A Safety Study of Piloting Skills, Abilities and Knowledge in Seaplane Operations
CONCLUSIONS AND RECOMMENDATIONS
This examination of the occurrence record confirms that the incidence and severity of seaplane accidents is disproportionately high in comparison to landplanes. Loss of control during take-off, engine failure after take-off, collision with objects during take-off, and loss of control during approach and landing are the most frequent types of accident resulting in serious injuries or fatalities. The most frequently cited contributing factors in these accidents strongly indicate serious shortcomings in pilot knowledge, skills or techniques, and/or judgement in decision-making. In sum, the evidence calls into question the adequacy of current practices and requirements for initial and recurrent training from water.
Presently, for training a pilot to fly seaplanes, it is assumed that the pilot need only be familiarized with the general handling characteristics of that class of aircraft. There are seldom any formal ground school sessions where the principles and practices of seaplane operations are explained, nor is any ground school required by regulations. Yet a pilot must be knowledgeable about a number of different operations and techniques to safely operate such aircraft. For example, knowledge of docking procedures, passenger safety procedures, float and hull design and construction, water leakage and drainage procedures, and proficiency in sailing, docking, glassy water, cross-wind and rough water take-offs and landings, etc.
In view of the frequency of seaplane accidents in which the pilot demonstrated inadequate knowledge of the practices and procedures for reducing the risks in operating seaplanes, or in which the pilot demonstrated inadequate technique or skills for the existing conditions, the Board recommends that:
The Department of Transport prepare comprehensive ground and flight training syllabi for the alternate seaplane endorsement; A93-14
The Department of Transport consider including mandatory dual flight instruction in glassy water, cross-wind and rough water conditions in the alternate seaplane endorsement flight training syllabi. A93-15
Transport Canada Response - A93-14
Transport Canada concurs with this recommendation and will develop comprehensive ground and flight training syllabi for the alternate seaplane endorsement as a part of the ongoing Flight Training Guidance Material Enhancement Project. This is a joint Transport Canada and aviation industry project consisting of working groups whose objective is to develop new or enhanced flight training guidance in areas where additional needs are identified.
Transport Canada Response - A93-15
Transport Canada concurs with the need for instruction in glassy water, cross-wind and rough water conditions. A requirement for mandatory dual flight instruction could, however, result in a lack of continuity in training and an inordinately long wait for applicants to obtain the alternate seaplane endorsement because varied weather conditions are not always encountered within a reasonable time period. Therefore, in the absence of actual weather conditions and recognizing the need to ensure candidates receive meaningful instruction in these areas, alternative training procedures will be introduced in the flight training syllabus being developed for the alternate seaplane endorsement as a part of the Flight Training Guidance Material Enhancement Project.
Seaplane conversion training may be conducted by any holder of a Commercial or Airline Transport Pilot Licence with 50 hours pilot-in-command experience on seaplanes. The pilot giving the training does not need to have ever submitted to a test of knowledge on seaplane operations, nor have any experience in training or flying training. In light of the circumstances of many of the occurrences which were studied, it is unrealistic to expect meaningful training, evaluation, and recommendation from a pilot whose only qualification is a minimum experience on seaplanes. Given the seasonal and remote nature of seaplane operations, maintaining quality control in the provision of sound pilot training for safe flight operations is a significant challenge. Yet, the occurrence record strongly indicates a need for improved methods for developing seaplane pilots' knowledge, skills, and judgement. In view of the unique requirements for safe flight operations from water, the Board recommends that:
The Department of Transport require an endorsement to the Commercial and Airline Transport licences for seaplane instruction which would entitle the holder to provide alternate seaplane flight and ground school training to pilots. A93-16
Transport Canada Response:
Transport Canada agrees that additional structure to the training for a seaplane endorsement will help instructors shape the course so that the identified performance objective are achieved. Proposed new legislation will require course approval and adherence to expanded training requirements that will be specified in the Personnel Licensing Handbook Volume1 - Flight Crew. As well, with the planned introduction of comprehensive ground and flight training syllabi to address TSB Recommendation A93-14, individuals authorized to conduct alternate seaplane training will be provided with more useful guidance.
