Angel Flight did not consider the safety benefits of commercial passenger flights when suitable flights were available.
The ATSB acknowledges that the Angel Flight Board has carefully reviewed the implications of changing the organisation's business model to address this safety issue. The ATSB notes that the Angel Flight Board has chosen not to change existing policies and procedures to preference the use of commercial scheduled (RPT) passenger flights, when available and suitable for their passengers’ needs, ahead of using private community service flights. Angel Flight will continue to preference private community service flights in most circumstances.
The ATSB has always acknowledged that there will be valid criteria (flight availability, passenger suitability and comparative costs) which prevents some passengers from using RPT. The latest edition of the ATSB’s Aviation Occurrence Statistics report shows that RPT (domestic) flights remain substantially safer than both private operations and community service flights. Therefore, the safety issue giving rise to the recommendation still exists.
The Australian Transport Safety Bureau recommends that Angel Flight Australia takes action to enable it to consider the safety benefits of using commercial flights where they are available to transport its passengers.
Angel Flight advised that further response would be considered at the next board meeting, and additional comments would be provided.
Angel Flight has considered the recommendation carefully and has determined that it maintain its current policy of giving priority to using private flights where possible and to continue to use regular public transport flights when private flights are cancelled or unavailable, and for transfers between capital cities.
The reasons for our decisions are:
Angel Flight rejects the claim in the ATSB report that, for Angel Flight passenger carrying flights, the “fatal accident rate was more than seven times higher per flight than other private flights” as invalid.
A valid analysis addressing passenger risks would require comparison of passenger carrying Angel Flights and other passenger carrying private flights. Since no such data are available for other private operations, the only reasonable comparison is between all Angel Flight operations and all other private operations. Even then, results must be treated cautiously because an unknown proportion of private operations involve circuit training and short local flying whereas all Angel Flight operations involve flights with an average sector length of 1.5 hours.
The analysis in Table B2 on page 69 shows that, when all Angel Flight sectors are included, the fatal accident rates are 0.5 and 0.2 per 10,000 flights for Angel Flight and other private flights respectively, and the difference is not significant. Furthermore, when all accidents are included, the rates are 1.1 and 1.5 per 10,000 flights for Angel Flight and other private flights respectively.
Angel Flight rejects the claim in the ATSB report that “community service flights conducted on behalf of Angel Flight Australia (Angel Flight) had substantially more occurrences …… per flight than other private operations” as invalid.
ATSB has compared Angel Flight operations, approximately 95% of which operate to and from Class C and D airspace with other private operations where an unknown, but undoubtedly much lower, proportion of flights are in controlled airspace. Angel Flight has been unable to find any data that would permit a valid comparison of similar operations for other private flights.
The ATSB report acknowledges, in the Safety Summary, that “The types of occurrences where flights organised by Angel Flight were statistically overrepresented (as a rate per flight) compared to other private operations were consistent with these operational differences.” However, the report then immediately ignores the vastly different operating environments and claims that the difference “indicated an elevated and different risk profile in Angel Flight”.
Thank you for your response to the above ATSB safety recommendation. The response, received via email on 29 September, indicated that the recommendation had been considered and rejected, and that Angel Flight Australia had determined that the current policy would be maintained. The ATSB Commission have considered this response, and would like to provide you a further opportunity to consider your response.
The reasons outlined for the decision by Angel Flight to maintain its current policy of giving priority to private flights where possible do not address the evidence on which the recommendation was made.
As outlined in the final investigation report, that evidence centred on that commercial passenger flights have an established lower safety risk for passengers than private operations. The reasons stated in your response only addressed your disagreement with other evidence in the ATSB final report concerning the relative safety of Angel Flights and other private operations.
The ATSB Commission believes that Angel Flight should firstly consider the safety of Angel Flight passengers. Regional and rural people should not be exposed to unnecessary levels of risk as a passenger on a private community service flight, and as such, Angel Flight should consider the safer option as the primary option, where available, before considering private operations.
The ATSB Commission is therefore asking you to reconsider your response to the safety recommendation.
The ATSB investigation showed that commercial passenger flight options are available for a considerable percentage of the private flights organised by Angel Flight. As a charity established to transport people without the means to medical appointments, the ATSB considers that Angel Flight could and should include the fact that commercial passenger flights have a lower safety risk to passengers than private operations as a factor when they are organising flights.The ATSB acknowledges that there will be passengers who cannot travel on regular public transport, and that there are times and locations where it is not available or suitable. However, in the case of the accident flight, no consideration was given to the safety benefits of using the available RPT, nor were the comparative costs considered. It is unlikely that any of the considerations previously outlined by Angel Flight (cost, passenger needs, flight locations and timing) would have prevented the use of a commercial flight.
In accordance with our protocols, we will publish the received response and Angel Flight’s position on the safety recommendation. However, prior to publication, I am offering you a further opportunity to reconsider the safety recommendation.
Please do not hesitate to contact me if you would like to discuss this response to the safety recommendation.
In closing, please allow me to reiterate that the ATSB considers the conduct of community service flights demonstrates selfless concern for others less fortunate requiring medical treatment from regional and rural Australia. It is our purpose however, to improve transport safety. The ATSB continues to encourage the consideration of the safety benefits of using commercial flights where they are available.
