I finally had a chance to view Frontline’s special from February entitled “Flying Cheap“. This program is a little under an hour in length and is worth watching, especially if you’re interested in flying, the aviation business, or government safety regulation.
I spent 4 1/2 years flying for a regional airline in the late 1990’s, so I have some personal experience relating to the topic of the show. I thought I’d provide some general and specific comments about the show, and briefly introduce a market-based idea which could better serve the safety interests of paying passengers than the current regulatory model.
Overall, I’d say Frontline did a fair to good job presenting challenges faced by the regional airline industry and the story of Continental 3407 in specific. Their presentation was met with a stern rebuttal from Colgan Air itself, which is also worth reading. As always, there are two sides to every story. That said, the issues of pilot pay, long hours, experience, and training are very real problems for the regional airline industry. The show does a fairly good job outlining those problems and showcasing one example of the adverse consequences that can come from not addressing those problems.
I would not rate the show as excellent or outstanding in part because it does focus nearly all of its attention on the problems with the industry and does not, in my opinion, do a good enough job highlighting the admirable safety record of the regional industry in spite of those challenges. It also contains a level of journalistic sensationalism that seems to fit NBC better than PBS (not quite Fox, but still dramatic).
Around 6:40 comes this quote, “No doubt in our mind that when she’s buying this ticket, she’s buying a flight on Continental for which she believed she had Continental pilots and Continental safety and Continental service.” I was glad to see Frontline point out that the reservation did say the service in question was operated by Colgan and that the passenger was, in fact, given that information. While the quote may accurately represent the impressions of the people involved, the people involved were clearly informed that the flight was operated by somebody other than Continental. This quote, and this whole show, should serve as a “buyer beware” warning. The warnings are there and have been all along. Now you know what that means.
At 18:00 comes this quote, “We ended up with a different structured industry than people have probably anywhere else in the world where these regional carriers are vitally important.” This is simply not true. The structure of major carriers partnering with regionals that are either contracted or subsidiaries, but with their own separate employee groups, is not uncommon. That arrangement is fairly widespread in Europe and also exists elsewhere in the world.
At 21:35 and onward, Roger Cohen defends the regional airline industry in response to revelations about pilot pay. He refers to average salaries for Captains and First Officers and is quickly reminded that lower salaries do exist. In my opinion, his defensiveness is very revealing. The facts he states may be true but he paints a picture of the industry that is better than I see it.
The truth is that first year pay is very low. Throughout the show, figures in the low-$20’s (thousands per year) were mentioned and those are very common numbers. There are actually a few that are lower than that. Commutair (Continental), Great Lakes (Frontier & United), and Gulfstream (Continental, United & Delta?) have first and second year First Officer pay rates below $20 per hour, which roughly equates to $20,000 per year. There are Captains at those same airlines making less than $40 per hour (roughly $40,000 per year). Those people are the ones working the hardest for the least pay. While there are senior Captains at some regionals working less hard, flying better equipment, and making over $100,000 per year, that doesn’t negate the fact that those lower paid, harder working pilots actually do exist.
Around 23 minutes into the show is a description of a crash pad. Those kinds of crash pads do actually exist. Not all crash pads are like that, though. I owned a crash pad (my former personal residence) for a while. I used it myself and rented space out to other pilots. It was a nice 3 bedroom, 2 1/2 bath house with a downstairs family room (I used that part for myself). I only rented to one person per room, so it was far more comfortable than most crash pads. It was also more expensive. My tenants all worked for the same regional airline I worked for, but they all either had other sources of money (income or savings) and/or had no other family obligations. None of them were living that way totally unassisted and solely on their income from our airline. Also, despite its niceness, none of them used my place as a primary residence (that’s not what a crash pad is).
At 27:20 comes this gem, “Safety is the number one priority, and there is no airline … that would ever operate any aircraft … and risk the safety of the passengers and crew.” The implication is that the airline won’t pressure the crew to operate unsafely (or illegally). Unfortunately, that’s simply not true. Airline managers do sometimes pressure crews into operating unsafely or illegally. Some do it more than others, and it’s not isolated to regional airlines. It is true that no airline I’m aware of has as its official policy that pilots should sacrifice safety or legality to complete a flight. However, the idea that no airline (manager)ever suggests or even pressures unsafe or illegal operation is simply not accurate.
Having said that, many (maybe most) people both inside and outside the airline industry are under the impression that safe operation is some kind of black and white, totally objective ‘thing’ that will result in an accident-free flight. That’s also not true.
Safety involves subjective criteria and (virtually infinitely) variable quality. For this reason, the “one level of safety” concept is horribly flawed. It communicates the false impression that if everyone does a certain set of things, there will be this nebulous concept of “safety”. There is no such thing as absolutely safe, or totally risk free. In theory, it might be possible to establish a minimum level of safety within a known set of constraints, but “one level of safety” neither means absolute safety, nor even the best safety practically achievable.
