ANC12GA114

The pilot's failure to maintain directional control while landing, which resulted in a collision with the water. Contributing to the accident were the pilot's lack of experience conducting waterborne operations in the accident make and model airplane and the public aircraft operator’s lack of training standardization.

The pilot was landing an amphibious float-equipped airplane in a lake on the final leg of a 4 day, public-use wildlife survey. The pilot stated she had not conducted a water landing recently, so she elected to land on the water to maintain proficiency. Before landing, the pilot completed the before landing checklist, set approximately 50 percent right rudder trim, and confirmed the wheels were in the up position. She noted that her airspeed on approach was slightly faster than normal. During touchdown, the airplane veered to the left and then to the right. The airplane then veered violently to the right, as though it "caught a float," and the right wing struck the water. The airplane then pivoted abruptly to the right, cartwheeled, and the wreckage began to sink. An NTSB postaccident examination of the airframe and engine revealed no evidence of mechanical malfunctions or failures that would have precluded normal operation. Because the airplane was operated as a public aircraft operation, the Department of Interior's (DOI) training program was not subject to the civil aircraft requirements. An NTSB review of the flight training program revealed a general outline with hour requirements. The flight training program did not include curriculums, events, or testing and checking procedures. No written maneuvers and procedures guide, with acceptable performance standards was developed, therefore no standardization existed within the pilot group, and tribal knowledge and experimentation were accepted as part of the organizations culture. Multiple checklists existed for the airplane, and pilots were allowed to use whichever checklist they preferred. DOI did not/nor were they required to incorporate best practices and industry standards into their training program and airplane operations, and no FAA oversight was required or provided. Vendor pilot requirements were substantially higher with stricter standards, and required FAA oversight, compared to those of agency pilots flying similar missions. The pilot stated that, during her interagency pilot evaluation/qualification check, step turns were not completed. The pilot said that the check pilot was not comfortable performing the maneuver, so they agreed to sign off the maneuver on the check ride form but did not accomplish the task. Although the pilot had logged 232 hours and 68 water landings, only 2 water landings were logged without an instructor onboard.

