Communications Advice

Widow · Post by **Widow** » Sat Jan 20, 2007 12:53 pm

I think most of you would agree that there are a lot of problems with communications/emergency notification on the West Coast.

Because of what has happened to me (http://www3.telus.net/public/t9232724/home) and my subsequent efforts to get the rules changes. Merlin Preuss has stated :

The Type D operational control requirements are intentionally permissive in recognition of the realities that limit communication in some areas of the country. CAR 723.16 dealing with Type D Operational Control does not require the pilot and the operator to be in constant communication with each other, either directly or indirectly through a third party. The regulation requires aircraft equipment that permits a pilot to communicate. It does not require that the pilot-in-command be capable of communicating with a ground station at all times. Such a regulation would seriously hamper aviation operations wherever line-of-sight VHF communications are not possible. The accident aircraft was equipped with a serviceable VHF onboard radio plus an operating cell phone (thereby satisfying CAR 723.16(1)(d)). He makes it clear that he believes it is OK for a commercial operator to be dispatching without a radio.

Now, I happen to think that because of "the realities that limit communication in some areas of the country", regulations (or the interpretation and enforcement of existing CARs) should be more stringent, instead of "intentionally permissive ".

The CARs read

"Each aircraft shall be equipped with serviceable and functioning communications equipment that permits the pilot-in-command to communicate with a ground radio station for the purpose of flight following with the air operator. Such a ground station may be operated by the government, the air operator or a private agency."

How can that possibly be interpreted to mean the air operator, if it is not using a government or private agency for the purpose of flight following, does not require a ground radio station?

When you add to this the known problems with existing regulated ELT's, then you get a disaster like we had. A plane can emergency crash-land five miles from home, everyone survive the crash - but nobody get rescued.

I know that most commercial operators care, and knowing the limitations of communications, voluntarily do extra things to improve safety (like more advanced ELT, subscribing to BCFS, fifteen minute contact, etc., etc.). I believe that enforcing this would "weed out the marginal operators" (to quote xsbank on another thread).

Comments and suggestions please.

cloudcounter · Post by **cloudcounter** » Sat Jan 20, 2007 1:29 pm

Hi Widow
I think the problem is not too many poo bahs ride the bush planes

So if it's their blood it will change pronto-ie priority improvement relative to personal concerns cause change.
.02
Now if the heads of NASA had been riding Columbia..
cc
Luk 13:4 Or those eighteen on whom the tower in Siloam fell and killed them, do you think that they were sinners above all men who lived in Jerusalem?
Luk 13:5 I tell you, No. But unless you repent, you will all likewise perish.

JL · Post by JL » Sat Jan 20, 2007 9:59 pm

A possible technological answer is automated flight following...

http://www.for.gov.bc.ca/protect/AFF/faq.htm

twotter · Post by **twotter** » Sun Jan 21, 2007 3:02 am

Now that sounds like a hell of an idea... Why don't most of us know about it??? Why aren't the manufacturers sales people out talking to us pilots out here on the coast?? Yes, it will cost money, but in the end, am I worth it?? I hope so..

Driving Rain · Post by **Driving Rain** » Sun Jan 21, 2007 4:18 am

http://www.satwest.com/Aircraft_Tracking_AFF_s/2.htm

These have been avaikable for years and are relatively inexpencive. We have something like this on all our aircraft.

Widow · Post by **Widow** » Tue Jan 23, 2007 8:54 am

Anybody disagree that a 15 minute check-in should be a min requirement for 703's in hazardous weather/communications areas?

Anybody disagree that if not using another agency, a 703 operator should have it's own radio in the dispatch office for "flight-following"?

Driving Rain · Post by **Driving Rain** » Tue Jan 23, 2007 9:30 am

Widow wrote:Anybody disagree that a 15 minute check-in should be a min requirement for 703's in hazardous weather/communications areas?

Anybody disagree that if not using another agency, a 703 operator should have it's own radio in the dispatch office for "flight-following"?

