The new balloon commercial ops medical regulation - a natural experiment?

[PeterNSteinmetz]

I strikes me that the new regulation for a medical for commercial balloon operations may provide an opportunity for a natural experiment.

One can measure the rate of such accidents and fatalities prior to this regulation being put in place and after.

But what may well be the case is that these sort of events are so rare that it will be statistically impossible to show an effect, at least in less than 100 years or something like that. Has anyone computed the rate of serious balloon accidents and fatalities over the time period the NTSB has been recording them? I know that I only very rarely hear of such a thing.

 

[rotorwrench]

I strikes me that the new regulation for a medical for commercial balloon operations may provide an opportunity for a natural experiment.

No experiment needed. Just read the docket for the new regulation. It gives the basis for the new rule and a link to the law that required the revision to the rule. Every new reg goes through the APA process to include ADs unless it is an emergency issue. The dockets give the reasoning with any applicable stats, cost of the change on the industry, etc. However, the reasons behind a new rule are not always quantitative in nature, to use the term loosely. Sometimes it just takes the wrong person to get killed or the wrong public optic to get congress to act. That was part of the reason for the Commercial Balloon Pilot Safety Act of 2018. Another example, is the reason there are ELTs in every aircraft. If a couple important congressmen hadn't gone missing in the 70s, and are still missing, I doubt there would be a Part 91 requirement. Rules have their place. Are all rules good? No. But adding a medical requirement and certain maintenance oversights to various non-135 "commercial" ops is a good thing from my industry perspective. Speed limit signs don't stop people from speeding, but they at least make them think about it before they do.

 

[PeterNSteinmetz]

I think one needs to actually look at the data to make rational determinations about the effects of these regulations. Otherwise we have laws and regulations based on qualitative guesses. Not in my view a particularly good reason to start pushing people around with threats of violence and actual violence - which is what all laws and regulatory enforcement are in the final analysis. That part is a difference in our moral systems.

The part that is analyzable is what data exists and can they tell us anything statistically. I will have a look at the docket on this one to see what reasoning or data was presented. Thanks for the pointer. But as you note, these things are not often done based on quantitative or even semi-quantitative reasoning.

 

[Jim Logajan]

Sorry for this diversion, but in 2006 I bought the 1999 book "Ballooning" by Smith and Wagner. It has a chapter on ballooning accidents up to that time. Rather than quote from it, I'll bend copyright and post some pictures of those chapter pages. It's got some nice photos.

 

[PeterNSteinmetz]

Sorry for this diversion, but in 2006 I bought the 1999 book "Ballooning" by Smith and Wagner. It has a chapter on ballooning accidents up to that time.

Hardly! Seems spot on. Would you be able to determine the source he references for the rates? Cameron? That might be in the back of the book in an appendix.

11 deaths per million flights is rather rare. Though apparently the rate of any kind of accident is quite a bit higher. That might be easier to measure.

 

[Jim Logajan]

Hardly! Seems spot on. Would you be able to determine the source he references for the rates? Cameron? That might be in the back of the book in an appendix.

11 deaths per million flights is rather rare. Though apparently the rate of any kind of accident is quite a bit higher. That might be easier to measure.

No index or bibliography in the book. Those stats look to be compiled by Cameron from unknown sources.

 

[PeterNSteinmetz]

Looking a bit more for it, this appears to a balloon making company named Cameron. I have submitted an inquiry about any report or data they may have.

Also, here is the link to the notice of proposed rule making for this new regulation - https://www.faa.gov/sites/faa.gov/files/2021-11/2120-AL51_Issuance_NPRM_Balloon_Medical.pdf

 

[Jim Logajan]

Looking a bit more for it, this appears to a balloon making company named Cameron. I have submitted an inquiry about any report or data they may have.

Also, here is the link to the notice of proposed rule making for this new regulation - https://www.faa.gov/sites/faa.gov/files/2021-11/2120-AL51_Issuance_NPRM_Balloon_Medical.pdf

It looks like the FAA was forced to act via a statutory mandate. So they did, expanding the medical requirement regulations only as much as needed to satisfy congressional requirements. For example, while they added the second class requirement for commercial balloon operations, third class medicals aren't required for non-commercial. Nor any medical to instruct in a balloon.

They at least are taking the NPRM as an opportunity to allow BasicMed pilots to act as safety pilots - something they couldn't do because of an earlier poorly written congressional mandate.