AKRON, OH (WOIO) - The National Transportation Safety Board released Tuesday the cause of the Nov. 10, 2015 plane crash. Nine people were killed when the plane went down in Akron just before 3 p.m..
According to the FAA, the 1979 Hawker H25 twin-engine business jet left Dayton-Wright Brothers Airport and was on approach to Akron Fulton International Airport. The Ohio State Highway Patrol says the plane clipped a telephone wire, hit an apartment building on Mogadore Road, then crashed into an embankment behind that building. No one was in the apartment building at the time of the crash.
The victims worked at Pebb Enterprises, a real estate company in Florida. Pebb was scouting locations for shopping malls in Ohio when the plane went down about two miles from the airport.
READ THE COMPLETE TRANSCRIPT OF THE HEARING BELOW:
Good morning. I would like to call this meeting to order. Welcome to the boardroom of the national transportation safety board. It is my privilege to serve as the chairman of the NTSB. Joining me are -- we meet in an open session to consider the fatal crash of a hawker 700 a into an apartment building just short of the runway 25 at the international airport. Several passengers and the captain lost their lives in the crash. On behalf of my fellow board members and the entire NTSB staff, I like to express my sincere condolences to the family and friends of those who died in this crash. We hope this investigation will prevent such tragedies in the future. The residents of the building were not at home, and while people on the ground face property losses , none was killed or injured. The accident flight was an on-demand charter flight operated by a company under part 135. Many conscientious charter services -- and Federal Aviation Administration inspectors are assigned to each operator to ensure that the regulations and company procedures are being followed. The traveler boards and on-demand charter flight with the assumption that these company protections are in effect. The accident you will hear about today , we found flight crew, FAA, and inspectors fell short. In addition the flight crews briefing was unstructured, inconsistent, and incomplete. As a result there was no shared plan. The disregarded procedures i have mentioned read of like pages from a basic text for preventing accidents. These procedures and the accidents they represent work nor it. This disregard for safety was not confined to the actions of the flight crew, it extended to their employer paid our investigators found organizational factors , scheduling, and other practices that predicated and predated the flight. The captain's test answers merited a failing grade of 40%. Yet it was graded 100%, glossing over deficiencies that could have been corrected. FAA oversight of executive Execuflight -- they implicitly trust that FAA standards, the charter company standard operating procedures, and the professionalism of the pilots will protect them from harm. They have a right to believe these practices -- these protective sessions -- these protections are practiced on every flight. Today tragically we consider the events that took the lives of nine people on board this flight, including both flight crewmembers. Protections built into the system were not applied, and they should have been. We hope by learning from the facts that led to this crash we can recommend changes to prevent such figures in the future.
Good morning members of the board. I would like to ask the audience that if they haven't already to silence their cell phones. There are two exits to the front of the auditorium, one to the left, and one to the right. Go down the stairs and out the door and follow the only exit signs to depart the facility. You may exit through the rear of the auditorium. Once you have exited, please turn left and follow the sidewalk to the end of the street. If there is an emergency we ask you walk quickly to the nearest exit and make it to the outside following the instructions of the NTSB staff personnel. Seated at the table this morning, starting to my right, the Director of the Office of Aviation Safety, the investigator in charge of this accident, Captain David Lawrence, operations, human performance, and carpet voice recorder. Seated behind the doctor is from the Office of Safety Recommendations. Next is airplane performance, the Director of Office of Research and Engineering, our general counsel, And our Deputy Director of Safety and Communications. Seated behind him is -- to his right, Maintenance Records, next is Meteorology, the writer of this report and finally Brian Murphy, Structures.