Widow, we use a 30 minute check-in. Admittedly 30 minutes is a long time even in a Beaver that could travel 50 miles in that time and 25 with a 15 minute check-in.
I've never worked for an operator that didn't have a VHF radio but the station outputs were so low and reception range so limited as to be almost next to useless. HF radio has much greater range but is sometimes spotty do to a variety of reasons.

If TC would get off it's butt and mandate the use of GPS trackers for these type of operations it would save them and everyone else a lot of time & money. For the price of a couple of charters these systems would pay the operators back in no time with the ability to make last minute changes to routes and receive reliable wx advisories.
If you read the features these units have, you get not only reliable 2 way communication but really what amounts to is a poor mans Black Box with telemetry sent to a PC for later and real time analysis. These features alone could have answered some of your questions in this tragedy or at least pointed the investigation in a more conclusive direction(s).

Brewguy · Post by **Brewguy** » Tue Jan 23, 2007 9:45 am

Widow: unfortunately you are falling into what I call "Ontario syndrome" ... that is, looking at things only from a regional perspective. Of course, flying in coastal / mountainous areas of BC will have its unique challenges. However, changing the requirements in the CARs makes those rules applicable to the whole country. In which case, I would not agree with the specific changes you're suggesting (as related to flight following and communications).

Widow wrote:Anybody disagree that a 15 minute check-in should be a min requirement for 703's in hazardous weather/communications areas?

Yes, I disagree. 15 minutes seems overkill to me; and who would be the one to define "hazardous"?

Widow wrote:Anybody disagree that if not using another agency, a 703 operator should have it's own radio in the dispatch office for "flight-following"?

What difference would their own radio make? ...please read on:

Let me give you an example that will illustrate the difficulties of both points mentioned above. For many years, I have been involved in CASARA (Civil Air Search and Rescue) here in Niagara. For a time, back when I was more involved in it, I was the units communications officer. When we are on an actual SAR or participating in training or SAREXs, our SOP is a 1 hour "Ops Normal" call - that is to say each crew must contact the HQ every hour to report that everything is ok.

Now, please remember that I am here in 'flat land' Ontario...... Our CASARA unit has base station radios, with an antenna on the biggest tower they will allow us to have on the airport. Air crews that are out in a search area (normally a 30 - 45 minute flight away from base for most exercises), operating at search altitudes cannot communicate with us via radio. We have a FSS on the field, and the a/c will often have to break off from the search, and climb to a significantly higher altitude to even reach the FSS (who relay the message to us).

So, imagine if you will that we are a 703 operator instead of a CASARA unit, operating the same light aircraft. We have the base station radio as you suggest ... but what difference does that make? We still can't reach an a/c that's less than an hours flight away - flying over (relatively) flat terrain. The local FSS can't even reach them with their more powerful radios. In fact, there have been some instances when climbing to altitude didn't help in reaching St. Catharines FSS - when operating near Hamilton we've had to relay the Ops Normal through Hamilton to St. Catharines to our Ops building.

If you really want to make a difference here - push for the newer 406 ELTs to become mandatory. That would do far more to speed up SAR than any amount of changes to the flight following would. But to abandon type D flight following in favour of something more restrictive would mean significant hardships for many small (1 plane, 1 pilot) operators across the country. Type D works well, and is sufficient, for a great many small 702/703 operators in this country.

Ok, now here is the flip side of things... you've recently been questioning SMS, right? Well, one of the key concepts of a proper SMS system, is that "one size DOES NOT fit all". An SMS system is supposed to be specific to the operator, and is based on their size, type of operations, etc. Effective emergency communications is certainly something that could fall under that system. i.e. a lack of communications being identified as a potential hazard.

I would suggest that the addition of satellite tracking or FM communications, or whatever else has been suggested here would be best implemented for coastal / mountainous float operators, through their SMS. But please don't suggest that it should be mandatory for all 703 operators in Canada. Please remember that regulatory changes have a national affect, and are not specific to one region.

Edit: Here is our set-up. The tower you see behind the building goes up another 2 sections (white & orange - I believe each is 8 feet), with the aviation band VHF antenna at the top. ...which is probably more than a lot of commercial operators have. Too bad it still isn't of much use!

angry inch · Post by **angry inch** » Tue Jan 23, 2007 10:14 am

One of the operators on N. Van Is is using a GPS tracking system... Surely, you know 'em Twotter... He's got quite a rep, but also has some damn good ideas...

