On January 11, the Federal Aviation Administration published a long-awaitedproposed rule that will extend the requirement for safety management systems to certain design and manufacturing organizations and most commercial air operators. The full notice of proposed rulemaking runs to 129 pages, but in the context of the emerging urban air mobility industry, two sentences in particular stand out.
Explaining why it decided to mandate SMS for air carriers that have only a single pilot, the FAA stated: “As a fundamental matter, the flying public expects safe carriage from operators offering flight services for hire. Irrespective of whether an operator employs one pilot or a thousand, that company has the same responsibility to conduct safe operations.”
This philosophy is not entirely consistent with how the FAA actually does business. The agency has multiple levels of operating rules, including Part 91 (general aviation) and Part 135 (commuter and on-demand), which enable many business models that are inherently riskier than scheduled airline operations under Part 121. The vast majority of Part 135 operators in the U.S. have fewer than 100 total employees, which means that companies with 1,000 pilots are functionally subject to stricter requirements and scrutiny than companies that employ only one.
Yet, it is nevertheless true that members of the flying public expect safe carriage from all commercial operators, and often lack the expertise to understand why one type of carrier may pose more risk than another. Electric vertical take-off and landing aircraft will conduct urban air taxi operations in the United States under Part 135, but there is widespread consensus that UAM will only scale if it can significantly improve on the existing Part 135 accident rate, which is somewhere between five and 20 times the rate for Part 121 scheduled carriers.2Accident rates vary from year to year, but in 2021, U.S. scheduled air carriers operating under Part 121 averaged 0.139 accidents per 100,000 flight hours (0 fatal). Part 135 on-demand carriers averaged 0.715 accidents per 100,000 flight hours (0.179 fatal), and Part 135 commuter carriers, 2.739 (0.249 fatal).
Despite the relentless drumbeat for SMS from the National Transportation Safety Board and others, it is unlikely that safety management systems alone will deliver the necessary step change. While they can be a useful tool for operators with a sincere desire to improve safety, they cannot meaningfully address the structural risks that are baked into certain business models. For high-tempo, low-margin UAM operations to achieve their safety targets, they will need to borrow more from Part 121 than just SMS.
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