Good morning. On November 10, 2015, a hawker 700 operated type Execuflight crashed during a non-precision instrument approach at the Akron International Airport. The airplane was operated as a part 130 five on-demand charter flight. The airplane was destroyed by impact forces and a postcrash fire. The captain, first officer, and several passengers were fatally injured. The apartment building was destroyed as a result of the airplanes impact. No one on the ground was injured. A flight rules plan was filed. The captain was the pilot monitoring, and had a total time of 6000 hours, and 1000 hours in a hawker 700 and 800 series airplane. The accident occurred on the second day of a planned two-day trip. The accident flight, which was the second flight of the day, departed from Dayton, Ohio for a 40 minute trip. The visibility was one point five miles with an overcast ceiling at 600 feet above the ground. The captain elected to have the first officer flight akron, contrary to the executive flights formal practice of the captain acting on a flight. The flight crew began preparing for a non-precision localized approach to runway two hundred five -- runway 205. The ensuing approach briefing was unstructured, inconsistent, and incomplete. And the approach checklist was not performed. Prior to the final approach fix the first officer began slowing the airplane, likely due to concerns expressed by the captain about another aircraft that they were falling on the approach. The first officer placed the airplane in danger. Although the captain recognize the situation, he never took control of the airplane and allow the first officer to continue. The first officer elected to use flaps 45 on the approach, contrary to the profile that required the airplane to be flown at flaps 25. It was contrary to the training both pilots received a non-precision approaches. The captain did not question first officer's decision. And further he met that he failed to make the flaps -- after configuring the airplane for landing the flight crew was required to accomplish a checklist for procedures. Yet the cockpit voice recorder indicated they never completed the. This slide shows a profile view of the airplanes approach to Akron. The green line represents a constant rate of descent on the final approach to the minimum descent altitude. The black line represents the MDA. The airplane approach fixes 400 feet higher. Because it was on the approach, it was out of position to use a normal descent rate. The airplanes rated descent was twice the rate . The dissent was contrary to procedures for a stable approach. Although the captain recognize the first officer was descending the airplane too fast and the approach was unstable, he did not call for a -- during the approach the captain failed to make any of the required call ups to alert the first officer and the captain allow the first officer to bring the airspeed to fall below the minimum descent altitude. Instead of leveling off the first officer continued to dissent when the captain said keep going. There was no call out on the cockpit voice recorder that indicated the -- indicated they had the airport or runway in sight. About 14 seconds after the airplane descended below the mda, the captain instructor the first officer to level off. As a result of the increased drag due to the improper flaps 45 configuration, the airplane entered into a stalled condition when the first officer attempted arrested dissent. After the captain's instruction to level off, the cockpit voice recorder recorded the first sounds of impact. This is an aerial view of the accident site, with the runway 205 visible in the upper part of the photograph. The airplane crashed 1.8 not a cold miles from the approach -- 1.8 not to cold miles -- 1.8 nauti cal miles from the approach runway. This is a view of the fuselage and engines resting on the embankment behind the apartment building. There were pre-impact structural or system failures. The pilots were properly certificated and there are performance was not impaired by alcohol, drugs, or anything else. Lack of a requirement for flight data -- lack of a requirement for safety management systems for part 135 operators, lack of a hawker and non-precision approach procedure that meets the stabilized approach criteria , lack of a requirement for flight crew training , inaccuracy of data , inadequate FAA surveillance, and inadequate cockpit voice recorder maintenance procedures. I would like to acknowledge everyone who participated in this investigation. The vice chairman was an on-site board member. Board staff was assisted by representatives from the FAA, Execuflight, Honeywell International, and the National Air Traffic Controllers Association. Captain David Lawrence will next discuss operational issues followed by organization all -- by organizational issues. Captain Lawrence...
Good morning, I will discuss the pilot's backgrounds, preflight planning, conduct of the approach, and FAA oversight. Both having previously been terminated from their most recent employer, records indicate the captain's previous employment had been terminated for failure to show up for recurrent training. The first officer had been fired from his previous employer for significant performance deficiencies identified during his simulator training for months prior to being hired. Execuflight was aware of the officers previous deficiencies. 14-cfr part 135 -- pilots conducted their own flight planning and followed an account on a website. The weather forecast called for instrument conditions at the time of arrival. Though the flight requires an auction to be filed , records indicate the crew never filed one. The crew incorrectly calculated their weight by using an inaccurate basic operating late, incorrect passenger and baggage weight, and incorrect fuel weight, contrary to company procedures. Execuflight management was required to ensure the accuracy of the flight plan and the weight and balance prior to doing so. Sop's are widely recognized as an element of safe aviation operation and are an effective countermeasure against operational errors. The crew repeatedly ignored important procedures. As discussed earlier, the flight crew failed to adhere to company policy. These include a failure to include the approach checklist and landing checklist, failure to make the required out suit callouts during the approach, and flew an un-stabilized approach with an unapproved and untrained