accountability for acft separation shift 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. Doesn’t this also mean 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? Doesn’t this essentially mean 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. Doesn’t this therefore mean that the published VFR Helo Routes and the published River Visual Circling RW 31 VFR Route procedures lead acft in Reagan Class B airspace directly into a conflict at a point off of the end of RW 31, and to exactly where the mishap occurred? Isn’t it true that this procedure leads traffic to a conflict point under VFR rules, both daytime and or at night? 4. Doesn’t this mean that if FAA ATC clears two acft onto these two conflicting, published VFR routes, wherein each acft having VFR authority, that 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 may be of special interest, but is it 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, isn’t acft traffic separation between helos on the low altitude Helo Routes around Reagan, and commercial passenger acft cleared for the VFR River Arrival circling for any runway, no longer to be considered de-conflicted by altitude separation, because they are both authorized to be at 200′? If items 1-5 are in fact true that the current procedures do not provide adequate vertical separation, shouldn’t FAA ATC now create written procedures to separate acft on all of these routes by distances horizontally? Further, isn’t it prudent that FAA ATC 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 commercial passenger airline flights? Is it fair to the traveling public to subject them to VFR See & Avoid at Reagan on a FAR Part 121 operation, when other VFR military aircraft are given clearance into the same airspace and altitude? 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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