Evaluation and Certification
The attainment of a given standard of knowledge or skill, particularly in the field of motorized equipment operation, generally requires some type of examination. Still, in the case of seaplane operations, a pilot is not required to demonstrate that he or she has acquired an acceptable level of skill, knowledge and decision-making ability. A pilot only needs to have flown the number of seaplane flying hours set out in the Personnel Licensing Handbook to obtain a seaplane rating; there is no requirement to pass a written, oral, or flight test. As a result, TC has no evidence that the applicant has reached a minimum proficiency standard. Although it is normally the trainer's responsibility to recommend the applicant for the seaplane rating, there is room for a wide variety of proficiency level assessments among trainers since there are no established proficiency standards.
To ensure that a minimum level of knowledge, skill, and decision-making ability has been attained after the completion of all required training, the Board recommends that:
The Department of Transport implement a specific knowledge and skill test for the alternate seaplane endorsement; A93-17
The Department of Transport require that all seaplane endorsements be recommended by a seaplane instructor who has been designated as seaplane flight examiner. A93-18
Transport Canada Response - A93-17
Transport Canada agrees that applicants should meet specific knowledge and skills requirements for the alternate seaplane endorsement. The recommending instructor now certifies on the application for endorsement that the applicant has completed the training and experience prescribed in the Personnel Licensing Handbook, Volume 1, Flight Crew, and its competent to hold a seaplane rating.
With the development of the proposed comprehensive ground and flight training syllabi it is felt that these clearly stated performance standards will enable the recommending instructor to judge when a individual is qualified for the seaplane rating.
Transport Canada Response - A93-18
Transport Canada considers that the additional proficiency standards included in the new ground and flight training syllabi will be sufficient to allow the recommending instructor to make a valid assessment of the competency of the applicant for a seaplane endorsement.
Flying Currency for Passenger Operations
Recently, TC has moved to require five take-offs and landings in the previous six months if the licence holder wishes to carry passengers. However, no special provision has been made for the operation of seaplanes.
The Board does not believe that the conduct of five take-offs and landings in a landplane several months before a flight in a seaplane takes adequate account of the unique skills required to operate a seaplane, nor adequately safeguards the lives of the passengers aboard such aircraft. Accordingly, the Board recommends that:
The Department of Transport develop currency requirements appropriate for seaplane operations for pilots wishing to carry passengers on seaplanes. A93-19
Transport Canada Response - A93-19
The present currency requirements specify that a seaplane qualified pilot must be current on seaplanes in order to carry passengers.
Air Navigation Order, Series IV No. 2 requires, in paragraphs 9, 3 and 4, that where passengers are to be carried the holder of a pilot license shall have completed at least five take-offs and landings in the same category and class of aircraft. This requires a pilot in the aeroplane category and the single sea and multi-engine sea aeroplane class to complete these currency requirements within six months preceding the flight by day or night as appropriate.
Periodic Flight Review
For the purpose of its proposed biennial flight review, TC states that sea and land class aeroplanes shall be deemed to be the same class. Since unique skills and knowledge are required to fly seaplanes, demonstration of skill in a landplane will not confirm competence in the specific skills required for seaplane operations. Therefore, the Board recommends that:
The Department of Transport establish a mandatory periodic flight review on seaplanes for the maintenance of the operating privileges of a seaplane endorsement. A93-20
Transport Canada Response - A93-20
Transport Canada has developed a mandatory flight review that is currently undergoing consultation with the aviation industry. The flight review program recommends that a pilot complete the requirements specified in one of the following options once in each 24 month period:
- Completion of the proposed Flight Review program as defined in the Aviation Notice of March 5, 1992; or
- Attendance at a Safety Seminar conducted by Transport Canada, Aviation, or by an organization approved by the Minister which consists of:
a) a session designed to update the pilot on changes to Regulations, Orders and operating procedures; and
b) a session on Human Factors; or
3. Participation in a program approved by the Minister which is designed to enhance pilot knowledge and cognitive skills; or,
4. Successful completion of a Pilot Proficiency Check or mandatory training program as required by an applicable Air Navigation Order; or,
5. Successful completion of a flight test for a license or for the endorsement of a license for instrument rating or instructor rating privileges.