flap configuration. Execuflight had no means to monitor the daily operations of its airplanes, identify operational deficiencies, such as noncompliance with SOP's, and correct those deficiencies before an accident occurred. In addition to this accident, NTSB has investigated part wanted five accidents in which the operator has lacked the means to monitor routine flight operations. Flight data monitoring systems installed on the aircraft can provide valuable data that can allow an operator to detect trends of noncompliance within procedures. Helicopter emergency and medical service operators are now required to installed such flight data monitoring systems. Operational flight data monitoring programs can provide part 135 operators with objective information regarding the manner in which their pilots conduct flights and a periodic review of detecting and correcting unsafe deviations from company sop's. The staff has proposed recommendations in this area. The nonphysician approach profile that hawker pilots were trained on , once landing was assured. According to interviews, simulator instructors had different interpretations from what landing a shirt met and how the pilots should use that term when deciding to begin their final to send. The staff has proposed recommendation in this area. In addition, non-precision approaches typically require a level off at about 500 feet above the ground. The hawker profile called for a reconfiguration of the airplane. Such a fake -- such a configuration changed at a low altitude. Staff has proposed a recommendation in this area. Execuflight hawker pilots were trained to dissent on a non- -- involving multiple step downs within the final approach fix. Commonly referred to as i've and drive by the red line. Dive and drive approaches have it ended -- have a history of increased risk . The FAA encourages to use of continuous descent approach. A technique that provides a constant rate of descent inside the final approach's -- final approach fix. It approaches a more stable approach. Even though the FAA states is the more safer alternative to dive and drive, they do not require pilots to be trained on the technique. They continue to use dive and drive has means of not -- and staff has proposed recommendation in this area. The principal operations inspector responsible for oversight of the execuflight primarily used scheduled reviews of the company's manual and the occasional line check of the captain to conduct his surveillance of the company. The pilot had not attended ground school or simulator training and was unaware of deficiencies in their training at the parker pilots. The pilot had not conducted a check on any of the operators he saw. Even though inspector guidance states inspections are one of the most effective methods -- as demonstrated by this accident, the oversight system was ineffective in correcting noncompliance smp's and part 135 operators. The faa is now implementing and oversight system . It could help identify operators that failed to comply . The staff has proposed recommendations. This concludes my presentation. The doctor will discuss the organizational issues.
There were multiple deviations from standard operating procedures that occurred. Deviations were not found on part of the right -- found on part of the flight crew. The pilot records improvement act requires that before allowing an individual to be in service of a pilot, a hiring air carrier must request, receive, and evaluate records from previous employers pertaining to that individual performance of the pilot. In this case both the captain and the first officer have been terminated by their previous employer, however no follow-up was made by executive flight to evaluate the terms of their termination. Staff believe because executive flight did not fully evaluate the information it had concerning the first officer's training difficulties at his previous employer, the company missed an opportunity to determine whether the first officer was capable of operating an airplane safely. Although both pilots had recently completed executive flights management training program, the crew's action during the flight revealed ineffective coordination and inefficient responsibilities, failure to make checklists, failure to call out, and poor pilot briefing. Execuflight's crm training program -- in addition the program included a multiple-choice crm test. The captain's uncorrected test score was documented by the chief pilot as 100%, however on comparison the captain actually received an uncorrected score of 40%. This example highlights the check the box approach by execuflight that minimizes the importance of teamwork, communication, and safety. The investigation also revealed an insufficient rest. -- rest period for the officers that occurred three days before the accident. As a result of improper crew scheduling that did not provide the first officer with adequate rest on the preceding trip, the first officer was likely experiencing fatigue, which may have exacerbated his performance deficiencies during the flight. This event highlights the lack of oversight i company management. In this case the flight that was in exceedances was a captain -- whose role was ensuring compliance. Execuflight's management's casual attitude likely set a poor example for their pilots and sets their regard for operational safety. Execuflight lacked a safety management system, or sms . Sms has been recognized as an effective way to establish and reinforce positive safety culture and identify deviations from sop so they can correct it. In response to key accidents come involving part 21, 191, -- in 2015, the FAA issued a final ruling requiring SMS programs to part 121 carriers. In its final rule, the faa stated its intent in developing part five was to establish a uniform standard that could be extended to other operating parts, including part 135. In the seven years since the first SMS recommendation was made for part 135, and the 20 once -- 20 months since part -- was established -- accident related to organizational culture are preventable. Yet part 135 accidents tight operational safety issues continue to occur. This accident is just one example of many in the past years. Staff believes all part 25 operators would benefit from sms programs, because they would require operators to comply with formal safety methods. Staff has proposed a recommendation in this area. Thank you. The doctor will continue.