Every 15 mins... I dunno... I like the idea of less radio work (GPS Tracking) rather than more... especially when the WX is shit & a guy needs to be focussed, not distracted...

Eg... Busy fire season... Forestry repeaters are smokin' busy... everybody's talkin'.... marginal VFR... getting close to busy airport... lots of a/c... talkin', lookin...
Might sound ridiculous that a simple radio call could be much of a distraction...
Neilblythin, You've got it!

Aviate, Navigate, Communicate...........

mellow_pilot · Post by **mellow_pilot** » Tue Jan 23, 2007 10:56 am

I don't want to belittle anyone in anyway here, but might I suggest we take a step back and look at this in another light? I don't want to start an argument. I hope this will be read as it is intended, a different point of view in an open and constructive discussion.

My Step-Mom won't drive outside of town without a cellphone, just incase. Now I'm pretty sure she's been driving since before cellphones, so my question is, what the hell did she do before? Not drive? Now I realise that having the capability to call someone in an emergency is a good thing. Why not have the extra security, but what if you can't afford a cellphone? I know they're relatively inexpensive, but there are people who truly can't afford it. Further, I work at a ski resort in the mountains. I can't get cell reception on most of the mountain. Hell, even driving the highway up to the mountain is patchy. Does this mean I refuse to work there? No. It is dangerous, at the time I'm going up and down the mountain, if I went off the road, no one would be likely to see me. It means I drive carefully, and when the roads are bad, I use chains. I don't drive too fast for the conditions, and I leave early if it's snowing. I may not be able to contact anyone, so I make sure that the odds are in my favour and don't take chances, because I know I can't call anyone for help.

If we just extrapolate this to aviation a little bit here, I completely understand the government postition that communication just isn't possible in certain areas. Not everyone can afford a sat-phone. I don't know how many times I've relayed position reports for aircraft that were out of comms range, and that was in Ontario and Quebec! I'm sure many of you have done the same. Were I (or the rest of you) not flying around at that time, the aircraft we relayed for would not have gotten through, I'm sure it happens all the time. In fact, it's happened to me.

Don't get me wrong, if there is an affordable technology that can track remote flights, I'm all for it. I think it's better to take your cellphone, just incase, but if I forget it at home, I don't turn around and cx the trip.

What happens if the tracker goes offline? Does it become a MEL issue? Do we not fly if the tracker is U/S? Do we stop driving because our cellphone lost reception?

Again, I'm not saying the trackers are a bad idea. I'm just providing an alternative point of view.

Widow · Post by **Widow** » Tue Jan 23, 2007 12:14 pm

neilblythin wrote:
Widow wrote:Anybody disagree that if not using another agency, a 703 operator should have it's own radio in the dispatch office for "flight-following"?
What difference would their own radio make?

Maybe it wouldn't make a difference. Maybe it would ... no way to know unless actually in that emergency situation. But how can anyone say that it isn't a necessity. How are they supposed to be doing their "flight-following" or check-ins? With cell phones? Aren't they illegal except for emergencies?

I do take the point that the ELT/GPS is the reg that needs to be changed in order to help eliminate a lot of related problems. That seems to be agreed upon by everybody.

Driving Rain · Post by **Driving Rain** » Tue Jan 23, 2007 12:39 pm

With cell phones? Aren't they illegal except for emergencies?

Not sure of the law here widow but it's one of those unenforceable rules. If your in a light plane in flight & using a cell phone it would be just about impossible as it stands now to catch someone. I've tried using mine in flight but the ambient noise from the engines make them just useless unless you have some special patch cords.
As for being able to afford the equipment ... complete hog wash. There is no excuse for not have GPS tracking capibility in commercially registered aircraft.
I don't see why the insurance companies haven't pushed this on the operators. A slight reduction in premiums would be all the shove this would need. The regulator has really dropped the ball on this
Transport Canada has pushed this idea in the trucking industry for years now.

