Attachment 2 is a sample extract of project information developed by the USGS helicopter committee. Alaska Region OAS is complimentary of the procedure and endorses continuation of the current system. The USGS has adopted a minimum pilot qualification criterion which exceeds that prescribed in the Departmental manual. Contract specifications for USGS aircraft services stipulates a minimum of 3,000 hours pilot-in-command whereas the Departmental manual specifies 1500 hours pilot-in-command. The increased pilot experience requirement represents a management decision made in the interest of optimizing the agency's production effort within the framework of a safe flying environment. Records at OAS indicate the Alaska USGS FY 87 flying hour program was 1,632 hours. Of that amount, approximately 10% was expended in Southeastern Alaska, to include the Ketchikan area. USGS Branch of Alaskan Geology employs 60 geologists who routinely use aircraft in pursuit of their professional endeavors. Additionally, another 10 to 15 USGS geologists with duty stations located outside Alaska use Alaska contract or rental aircraft at sometime during the year. Thus, a total of 70 to 75 employees are involved in the Alaska USGS aviation program. Some Alaska USGS employees who fly in contract and rental aircraft perceive themselves as a captive audience subject to the variable skills of the pilot involved. Their inability to contribute to or influence safety of flight is frustrating and represents a factor which should be addressed. Discussions with the OAS Alaska Regional Director and Alaskan Geology Associate Branch Chief resulted in a general agreement that "observer training" could be a reasonable mitigating measure and one which would provide a positive contribution to the see-and-avoid program. Subject matter content should be oriented toward avoiding midair collisions to include causes and profile of midair collisions, scan pattern/techniques, physiological limitations of the eye, etc. The Ketchikan International Airport is located on the Gravina Island side of the Tongass Narrows directly across from the city of Ketchikan. See Attachment 3. It is a modern airport facility with instrument landing and departure systems, lighted hard surface runway, and a well maintained terminal building. The terrain surrounding the Ketchikan Airport is characterized as having high topographic relief with dense stands of commercial grade spruce/hemlock timber. The steep close-in mountainous terrain adjacent to both sides of the airport channelizes VFR traffic landing or taking off in the Ketchikan area. See Attachment 4. In recognition of the unique flying requirements applicable to the Ketchikan area, the Federal Aviation Administration (FAA) published special air traffic rules in 14 CFR Part 93 Subpart M, copy furnished at Attachment 5. The application of this rule causes the Ketchikan control zone to be configured so as to permit the exclusion of most of the local VFR float plane and helicopter traffic in the area. This is achieved by excluding airspace below 600 feet mean sea level (MSL) except for a narrow corridor covering the airport and extending three miles beyond the ends of each runway. Inside the corridor the control zone begins at ground level. Attachment 6 is a schematic cross section showing a partial horizontal profile of the control zone sliced vertically on a plane perpendicular to the west end of Runway 11. Attachment 7 is a vertical sketch which has been shaded north of control,zone to depict excluded airspace below 600 feet MSL. Persons operating aircraft under VFR within the control zone must have established communications with the Ketchikan Flight Service Station (FSS) and have received an air traffic advisory. While this rule provides coordinating information to users of the control zone airspace, it does not provide positive control and insure traffic separation. Information furnished in a traffic advisory is not directive in nature and its use is totally discretionary on the part of the pilot. The weather pattern for Ketchikan is somewhat typical for a Pacific Ocean coastal community, however, a concentrated moist airflow normally dominates the area resulting in over 155 inches-per-year rainfall. The area received 31 inches of rain in November 1987. The high terrain on both sides of the airport produces a venturi effect which increases wind velocity through the Tongass Narrows. Flight in windy cloud covered conditions is routine at Ketchikan. Basic VFR weather minimums are prescribed in 14 CFR Part 91.105 and are partially described below: B. 500 feet below Clear of clouds No person may operate an aircraft, under VFR, within a control zone beneath the ceiling when the ceiling is less than 1,000 feet. The distance between the 1,000 foot contour lines on both sides of the Tongass Narrows measured at the west end of the runway reveals a lateral distance of 2.15 statute miles. Thus, with a cloud ceiling of 1,000 feet all VFR traffic is funneled through a geographically constricted area which becomes progressively smaller as aircraft altitude is decreased. Because "outside controlled airspace" rules are less restrictive, there would be a tendency for aircraft to remain in the shaded area of Attachments 6 and 7 in order to continue aviation operations during periods of reduced visibility. This can be viewed as bittersweet when impact on air commerce is considered. It allows large volumes of VFR traffic (seaplanes) to operate without special VFR clearances thus expediting traffic flow without increasing FAA workload. However, the flip-side of that is a reduced level of safety due to concentrated traffic density in a confined area without positive control. The August 1987 midair collision (the first ever in Ketchikan) involving the USGS contract helicopter had a galvanizing effect on the community. Even though there was a general awareness and concern about the flying conditions at Ketchikan, the local aviation community was passive and not motivated to initiate changes prior to the accident. Since the accident, a dynamic coordinated effort has been taken to address aviation safety issues and conflicts. Involvements include: - FAA: The FAA organized a task force and conducted an on-site air traffic management analysis of the Ketchikan area during the period September 11-18, 1987. A copy of the FAA report will be provided OAS when completed. - Borough Government: Ketchikan area has two local governments, city and borough (county). The borough has jurisdictional authority for taxation, education and airport services. Population of the borough is approximately 12,000. The borough mayor formed an ad hoc Air Safety Task Force consisting of local community members to address three issues: 1. FAA plans to modernize and consolidate flight service stations in Alaska. 