Good morning. I will discuss issues related to the cockpit voice recorder. The accident aircraft was required to be equipped with a 30 minute cockpit voice recorder, but not with a flight data recorder. The accident aircraft was equipped with a tape-based cvr built in 1989. The cvr was overhauled in accordance to the cvr manufacturers instructions. On may 13, 2015, and inspection was performed, including a functional check of the cvr. Although the cvr, shown on the left, experienced heat damage as a result of the accident, the tape, shown here on the right, was undamaged. Despite the lack of damage come of the recorded audio was of poor quality. Meaning that even after extraordinary means were used to remove background noise, the transcript still contains many fragmented or unintelligible conversations. The poor quality was attributed to interference from the aircraft ac electoral generators and significant background noise. After the accident execuflight determined in other cvr installed in a nether hocker aircraft was inoperative, and they replaced it with an overhauled cvr. Most recommendations related to cvr quality issues date back to 2002. Our 2002 recommendation was superseded in 2006 and finally closed eight years later in 2014. The faa issued a safety alert for operators prior to the first flight of the day, and updated faa order 180.1 to provide guidance for FAA maintenance inspectors respectively. The FAA's principal operation inspector was not aware of -- and stated he had no responsibility for cvr oversight. However, no power was available to the aircraft and he could not require the aircraft to be powered, so the cvr was not tested. Generally the inspector comments that the cvr's are not tested with engines running. For the accident aircraft, most of the quality issues would have been detected only if the cvr had been tested with the engines running. Despite the faa's actions, the board continues to receive quality issues. The ongoing investigation of the august 2015 collision revealed a taped-based -- tape-based cvr was not able to save old content before rewriting new content. In February 2014 -- the NTSB has also received inoperative cvr's from other aircraft, such as -- both in 2008. Even the newly recertified boeing 787 had for cvr quality. About at the time of this accident, the FAA was working on updating the standing cvr -- last issued in -- the board provided compounds . On July 20 2, 2016 the FAA released advisory circular 20 -- -- 20-186. As this new advisory circular is not a regulatory, staff is concerned how the ac will be used impact us. Staff believes that having an adequate functional test of the cvr being performed with the engines running, or by reviewing cvr content from an actual flight, the poor quality of the cvr recording may have been detected and corrected. Staff has proposed a recommendation in this area. This concludes our presentation. Staff is ready to answer any questions you may have. Thank you.
Thank you for your excellent and comprehensive presentations. We will now begin the question and answer segment.
Good morning, I know oftentimes we say we want our -- we should to have our investigation completed within a year, and you certainly have done that and i want to congratulate you and your team for putting together a very good investigation and doing it in a timely fashion. So thank you. I think the chairman already alluded to this. I go out and give presentations on -- and the title of the presentation is, "our customers getting what they expect?" often we find out they are not getting what they expect. Customers expected a professionally managed aircraft. As we have already laid out, they did not get that. The company, execuflight , had a casual attitude toward standards and compliance. Page 89 of the report says the repeated deviations from sound operational practices identifies missed investigation to identify a culture of complacency. The customers also expect a professionally flown aircraft and they didn't get that either. The crew mismanaged the approach, they had multiple deviations from standard operation procedures, including deviations from the standard federal regulations. There were a litany of failures involved in this accident. In my line of questioning this morning, we will look at the company, the pilots, the very act of congress , the pilot records improvement act of 1976 that was supposed to allow employers have accurate records of pilot previous employment, and finally the regulatory oversight. Let's start with the company. I think the doctor has covered many of the organizational issues. Let's talk about some maintenance related issues that may have nothing to do with the actual causation of the accident but shows a pervasive lack of disregard -- or disregard for doing things right. Captain lawrence, perhaps you would be the one to answer this. I believe the weight and balance document showed the ap you -- the ap u was removed from the aircraft in 2014. If that correct? -- is that correct?
The APU was removed from that airplane.
Did the books reflect that it was removed?
We could not find any record stating that it was removed. And by regulation any major alteration or repair would have to be an entry in the maintenance records. Even a form of 337 .
There is an approved procedure for removing the APU , but yes maintenance record would have been required.
And they were not that we could find? Once it was finally replaced in 2015, the weight and balance , were those amended? so when it was removed in December, they reflected a 300 pound loss from the APU. But when they reinstalled the APU, did the weight and balance records reflect that?