Brewguy · Post by **Brewguy** » Tue Jan 23, 2007 1:36 pm

Driving Rain wrote:...There is no excuse for not have GPS tracking capibility in commercially registered aircraft...

Sorry Driving Rain, but I couldn't disagree more.

Ok, maybe for a 704 operator (10+ pax, larger aircraft) it's justifiable ... perhaps even for some 703 operators in some circumstances. But for a 1 plane operator, flying charters in a 170 on floats (or some other 4 seater) around 'cottage country' Ontario? I'm sorry, but you simply cannot make such a blanket statement. Even a/c involved in 702 aerial work operations are "commercially registered". Are you saying some guy who uses his little R22 to do pipeline or powerline patrols (pilot only, no other crew or pax) still needs GPS tracking because his a/c is "commercial"?

As I wrote earlier, perhaps this type of tracking or comms system should be implemented for some operators; IF a lack of such a system is identified as a potential safety issue for their type of operation. The implementation of which should then be addressed as part of their SMS.

Specialty items that are suitable to your specific type of operation or area of operations should be addressed by your Ops Manual, SOPs, or SMS ... not added into the CARs. What may make sense for flying in the Rockies may be just another senseless regulation in other parts of the country.

Driving Rain · Post by **Driving Rain** » Tue Jan 23, 2007 4:23 pm

neilblythin wrote:
Driving Rain wrote:...There is no excuse for not have GPS tracking capibility in commercially registered aircraft...

Sorry Driving Rain, but I couldn't disagree more.
But for a 1 plane operator, flying charters in a 170 on floats (or some other 4 seater) around 'cottage country' Ontario? I'm sorry, but you simply cannot make such a blanket statement. Even a/c involved in 702 aerial work operations are "commercially registered". Are you saying some guy who uses his little R22 to do pipeline or powerline patrols (pilot only, no other crew or pax) still needs GPS tracking because his a/c is "commercial"?

Yes that's exactly what I'm saying. Private pilots are installing these systems in their aircraft. The piece of mind alone is worth it.
There is a thing in this industry that's called various things but I call it terminal cheap. For $4000 not only would seach and rescue find you right away if you go down but investigators would be able to monitor your intial track &airspeeds to come to a more complete hypothesis to what caused your crash.

In widows case were talking about a Beaver not an R22. Don't you think the passengers deserve the best and latest technology in the event of something like this. Guys like you are great at picking fly shit from pepper. An R22 is not a Beaver

chipmunk · Post by **chipmunk** » Tue Jan 23, 2007 4:39 pm

There are some cheaper alternatives starting to appear out there. Clunckdriver's got a portable sat tracking for his flight school's aircraft, in the $1600 range. He made a post about it a few weeks ago. in the "Letter to Mr Preuss" thread.

Donald · Post by **Donald** » Tue Jan 23, 2007 4:42 pm

Money talks. You say $4000 DR? Is this the price of the installation alone? What about the subscription/renewals? Maintenance of the system? What is the effectiveness above 70N? Iridium?

I'm all for improving the safety of operations, but will customers pay?

Cat Driver · Post by **Cat Driver** » Tue Jan 23, 2007 4:49 pm

This is a stupid fu.king discussion.

Hell I have a bunch of GPS stuff for my car and boat that is so accurate I can measure my dick with it, the problem is everyone has to get their heads out of their asses and install non aviation certified stuff in their airplanes and that will get rid of a lot of useless B.S. and make flying a lot safer.

There hows that for getting to the point.

Widow · Post by **Widow** » Tue Jan 23, 2007 4:49 pm

Donald wrote:I'm all for improving the safety of operations, but will customers pay?

If its regulated (because it makes them safer) what choice will they have?

Speaking as the widow of a passenger who used to say "no" when pilots were willing to fly, wore his floater coat and took underwater egress training, because safety was important to him, we would have happily paid more. The people who hired him and told him who to fly with, certainly could have afforded to pay.

Widow · Post by **Widow** » Tue Jan 23, 2007 4:58 pm

Cat Driver wrote:the problem is everyone has to get their heads out of their asses and install non aviation certified stuff in their airplanes and that will get rid of a lot of useless B.S. and make flying a lot safer.