Pilot Requirements The DOI Departmental Manual, Aviation Management, Part 351 Aviation Operations, Chapter 3 Flight Crewmember Policy, 3.2 Pilot Qualifications states in part: Pilots shall meet the following minimum rating, and experience requirement prior to flying operational missions. Incidental/Dual Function: Commercial Pilot Certificate with appropriate category and class ratings, Instrument Rating, Recent Flight Experience as appropriate (14 CFR Part 61), VFR 500 hours Pilot in Command (PIC), 25 hours PIC night, 24 hours PIC last fiscal year in category, 10 hours PIC in make and model, and 25 hours PIC in seaplanes. Vendor Pilot Qualifications: Shall meet the PIC requirements of 14 CFR Part 135; 1500 hours total pilot time, 1200 hours PIC time, 25 hours PIC in seaplanes, and 100 hours in the last 12 months. Training Program Prior to operating aircraft for the DOI, a pilot must complete certain flight training requirements. An aircraft make and model checkout requires 10 hours of flight time in the specific make and model to be operated. The turbine aircraft training module requires 50 hours in make and model. The floatplane operations training module requires 10 hours lake and general float operations, 10 hours river and stream operations, 5 hours for ocean and saltwater operations, and 10 hours for amphibious float operations. If a pilot has accumulated 25 hours or more of seaplane operations, the hour requirement is waived, and the pilot must only meet the standards of the module with no hourly requirement. In order to operate the Kodiak 100 on amphibious floats for the DOI, the pilot must have completed a minimum of 50 hours flight training. An in depth review of the DOI flight training program revealed a general outline with hour requirements. The flight training program did not include curriculums, events, or testing and checking procedures. No maneuvers and procedures, or acceptable performance guidelines were developed for the amphibious float-equipped Kodiak 100. The flight training for the Kodiak 100 was recorded on the "Seaplane Instruction Form" grading is accomplished by placing a number next to the maneuver that was performed: 1 = Below Acceptable Standards, 2 = Improving/Below Standards, 3 = Satisfactory, 4 = Above Average, 5 = Excellent. No grading was used on the accident pilot's Kodiak 100 flight training record, a check mark was placed next to the maneuver that was performed. The DOI had not developed or written any specific procedures for the Kodiak 100. According to the Chief Pilot/Training and Standardization Manager for the Alaska Region, Office of Aviation Services (OAS) who is responsible for conducting training and checking for DOI, multiple checklists existed for the Kodiak 100, and pilots were allowed to use whichever checklist they preferred. Government Aircraft Operations FAA Advisory Circular (AC) 00.1-1, "Government Aircraft Operations," dated April 19, 1995, provides "guidance on whether particular government aircraft operations are public aircraft operations or civil aircraft operations under the statutory definition of public aircraft." As explained in the AC, an operation is considered public or civil depending on the circumstances of the particular operation rather than the ownership or overall use of an aircraft. Generally, public aircraft operations include law enforcement, low-level observation, aerial application, firefighting, search and rescue, biological or geological resource management, aeronautical research, national defense, and intelligence missions. During the NTSB's February 2009 public hearing on the safety of helicopter emergency medical services operations, FAA representatives testified that, with the exception of operations within the National Airspace System, the FAA has no statutory authority to regulate public aircraft operations. Title 49 United States Code Section 44701 is the primary authority for federal aviation regulations. This section instructs the FAA administrator to promote the safe flight of civil aircraft in air commerce through regulations and standards prescribed in the interest of safety. Unless a government-owned aircraft is engaging in a civil operation, it is not subject to civil aircraft and pilot requirements pertaining to certification, maintenance, and training. During an interview with the NTSB IIC on October 3, the Chief Pilot/Training and Standardization Manager for the Alaska Region, Office of Aviation Services (OAS), who conducts training and checking for the DOI, stated that the Kodiak 100 on Wipline 7000 amphibious floats had a left-turning tendency when the propeller was in beta and that the water rudders could be deployed if directional control was needed once coming off the step. He also stated the Kodiak 100 on Wipaire, Inc., Wipline amphibious floats was not a "beginner's airplane" and tended to be unforgiving. During a telephone conversation with the NTSB IIC on October 3, the Senior Flight Instructor for Lake and Air, who conducted training for Wipaire, Inc., stated that, as the Kodiak 100 on Wipline 7000 amphibious floats came off the step, there was a left-turning tendency when power was applied to the propeller. He also stated that he did not condone nor recommend deploying the water rudders with the airplane still on the step. FAA Order 8900.1, Volume 3, Chapter 19, Section 1, Scope, Concept, and Definitions states in part: Training program - "A system of instruction which includes curriculums, facilities, instructors, check airmen, courseware, instructional delivery methods, and testing and checking procedures." Curriculum - "A complete training agenda specific to an aircraft type, a crewmember or dispatcher duty position, and a category of training". Event - "An integral, task- oriented part of training, checking, or qualification module that requires the use of a specific procedure or procedures. A training event provides a student an opportunity for instruction, demonstration, and/or practice using specific procedures. A checking or qualification event provides an evaluator the opportunity to evaluate a student's ability to correctly accomplish a specific task without instruction or supervision. The closest weather reporting facility is Ted Stevens Anchorage International Airport, approximately 1 mile west of the accident site. About 8 minutes after the accident, at 2353, an aviation routine weather report reported in part, wind calm, visibility 10 statute miles, few clouds at 6000 feet, scattered clouds at 13,000 feet, scattered clouds at 20,000 feet, temperature 45 degrees F, dew point 29 degrees F, and altimeter 30.02 inHG. The airplane was manufactured in 2009 and registered to the owner in September 2010. It was equipped with a Pratt & Whitney PT6A-34, 750-shaft horsepower turbo-propeller engine and a Hartzell HC-E4N-3PY/D9511FS four-blade propeller. The airplane had accumulated 284 hours at the time of the accident. Its most recent annual inspection was completed on May 31, 2012. The airplane was manufactured with fixed tricycle landing gear and received Supplemental Type Certificate (STC) approval for the installation of Wipaire, Inc., Wipline 7000 amphibious floats in June 2010. The float installation was completed on July 8, 2010, and the airplane had accumulated approximately 245 hours of flight time since the installation. The pilot, age 36, was a dual-function pilot (pilot/biologist) for the DOI, U.S. Fish and Wildlife Service. She held a commercial pilot certificate with ratings for airplane single-engine land and single-engine sea. She reported 1,650 total hours of flight experience, 550 hours which were in seaplanes. She had accumulated 232 hours and 68 water landings, 66 of which were associated with training or ongoing proficiency accompanied by an instructor in the Kodiak 100 equipped with amphibious floats. Her most recent FAA second-class medical certificate was