The weight and balance records that were found on the aircraft -- even though we found the apu in the records.
Is that not legal to have your weight and balance be correct.
No, it is not, there is some conflicting testimony as to whether or not the first officer was scheduled legally for a particular flight. On a previous flight a couple of days before this crash, he was supposed to have had 10 hours of rest period. Our records show he only had seven hours 45 minutes of rest.
Yes, when we first did the analysis we used the flight logs that Execuflight had provided to us, which reflected and on-duty time for the first officer of 3 p.m. Prior to that day. In this case he flew two flights, and a second flight was an overnight flight to mexico. At the end of that overnight flight , he had seven hours 45 minutes of rest according to those flight loss -- flight logs. We had conflicting information coming and where the president of the company stated the first officer did not go on duty until 5:15 that day, which gave him absolutely 10 -- which gave him 10 hours of rest. There is evidence that provides contradictory information to what the president has said.
I think you have hotel receipts that shows they checked out of that hotel .
It was 1200 9 p.m. -- it was 12:09 p.m.
We don't normally takes one testimony unless it was an investigative hearing. We have sworn testimony from the captain who flew with the first officer , and we have sworn testimony from the president of the company and they are showing conflicting things. It probably means one of two things, somebody's memory isn't correct and somebody is not being truthful. I will come back to more issues and get back to the pilot in the next round of questions.
Thank you and good morning. In the chairman's opening remarks he talked about the crew research management training , a rather cavalier approach to the training. Documenting completion rates that were 30%, 100%. The NTSB courses had a long history of recommending crew research management. In fact previous toward members were instrumental in developing and implementing crew research management. In this case it appears the crew resource management was not very effective training. -- effective. Training was not complete. Recommendations for training with crew members together were not implemented. In this particular case the captain was very reluctant to step in. He had observed the opening getting slow. Of he had won the first officer against stalling it. He did not take over or exercise as command authority. Does the CRM address that?
The training would have addressed that. It was technically in the requirements, which was covered in the pratt -- covered in the powerpoint presentation. The questions the captain had missed, we saw deficiencies in terms of the captain's understandings of the responsibility and authorities. We saw deficiencies in flight deck management. Those were the questions that were missed.
I guess it wasn't questioning in the particular cases of this accident. The captain was the pilot monitoring, the first officer was the pilot flying. Checklists were incomplete. Two captains make poor pilot monitoring? -- do captains make poor pilot monitoring?
I believe the study you may be referring to is a 1994 study on accidents related to crew -- to crewed deficiencies or performance issues. In that study what was found was that there was a higher percentage of accidents that the pilot flying was actually the captain. In this case we don't necessarily think the study would apply here, because the caption was pilot monitoring. It should also be mentioned this is why you have crm training. This is what has been recommended .
Let me move to safety management systems. Safety management systems have been really acknowledged as part of the tools that have led to the real dramatic improvement in part 121 commercial airline flying. But they have not been applied to are required in part 135. What would a safety management system have been for this particular operator and accident?
The safety management system gives the company structure to actively manage the safety. In this case, implementing the components of safety policy and making sure there are documents, there are objectives that are clearly defined for the entire company would have set the stage for the entire company in terms of their commitment to safety. An sms provides a to cool for safety risk management reporting. If a pilot may have had an issue , such as procedures weren't being followed, there would have been a nap and new -- then an avenue to take that to company management. -- there would have been an avenue to take that to company management. Maybe advocating following sop's . Flight data monitoring is one way to do that. In addition to the safety aspect there is the safety culture in terms of the company. All of these components are implemented and the company could have had an effect on the issue we saw here, one of the many issues.
Flight data monitoring is one of the sources of information for safety assurance, as well as risk assessment. Would not having a flight data recorder on board the aircraft , how would safety assurance be accomplished without data?
There are multiple ways to accomplish safety assurance and continual assessment of data. Another way is getting feedback from pilots on your flight. In a way that is not implemented over require a recorder in the cockpit.
I will yield the rest of my time for this round.
