ety Effects of Raising the 

um Payload for Turboprop 

rcraft in Part 135 Cargo 

Operations 

( 
THE ISSUE 

mit on-demand cargo operations under Part 135 to 

aft with a maximum payload of 7,500 pounds. 

n-demand 135 cargo operators to aircraft no 

n the EMB-11 0 and the Beech-1900C. 

5 Advisory Rulemaking Committee (ARC) 

nds increasing that limitation to allow turboprop 

up to a payload of 18,000 pounds to operate on

argo services under Part 135. 

s the following fleet (mostly out-of-production): 

Shorts-360 ATR-42 ATR-72 

Saab 340 Fokker F.27 DASH-8 (1 00-300) 

YS-11 Convair 580 
The Rationale - Efficiency 

ieves the change would fill a gap in the cargo 

 very few aircraft between the BE-1900C & the 

perate cargo flights under Part 121. 

ntends this is a consequence of the regulatory 

e targeted fleet could operate under Part 121, but 

ertificate is too time consuming and too costly to 

arket niche attractive. As a result the targeted 

ded from the cargo market. 

ads might also replace multiple, smaller aircraft 

simultaneously on a route because 1 or even 2 

ot carry payloads that markets demand. 
The Rationale - Safety 

ieves the change also would improve safety ., as 

 more powerful twin-turboprop airplanes would 

wer accident rate than the fleet that currently 

cargo flights under Part 135. 

od would be increased, according to the ARC, by 

he targeted fleet to meet selected requirements 

art 121, but under an existing Part 135 certificate. 

dd that some Part 125 operators have indicated 

roposed change would be enough to bring t~em 

135, thereby adding a presumed safety beneiit. 
Safety Question Posed by the ARC 

uestion posed by the ARC is whether twin

airplanes with payloads up to 18,000 pounds, with 

haracteristics of FAR Part 121, could operate 

t 135 with a lower accident rate than the current 

cargo fleet. 

conclusion is less straightforward. 

assessed only against the posed question, the 

er is clearly "yes, the targeted fleet would have a 

accident rate than the current Part 135 cargo fleet." 

ver, FAA should address other questions as well. 
nalysis of the Posed Question 

racteristics of the targeted fleet were tested and 

ainst 230 Part 135 cargo airplane accidents from 

ugh 2007. The 230 accidents involved a total of 

35 cargo aircraft and 72 fatal accidents. 

9 characteristics was assessed for the degree to 

kely could reduce risk in each of the 230 cases 

the details of each accident. 

J analysis, each characteristic was limited to a 

 score of 90°/o against any single accident, under 

mption that risk can not be absolutely eliminated. 

mula avoided double-counting against any single 

so that no accident was "saved" multiole times. 
Nine Key Characteristics 

RC documents and conversations with some ARC 

 the following characteristics were tested. 

 2-person crew. 

light Following. 

n approved Continuous Airworthiness 

nce Program (CAMP). 

GPWS (future updates by reference to 121 ). 

CAS (future updates by reference to 121 ). 

Autopilot. 

On-Board Weather Radar (Updates by Reference). 

n approved pilot training program, with simulators. 

he reliability, power & higher altitudes available 

turboprops. 
Some Analytical Challenges 

characteristics lacked precision; some of the 

ndicated on the preceding slide was assumed by 

 exactly what is meant by a "Part-121-like" 

CAMP or "121-like" training? What would be 

of flight following? Do we really assume TAWS 

oard Weather Radar (including retrofits)? 

ariation in the targeted fleet made some cases 

 score. When scored against a particular 135 

likely outcome for an EMB-120 or BE-19000 might 

m the likely outcome for an ATR-72-500 (or 600). 
G) 

CD 

::s 

CD 

.... 

D) 

-

m 

D) 

)>Cl 

n 

nee " 

-· .... c.o 

CD C: 

::s ::s ... c. 

tn 

0 

::s 

-a 

D) 

::1 
dents and Fatal Accidents, Part 135 Cargo 

1983-2007 

-------------------------------~ 

(Average 22 annually past 5 years) 

(Average 5 annually past 5 years) 

85 87 89 91 93 95 97 99 '01 '03 '05 '07 
ne Accidents & Fatal Accidents, Part 135 

998-2007, Excluding Ramp & Miscellaneous 

Events (Analytical Baseline) 

---------------------------------~ 

--------------------------------~ 

r-------------------------------~ 

~. , 

~ 1 ,- ~ 1\ A I 

-------------------------- ---- ~ 

~ ,.. ........_ = ,......,.. ,........,_ I 

.- X :A: I .__ . 

~~~~~~~~~~~~~~~~~~~ 

85 87 89 91 93 95 97 99 '01 '03 '05 '07 
., 

-· 

-· 
( 

Percentage of Risk Eliminated 

d Fleet Versus Actual Part 135 Cargo 

Accidents from 1998 to 2007 

ersus All Accidents Versus Fatal Accidents 

Alone Cum Alone L.;um 

13.4 13.4 GPWS 19.9 19.3 

12.1 24.8 2 Crew 18.8 36.4 

Eng 8.7 29.2 T-Prop Eng 15.3 46.8 

w 3.1 30.8 Fit Follow 4.4 48.8 

2.7 32.9 CAMP 3.1 50.1 

 2.3 34.1 WX Radar 2.8 50.9 

ar 2.2 34.9 Training 2.6 52.5 

ot 0.6 35.3 Auto-Pilot 1.4 53.1 

0.4 35.6 TCAS 1.2 54.1 

nefits come from 2 crew members, GPWS & characteristics of 

win turboprops (such as more power and higher altitudes). 

( 
ground on Part 135 Cargo Accidents 

unted for 53 of 230 accidents reviewed (23°/o) & 

accidents (12.5°/o). 

ccident airplanes & 468 0-D locations: 

8 locations (37 .4°/o) are non-towered 

cations have no published procedures 

 fuiiiLS. 

m of 34 accident 0-D pairs (15°/o) are not potential 

or the targeted fleet due to runway length, remote 

xtremely short trips. 

Engine Turboprops or Light Jets (18°/o). 

-Engine Turboprops (14°/o). 

Engine Reciprocating Airplanes (42°/o). 

-Engine Reciprocating Airplanes (24°/o).