This flight review builds on proven programs that are now being delivered by Transport Canada and segments of the aviation community. As part of the ongoing consultation with the aviation industry, consideration will be given to including material specific to seaplane operations when appropriate.
Commercial Seaplane Pilot Proficiency Check
A proposed new pilot proficiency check (PPC) to be implemented by TC would require an annual check on the most complex single engine aeroplane that the pilot is to operate commercially in VFR. However, for commercial pilots engaged in seaplane operations, the expression "most complex aeroplane" might not always mean a seaplane.
The frequency of seaplane accidents involving commercial pilots suggests shortcomings with respect to the current practices for ensuring pilot proficiency. Therefore, the Board recommends that:
The Department of Transport require that a pilot proficiency check be performed on a seaplane if the pilot seeking the certification of proficiency is to operate seaplanes commercially. A93-21
Similarly, there is a requirement for pilots engaged in commercial operations to have completed within the preceding 90 days, on the same type of aeroplane they are to operate, at least three take-offs and landings. This requirement only applies to the type of aircraft, not the landing gear configuration. A seaplane pilot could therefore satisfy the requirement by having flown the same type of aircraft on wheels or skis in the preceding 90 days. By doing so, the intent of regency for take-offs and landings is defeated. Therefore, the Board recommends that:
The Department of Transport amend the 90-day requirement for commercial seaplane pilots so that the take-offs and landings must be performed on a seaplane. A93-22
Transport Canada Response - A93-21
Transport Canada agrees that the pilot proficiency check should be performed on the appropriate class of aircraft that the pilot operates. The new Air Taxi Standard which will be issued in conjunction with the new Canadian Aviation Regulations specifies the type of landing gear utilized in the performance of the competency check. This will certify the competency of each pilot in the most complex single-engine aeroplane type to be flown with the landing gear configuration, wheels, floats or skis, as appropriate to the operation.
Transport Canada Response - A93-22
Transport Canada agrees that the 90-day currency requirement should reflect the category and class of aircraft being operated by the individual pilot. Transport Canada Aviation will consult with industry through the Canadian Aviation Regulation Advisory Council regarding an amendment to the Air Taxi Regulation that would require the pilot to complete the 3 take-offs and landings within 90 days on wheels, skis or floats as appropriate.
Seaplane Pilots' Seminars
The decentralized nature of seaplane operations throughout Canada's remote regions requires that skills and techniques (beyond those acquired in initial seaplane training) be developed and passed on by experts in the field. These generally sound operating practices do not lend themselves to traditional regulatory controls. Therefore, seaplane pilots require alternative means for acquiring information to refresh and enhance their knowledge for safe seaplane operations.
Some industry representatives have indicated that local seminars would be an effective way of bringing experienced seaplane pilots together to share their experience regarding verified techniques and procedures with their peers. Therefore, in order to reinforce the foundation upon which certified seaplane pilots can build their piloting skills, abilities, and knowledge, the Board recommends that:
The Department of Transport, in collaboration with seaplane pilot associations and other aviation industry associations, require Seaplane Pilots' Seminars to be conducted regionally every year at the beginning of the normal seaplane season in strategic locations. A93-23
Transport Canada Response - A93-23
Transport Canada agrees that safety seminars can be beneficial in improving the safety of seaplane operations in Canada. The Transport Canada Regional Offices will coordinate, in conjunction with the industry associations, these seminars at appropriate times and locations.
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