We have had a major board change last week, with the retirement of our Founder and one other director, and the appointment of two new Directors, with the first AGM comprising additional company members to occur 3 December. The new board has yet to have its first formal meeting.
However, we have this week determined that it would be in the interests of the ATSB, Angel Flight, and rural communities if Mr Hood would meet with us at the Angel Flight headquarters, in order that he may familiarise himself personally with our charity, its people, and the processes by which disadvantaged rural Australians are assisted.
We envisage this occurring before a formal response is given.
The ATSB Commission acknowledged the invitation to Angel Flight facilities, and are liaising with Angel Flight to coordinate a visit to coincide with a board meeting to further discuss the recommendation.
Angel Flight Board response
The Angel Flight Board has given very careful consideration to both the recommendation and the safety issues included in the report and can now advise our position as follows. We make these responses provisionally, as we have only now had the opportunity to view the latest ATSB accident rate report [Aviation occurrence statistics, 2010-2019]. On the face of it, the [community service flight] CSF [fatal accident] rate [for 2014-2018] is approximately half of that originally reported [2008-2017], and even less when the correct data is used (and not the admittedly flawed BITRE data). The latter reports 1,264 total hours flown in the entire sector, whereas our own (validated) database shows Angel Flight alone flew 3,042 hours that year. However, we are undertaking further expert analysis to confirm these comparatively low rates, and shall revert to you when these findings are available.
The Angel Flight Board noted that the recommendation advises Angel Flight to “consider the safety benefits of using commercial flights”; it does not specifically recommend preferential use of airline (RPT) flights.
Angel Flight has always made use of airline flights when safety considerations preclude private flights, to the extent that RPT accounts for approximately 20% of passenger transfers. The Board has carefully reviewed the implications of changing the business model to preferential use of RPT flights. In doing so, Angel Flight readily acknowledges that RPT flights have a better safety record than both charter and general aviation. Indeed, that is the reason passengers are made well aware that flights do not operate to the same standard as airlines.
While accepting the higher safety standards of RPT, the Board considers that there are many other factors that determine whether RPT is the most suitable option for passengers:
a) Angel Flight already uses RPT flights whenever weather, the availability of suitable aircraft and/or pilots or any other factor means that safety or passenger comfort considerations deem a private flight unsuitable.
b) Angel Flight is continually working to improve its systems and to address safety issues that become apparent at any time, not only in response to an accident.
c) RPT flights are sometimes cheaper than volunteer flights when there is only one passenger on a popular route, but this is rarely the case. Commonly, there are two or more passengers, in which case, airline flights are rarely cheaper.
d) RPT schedules frequently do not align conveniently with passengers’ medical appointments and would often require overnight stays. Angel Flight’s volunteer flights are matched closely to passengers’ appointment times so the majority of appointments are accomplished as day trips with minimal waiting times.
e) RPT departure times are inflexible, causing problems for passengers when medical appointments run late (a very common occurrence). Angel Flight’s flexibility easily copes with such delays, and with early completion of appointments.
f) All active pilots are very experienced and well qualified. Of the active pilots, 54% have CPL or ATPL licences; 59% are instrument rated; 44% have more than 1,000 hours PIC; and several have more than 20,000 hours.
g) Passenger pick up and drop off are very difficult for both passengers and drivers at capital city airports. Volunteer drivers frequently comment on difficulties locating passengers in busy terminals, the inconvenient locations of car park, and the long walks to car parks, especially for elderly and physically impaired passengers, all factors that add unnecessary stress to passengers. It is far easier for pilots, passengers and drivers to use secondary airports where parking and access are much easier.
h) Passengers prefer the very personal service, interactions and care provided by volunteer pilots and drivers over the impersonal service of airline flights. Flight in a light aircraft is also a welcome distraction from the health, financial and other difficulties they face.
i) Pilots volunteer because they love flying and want to use their skills to help others in need; Angel Flight anticipates that many will lose interest if there are significantly fewer opportunities to fly.
j) Drivers also volunteer because they want to help others; they, too, will lose interest if most flights arrive at and depart from the major airport terminals
k) Revenue would decline substantially because donors are particularly attracted to Angel Flight’s volunteer model, its very low overhead costs, and the way it uses more than 90% of its funds for passenger transport.
In addition to all of the above, preferential use of RPT flights would change completely the Angel Flight business model. Angel Flight Australia is modelled very closely on the successful Angel Flight West which has operated in USA since 1983 and is the largest such organisation in the world. The key to the success of all Angel Flight organisations is the willingness of pilots and drivers to volunteer their services, their aircraft and cars to help people in need.
The current Covid-19 crisis provides an excellent illustration of the real value of Angel Flight in regional Australia. With Rex Airlines suspending all flights except the few government subsidised flight in Queensland, and other airlines ceasing or dramatically reducing all services, Angel Flight has become the only option for even more rural Australians.
It is the Board’s view that Angel Flight should continue to use RPT as a back-up to its volunteer services while using volunteer pilots as the primary source of passenger transport. In doing so, Angel Flight has processes for safety management and continual improvement that ensure our services are delivered with ever-improving standards of safety, comfort, convenience and courtesy.