To begin i would like to thank staff for their excellent work on this investigation and the report. This is my first on scene experience , and i appreciated all the NTSB staff and FAA staff for taking the time to help me learn more about part 135 operations. I was impressed with the professionalism and compassion. Coming from a surface transportation background, i equate part 135 operations to limousines or taxis in the sky. The people who hire these operators do so with the expectation that they are going to be on par with a part 121 air carrier operation. Tragically that is not always the situation. I would like to start my questions by asking about part 135 operations to help us and the public understand better the sense and the scope of these issues on safety. First question is to you, how many part 135 operators are there in this country?
Currently there are 2061 operators flying part 135, that would include 11,231 aircraft. That also includes helicopters and airplanes.
Could you provide me a rough breakdown of flight hours both on-demand and scheduled hours ?
Part 135 on-demand is about 300,000 -- scheduled is 300,000 and on-demand is 3.7 million. Almost 4 million part 135 flights are flown each year.
How many hawkers are in service?
The number flying 135 certificates are -- there are 853 registered in the united states under part 91. And in our service worldwide there are 3058.
Thank you. Of those in service here in the u.s. , how many of those are the different types? 700 a, 700 a1?
94 of those 272.
Thank you. How many of them operate under part 135? i know you mentioned that in the course of your answer?
Currently there are 272 hawkers.
And the others are under part 191? I have some questions for you about flight data monitoring. Can you tell us why you think the new proposed recommendations about flight data monitoring are so important?
Certainly. One of the challenges the faa has in their oversight of part 135 on-demand is just the nature of the business. They don't know when it is going to go out. Since it is on-demand the faa has a hard time trying to do route inspections, at inspections. Operators have a hard time understanding what actually is going on with the operation outside the training environment. When the airplane leaves the base and flying revenue flights, unless somebody is writing on the jump seat or observing there is no way to understand what has been done on a day-to-day basis with the operations. Flight data monitoring program would be able to take that data in on a regular basis, analyze that, and identify any deficiencies , such as noncompliance with sop's. The operator can then go into the training procedures and adjust those indication elements they found in the operation.
The sort of data, if there was a flight data monitoring program, that would raise red flags would be unstable lysed approaches or not following sop's. Are there any other types of information that would help monitor the data?
There is a litany of elements that they could be looking at. Maybe power settings or temperatures that are in exceedances recommended -- exceedance of recommended takeoff procedure. If flight operations quality insurance is a more structured program with the airlines, but it is the same principle of collecting data.
Thank you captain. Mr. Marcus? Would you identify some examples that illustrate how a program like this has been used to identify safety issue?
We recently had a board meeting about an accident that occurred in Bedford, Massachusetts. The pilots had not removed the locks before the takeoff. As a result the played -- result the plane was not able to take off, crashed, and killed everybody on board. That is something that should have been readily apparent to the pilots before they started their takeoff . For a second or two they moved the controls to a full range of motion . We issued a recommendation to the National Business Aircraft Association, which has been working with some of their members who have flight data monitoring programs. We ask them to go through and analyze their data to see whether or not the lack of preflight checks was a single crew who fail to do it or whether it was a systemwide problem. A year after we issue did a month ago, they send us a copy of the report and found that only 20% of their flights that they reviewed was there a preflight check done. That is an example of illustrating a problem people are not aware of when you have the data and can do the data -- do the analysis.
Thank you. In light of what Captain Lawrence said about the challenges in doing this type of work, flight data monitoring seems essential.
Yhank you. I have a couple of areas i would like to cover. What did you say about the studies and what they showed?
The data that was shown in the study showed there was a higher percentage of captains operating as pilots flying in the accidents. In this case because we have the captain here , we wouldn't want to make the extension about the results of that study.
Were be able to make a comparison as to how much the pilot in command is flying versus -- can we get some exposure number to see the accidents were likely to be -- is that because they are more likely to be flying then a second in command?
In the study they had actually taken out cases where the captain may have taken over some aspect like that.
Thank you. What I would like to go into at a high-level is data monitoring process flight data recording. I would like to give an overview of what the flight data recorders issue was. Can anybody give me a high-level overview of that?
I can talk about the flight data recorders, they are not required right now. The recommendation the staff proposed mirrors the flight data monitoring program that is required within the emergency helicopter services. The regulations say these helicopters have to have the recorder in there, but the FAA didn't go as far as requiring any type of program that required an analysis of that data. Our proposed recommendations aren't just to put the quarter in the 135 demand. But also a program that can actually analyze it. I would defer to Mr. Marcus.
To what extent 135 operators are now required to have flight data recorders, is it only the larger ones? what is the story?