There hows that for getting to the point.

here here Cat. or there there, i'm not sure.

But that is exactly what I don't get. Half the new cars coming out (may be an exaggeration, but you get my point) have gps systems pre-installed. The average joe logger carries a hand-held gps in case he gets lost in the bush. Heck, hikers carry them to keep themselves safe. What the heck is the big deal in regulating a commercial airplane to carry a gps/elt? With the clear potential to save so many lives, and help answer so many unsolved questions? I would think every pilot out there would be clammering for it. For your own safety. But if you are taking someone else's life into your hands, you are responsible to do everything possible to keep them as safe as possible.

Cat Driver · Post by **Cat Driver** » Tue Jan 23, 2007 5:09 pm

Widow:

The truth is there is no law that dictates you can not " carry " on board any electronic device your little heart desires....they are known as portable.

Lets not even start to discuss the "why" of why the regulator does not come out of the cave man era and use some common sense.....when you have an overpowering desire to try and understand the bureaucratic mindset of how TC works just pull out that letter from Merlin Preuss and there is proof positive that the " peter principle " trumps IQ in the world of government politics.

Cat

trey kule · Post by **trey kule** » Tue Jan 23, 2007 5:16 pm

The first sense I get of this is why do companies have to wait for it to be regulated. If it is a good idea, and makes things safer why not do it.
The good companies will. and the unethical sleazebags will simply fake the paperwork anyway. TC will get trounced on for failure to enforce another regulation.

So, instead of making this a regulator issue, why do not all the pilots flying in that area have a little safety chat with their companies. SMS and all that. Document the heck out of it. good companies will listen. Bad companies....well dust off the resume if they dont implement it.

It always suprises me that everyone who slags the continuing burden or more regulations and more paperwork so quickly will jump to demand the regulators make even more regulations. Seems like people just want to have someone other than the bad companies to blame.[/quote]

Widow · Post by **Widow** » Tue Jan 23, 2007 5:19 pm

In this case, the bad company would not have existed had the regulation been in place.

Brewguy · Post by **Brewguy** » Tue Jan 23, 2007 6:12 pm

What exactly is it that you want here Widow?
GPS, FM radios, Satellite phones, base station radios .... what exactly?

These GPS units you're talking about in cars and used by hikers do not transmit any data to anywhere. The ones used in the trucking industry operate via the cellular telephone networks - and are of no use in remote areas.

I'm sorry, but nothing said on this thread has made any real argument for why a real-time GPS tracking system, that transmits this data (via what, FM or satellite?) - should be mandated for all commercial aircraft in Canada. (as has been suggested by some - not necessarily you)

And then of course there's Cats suggestion that we all abandon aviation equipment in favour of the Canadian Tire / Radio Shack special?

Wow! .... while we're at it, why don't we start buying our maintenance supplies from Home Depot too. I'm sure if the TSB had found that "non aviation certified stuff" had been installed in the aircraft - Widow would be screaming blue murder at the government and industry for that too. Much of what you say makes sense to me ., and I have come to normally respect your opinions - but where did you come up with that one?

So, what do you want - and why should that be applicable to all operators, of every type, across the entire country?

As I've already suggested 406 Mhz ELTs should be made mandatory, and sooner rather than later. As someone who has been involved in SAR, I'd agree with that 100% They do couple with a GPS and transmit all of the necessary data to SAR in the event of an accident. That would solve many of these issues here. But all I've heard so far are suggestions that may have helped in this one particular situation, in this one region.

And once again, since nobody seems to be understanding this, let me repeat: IF alternate comms systems (i.e. FM or satellite phones, etc.) make sense for a particular type of operation (i.e. coastal, mountainous, remote, sparsely settled areas, etc.) ... THEN OF COURSE they should be used by the operators in those circumstances. This is best done through that operators SMS, if a lack of that type of communications system represents a safety concern. But would you BC mountain people please stop making blanket statements about what should be mandatory for all operators across the entire country.

Widow · Post by **Widow** » Tue Jan 23, 2007 6:34 pm

neilblythin wrote:What exactly is it that you want here Widow?
GPS, FM radios, Satellite phones, base station radios .... what exactly?