2. The need for a control tower. 3. Narrows. Enhancement of flight safety regulations relative to the Tongass The airport manager is a member of the task force and openly expressed concern over the safety aspects of the flying environment at Ketchikan. A copy of the resolution creating and charging the Air Safety Task Force is at Attachment 8. -- Tongass Aircraft Pilots Association (TAPA): TAPA is an unincorporated coalition of pilots and operators formed to promote aviation safety in the Ketchikan area. Motivated by the USGS contract helicopter midair collision, TAPA has taken the initiative in proposing solutions to the Ketchikan airspace problems to include the establishment of a harbor airspace traffic pattern and associated operating procedures. Copies of FAA internal memo, letter of agreement signed by the three largest operators in Ketchikan and TAPA traffic pattern proposals are found at Attachments 9-1 through 9-3 respectively. The Ketchikan FSS Air Traffic Manager participated as a member of the traffic pattern committee and has served as a catalyst in processing the proposals to the FAA regional office. One of the proposals provides for a non-standard traffic pattern for Runway 11 (right downwind), keeping all small land plane aircraft south of the runway and raising the pattern altitude higher. Adoption would significantly contribute to the deconfliction of float plane traffic and airport traffic by providing horizontal and vertical separation. The three primary elements in the Ketchikan economy are timber, commercial fishing and tourism. Two of these elements directly impact on Ketchikan aviation safety: - Approximately 300 fishing boats comprise the commercial fishing fleet that make home port in Ketchikan harbor. Fishing boats traverse the Tongass Narrows daily for harbor ingress and egress. The east end of the Narrows is split into east and west channels by Pennock Island; the opposite end of the Narrows is constricted as it flows past the airport; the area in between forms the greater harbor area in which surface water traffic congregate. The downtown seaplane base is immediately adjacent to the fishing boat dock facilities. Waves produced by boat movement, boat congestion and water space occupied by boat slips are important factors to be considered in resolving seaplane/surface boat conflicts. - Tour boats carrying several thousand passengers each visit the Ketchikan port on a daily basis during the May-September tourist season and less frequently throughout the remainder of the year. As many as five tour boats may be in port simultaneously. Not only does the presence of these large vessels add to harbor congestion, but many passengers charter local aircraft for "flightseeing" tours of points-of-interest. Five tour ships may unload a combined total of several thousand passengers on a given day. These temporary port calls last five to six hours. It is estimated that each tour boat docking produces $50,000 in community revenue. Business leaders and local government officials are sensitive to the implementation of any modification which may impede tour boat access or restrict visitor movement throughout the area. an FAA Alaska Region Air Traffic Division representatives expressed institutional commitment to improve aviation safety in Ketchikan. Remedial FAA initiatives include: - FAA-sponsored quarterly safety seminars involving TAPA, harbor master, stevedoring leaders, and other local community groups. - Installation of an automated terminal information system (ATIS). Increasing a full time flight standards presence in Ketchikan during the April through November time frame. The FAA Alaska Regional Director has publicly announced his commitment to support local air traffic safety initiatives. However, this commitment does not include activation of an airport tower facility. The FAA position is that a tower is inappropriate because: - - 75% of Ketchikan air traffic is float plane take-offs and landings. The seaplane landing area is approximately one mile from the airport and difficult to see and control from the airport. - The seaplane landing/take-off area would require manpower to maintain a debris-free waterway. There would be no way to communicate with boat traffic. Interviews with the Ketchikan airport manager, Ketchikan FSS manager, the president of TAPA, and the local U. S. Forest Service (USFS) aviation manager provides a consensus outlining various agency positions with respect to management responsibility of water traffic of the Tongass Narrows. - Borough Harbor Master: Limited jurisdictional authority is exercised within the protected harbor (docking areas) only. Responsibility for the Tongass Narrows navigable waters is disclaimed. U. S. Coast Guard: The U. S. Coast Guard (USCG) has a full time presence in Ketchikan. The USCG is reluctant to establish itself in a law enforcement role particularly as it might relate to boat speed and traffic patterns. This is because of resource limitations and a primary mission of search and rescue. Apparently the real or implied legal liability and presumed obligation for expenditure of resources have prevented assumption of seaplane landing area management responsibility by any federal, state, or local entity. Ketchikan air traffic land and take-off from five different locations in close Air traffic volume at the International Airport represents a minor percentage (15%) of the total air operations that occur in the Tongass Narrows and harbor area. proximity to the International Airport. One method of expressing air traffic density is in terms of numbers of aircraft operations. One operation is a landing or a take-off. A recapitulation of annual aircraft operations data is furnished below: *Supporting FAA Forms 5010-1, Airport Master Record, reflecting air traffic operations data are at Attachments 10-1 through 10-5. Accuracy of data will be compared with FAA Ketchikan Air Traffic Management Analysis study when received. |