Safety does cost money, and in as much as this documentary correlates safety and money (“Flying Cheap”), it hits the mark. Regionals who are cheap on pay and training do increase the risk of competence- and proficiency-related accidents. That doesn’t mean that cheap airlines are absolutely unsafe, nor that expensive airlines are absolutely safe. However, regionals do systematically save money by increasing risk factors in ways their major airline partners don’t: lower pay attracts less experienced pilots, and harder worked (more productive) pilots results in more fatigue on average. Those are the facts of the regional airline industry and the Frontline documentary describes them reasonably well.
Mary Schiavo is quoted several times in the documentary. What a mistake that was. She’s never met a camera she doesn’t love and always has some way to twist the truth that makes it dramatic and sensational. She occasionally has some legitimate comment to make but I tune her out at every opportunity and recommend others do the same. Her comments in this documentary mostly live up to my expectation.
Probably the best quote in the whole thing comes about 33 minutes in to it. “Relying on the FAA to ensure that all carriers fly safely has its limits.” Never has a truer statement been spoken! Unfortunately, the documentary immediately focuses solely on the FAA not doing enough of what it already does, as if doing ‘enough’ would somehow result in unlimited ability to ensure safety. Never does the documentary question whether, even under perfect conditions, the FAA could ensure all carriers fly safely.
In fact, it can’t. Nobody can. The proposition that anyone could ensure all carriers fly safely requires accepting the false premise that safety is completely objective. It isn’t, ergo the FAA can never do what most people presume it’s supposed to do. When you follow that train of thought, you come to a bit of a bizarre, but logical, conclusion: The FAA is implicitly and maybe explicitly fraudulent.
The FAA’s mission statement, until recently, was “to provide a safe … aerospace system…” This was recently revised to read “to provide the safest … aerospace system in the world.” While that latter goal is, in theory, attainable, they go on to say, “We work so all air and space travelers arrive safely at their destinations.” That goal is clearly unachievable. Furthermore, their historical emphasis on safety, including “one level of safety” (a key initiative starting in the 1990’s) gives the impression of an objective and absolute level of safety.
The implication of FAA certification is twofold: That certified operators are “safe”, and that non-certified operators are “unsafe” and, thus, prohibited from operating. While there may be early signs of abandoning that irrational view and moving towards a view valuing relative safety, those implications are still ever present. As a result, it’s hard to see the FAA as anything other than fraudulent (never mind irrationally coercive). Those who fail to see this are disappointed and confused when accidents like Colgan 3407 happen.
I don’t say this to disparage the efforts of many hard working people at the FAA who genuinely want to increase the level of aviation safety. In many cases, they’ve had a positive impact on aviation safety. Of course, there are those who are just power hungry irritations that exist solely to reinforce the FAA’s motto: “We’re not happy ’til you’re not happy.” Despite that reputation, I’ve interacted with many people in the FAA who seem genuinely interested in safety. I suspect they’re doing the best they can and some of them probably do positively impact safety.
None of that fixes the underlying philosophical problems with the entire FAA mindset and government safety certification. This raises the question, “Is there a better way?” I believe there is. The answer to that question involves a paradigm shift in three important ways.
First, a better system needs to be based on the correct premise that safety is subjective and relative. The flying public should be treated like intelligent adults and told the truth. There is no such thing as “safe”. There are desired outcomes which are subjective and relative levels of safety quality with respect to those outcomes. Any statement about safety should include both the subjective criteria (e.g. “does not directly cause harm to persons or property”), and a statement about the expected relative level of safety (low, medium, high, etc.). This is, in essence, the exact opposite of “one level of safety.” Automotive crash and rollover test ratings might serve as a useful example.
Second, a better system should allow competing safety standards within the arena of allowable operation. This could potentially include two dimensions. First, multiple levels of safety standards could exist without outright prohibition of operation. Using the automotive example, it’s possible to buy cars that rate at three stars even though five star cars are available. No such luck with airlines. Additionally, opening the door to competition between certification agencies and the types of safety factors they measure might improve customer satisfaction. Factors could be evaluated based on their effect on outcomes and customer preference could be measured based on what outcomes they want to see more of.
Third, prohibition should be limited to requiring the operator to take complete financial responsibility for their actions (including potential harm on the ground), demonstrating that ability, and truthfully informing the customer with respect to the safety standards they meet. The combination of a variety of certification standards and required financial liability would serve as a practical barrier to operating without certification. Insurance companies might offer discounts for carriers with lots of high quality certification and customers might pay a premium for safer travel. Without that kind of freedom and information, the market is incapable of best serving the needs of the flying public.
The ideas above would not result in a totally unregulated environment, nor would implementation of those ideas necessarily spell the end of the FAA. I don’t know how it would ultimately turn out, but I imagine such a system may well result in higher safety standards. Even if it didn’t, customers would be informed as to what they were getting. Then, maybe their interview with Frontline might be a different kind of warning to the rest of the world: “Don’t choose a less-safe airline just to save a buck.” As it stands now, we don’t know the difference and we don’t have a choice.
Note: I didn’t spend a huge amount of time editing this. While I think it’s reasonably good, I wouldn’t hang on every word. Ask before quoting and/or hanging your hat on anything here… 🙂