These GPS units you're talking about in cars and used by hikers do not transmit any data to anywhere. The ones used in the trucking industry operate via the cellular telephone networks - and are of no use in remote areas.

I'm sorry, but nothing said on this thread has made any real argument for why a real-time GPS tracking system, that transmits this data (via what, FM or satellite?) - should be mandated for all commercial aircraft in Canada. (as has been suggested by some - not necessarily you)

And then of course there's Cats suggestion that we all abandon aviation equipment in favour of the Canadian Tire / Radio Shack special?
Wow! .... while we're at it, why don't we start buying our maintenance supplies from Home Depot too. I'm sure if the TSB had found that "non aviation certified stuff" had been installed in the aircraft - Widow would be screaming blue murder at the government and industry for that too. Much of what you say makes sense to me ., and I have come to normally respect your opinions - but where did you come up with that one?

So, what do you want - and why should that be applicable to all operators, of every type, across the entire country?

As I've already suggested 406 Mhz ELTs should be made mandatory, and sooner rather than later. As someone who has been involved in SAR, I'd agree with that 100% They do couple with a GPS and transmit all of the necessary data to SAR in the event of an accident. That would solve many of these issues here. But all I've heard so far are suggestions that may have helped in this one particular situation, in this one region.

And once again, since nobody seems to be understanding this, let me repeat: IF alternate comms systems (i.e. FM or satellite phones, etc.) make sense for a particular type of operation (i.e. coastal, mountainous, remote, sparsely settled areas, etc.) ... THEN OF COURSE they should be used by the operators in those circumstances. This is best done through that operators SMS, if a lack of that type of communications system represents a safety concern. But would you BC mountain people please stop making blanket statements about what should be mandatory for all operators across the entire country.

Ok, so first off, the GPS thingys I was talking about in cars, and that hikers i know use, are the ones that do transmit a signal ... you know like that "OnStar" system where the lady pops up on your dash and tells you which way to turn?

Obviously I DO NOT UNDERSTAND the intricate differences between the multitudes of different satellite and gps systems out there. That may be why I have usually said GPS/ELT, because of the 406's you talk about. I think when Cat says forget what the regulator says, what he means is - if the regulator isn't going to MAKE you use the best possible option, then you should do it out of choice. And he's not talking about Canadian Tire junk, he's just saying it hasn't been aviation certified. (Correct me if I'm wrong here Cat, this is my take on what you say). I don't think there is anything wrong with having EXTRA safety equipment over and above what is regulated.

Try to understand, the officials are telling me everything was done by the book. If that was by the book, the book needs a serious rewrite. If I do not seem to have a singel objective, maybe it is because from my eyes, so many things in so many systems were wrong, and let my husband, the pilot and the other passengers down.

In a perfect world we could trust that an SMS would be written and followed as written. But you and I both know this isn't a perfect world and there are some real creeps out there.

Like I said before

I do take the point that the ELT/GPS is the reg that needs to be changed in order to help eliminate a lot of related problems. That seems to be agreed upon by everybody.

Cat Driver · Post by **Cat Driver** » Tue Jan 23, 2007 6:42 pm

" And then of course there's Cats suggestion that we all abandon aviation equipment in favour of the Canadian Tire / Radio Shack special? "

Neil, I was not suggesting using inferior, unreliable equipment.

There are many reliable devices in industry that are not TSO'ed for aircraft and are reliable.

For instance I had a very good Icom FM radio in my Cessna 185 Amphib ( not installed ) that gave me excellent communications all over the west coast via repeater stations, with that I had portable GPS that worked just as accurately as TSO'ed GPS.....remember it is not IFR flying we are discussing.

For the past ten years we have been in the aircraft ferry business and used ....portable GPS....Satellite phones....( we also had certified HF, which we seldom ever turned on because the Sat. phone was far superior. ) and in one instance a GPS tracking device that was supplied by Air France that tracked us from Toulouse to Santiago..in real time.

Non of the above needed TC approval...

I do not recommend unreliable equipment, however there are lots of accurate electronics outside of aircraft certified that can be used, it just can not be " installed".

Cat