Aviation safety issues and actions

Angel Flight Australia consideration of commercial flights

Issue number: AO-2017-069-SI-01
Who it affects: All passengers on community service flights conducted by Angel Flight Australia
Issue owner: Angel Flight Australia
Transport function: Aviation: General aviation
Background: Investigation Report AO-2017-069
Issue release date: 13 August 2019
Current issue status: Safety action pending

Safety issue description

Angel Flight did not consider the safety benefits of commercial passenger flights when suitable flights were available.

Response to safety issue from Angel Flight: Angel Flight consider it inappropriate for [the ATSB] to criticise the charity for not abandoning the model for which it was constituted. Angel Flight only consider the use of regular passenger transport in two circumstances: if a private pilot is unavailable or cancels at short notice and flights are available, or if the flights are capital city to capital city. They are not, and are not required to be, considered other than as a back-up and for long distance compassionate flights.

ATSB comment: The ATSB acknowledges that Angel Flight uses commercial passenger transport for some flights it organises. This ATSB investigation showed that commercial passenger flight options are available for a considerable percentage of the private flights organised by Angel Flight. As a charity established to transport people without the means to medical appointments, the ATSB considers that Angel Flight could and should include the fact that commercial passenger flights have a lower safety risk to passengers than private operations as a factor when it is organising flights.

The ATSB is issuing the following recommendation.

Recommendation

Action number: AO-2017-069-SR-015
Action organisation: Angel Flight Australia
Date: 13 August 2019
Action status: Monitor

The Australian Transport Safety Bureau recommends that Angel Flight Australia takes action to enable it to consider the safety benefits of using commercial flights where they are available to transport its passengers.

Additional correspondence

Response date: 29 September 2019
Response from: Angel Flight
Action status: Monitor
Response text:

Angel Flight has considered the recommendation carefully and has determined that it maintain its current policy of giving priority to using private flights where possible and to continue to use regular public transport flights when private flights are cancelled or unavailable, and for transfers between capital cities.

The reasons for our decisions are:

Angel Flight rejects the claim in the ATSB report that, for Angel Flight passenger carrying flights, the “fatal accident rate was more than seven times higher per flight than other private flights” as invalid.

A valid analysis addressing passenger risks would require comparison of passenger carrying Angel Flights and other passenger carrying private flights. Since no such data are available for other private operations, the only reasonable comparison is between all Angel Flight operations and all other private operations. Even then, results must be treated cautiously because an unknown proportion of private operations involve circuit training and short local flying whereas all Angel Flight operations involve flights with an average sector length of 1.5 hours.

The analysis in Table B2 on page 69 shows that, when all Angel Flight sectors are included, the fatal accident rates are 0.5 and 0.2 per 10,000 flights for Angel Flight and other private flights respectively, and the difference is not significant. Furthermore, when all accidents are included, the rates are 1.1 and 1.5 per 10,000 flights for Angel Flight and other private flights respectively.

Angel Flight rejects the claim in the ATSB report that “community service flights conducted on behalf of Angel Flight Australia (Angel Flight) had substantially more occurrences …… per flight than other private operations” as invalid.

ATSB has compared Angel Flight operations, approximately 95% of which operate to and from Class C and D airspace with other private operations where an unknown, but undoubtedly much lower, proportion of flights are in controlled airspace. Angel Flight has been unable to find any data that would permit a valid comparison of similar operations for other private flights.

The ATSB report acknowledges, in the Safety Summary, that “The types of occurrences where flights organised by Angel Flight were statistically overrepresented (as a rate per flight) compared to other private operations were consistent with these operational differences.” However, the report then immediately ignores the vastly different operating environments and claims that the difference “indicated an elevated and different risk profile in Angel Flight”.

ATSB comment:

ATSB letter to Angel Flight to reconsider their response

Thank you for your response to the above ATSB safety recommendation. The response, received via email on 29 September, indicated that the recommendation had been considered and rejected, and that Angel Flight Australia had determined that the current policy would be maintained. The ATSB Commission have considered this response, and would like to provide you a further opportunity to consider your response.

The reasons outlined for the decision by Angel Flight to maintain its current policy of giving priority to private flights where possible do not address the evidence on which the recommendation was made.

As outlined in the final investigation report, that evidence centred on that commercial passenger flights have an established lower safety risk for passengers than private operations. The reasons stated in your response only addressed your disagreement with other evidence in the ATSB final report concerning the relative safety of Angel Flights and other private operations.

The ATSB Commission believes that Angel Flight should firstly consider the safety of Angel Flight passengers. Regional and rural people should not be exposed to unnecessary levels of risk as a passenger on a private community service flight, and as such, Angel Flight should consider the safer option as the primary option, where available, before considering private operations.

The ATSB Commission is therefore asking you to reconsider your response to the safety recommendation.

The ATSB investigation showed that commercial passenger flight options are available for a considerable percentage of the private flights organised by Angel Flight. As a charity established to transport people without the means to medical appointments, the ATSB considers that Angel Flight could and should include the fact that commercial passenger flights have a lower safety risk to passengers than private operations as a factor when they are organising flights.The ATSB acknowledges that there will be passengers who cannot travel on regular public transport, and that there are times and locations where it is not available or suitable. However, in the case of the accident flight, no consideration was given to the safety benefits of using the available RPT, nor were the comparative costs considered. It is unlikely that any of the considerations previously outlined by Angel Flight (cost, passenger needs, flight locations and timing) would have prevented the use of a commercial flight.

In accordance with our protocols, we will publish the received response and Angel Flight’s position on the safety recommendation. However, prior to publication, I am offering you a further opportunity to reconsider the safety recommendation.

Please do not hesitate to contact me if you would like to discuss this response to the safety recommendation.

In closing, please allow me to reiterate that the ATSB considers the conduct of community service flights demonstrates selfless concern for others less fortunate requiring medical treatment from regional and rural Australia. It is our purpose however, to improve transport safety. The ATSB continues to encourage the consideration of the safety benefits of using commercial flights where they are available.

Response date: 05 November 2019
Response from: Angel Flight
Action status: Monitor
Response text:

Angel Flight advised that further response would be considered at the next board meeting, and additional comments would be provided.

Response date: 26 November 2019
Response from: Angel Flight
Action status: Monitor
Response text:

We have had a major board change last week, with the retirement of our Founder and one other director, and the appointment of two new Directors, with the first AGM comprising additional company members to occur 3 December. The new board has yet to have its first formal meeting.

However, we have this week determined that it would be in the interests of the ATSB, Angel Flight, and rural communities if Mr Hood would meet with us at the Angel Flight headquarters, in order that he may familiarise himself personally with our charity, its people, and the processes by which disadvantaged rural Australians are assisted.

We envisage this occurring before a formal response is given.

ATSB comment:

The ATSB Commission acknowledged the invitation to Angel Flight facilities, and are liaising with Angel Flight to coordinate a visit to coincide with a board meeting to further discuss the recommendation.

Last update 11 December 2019