Carol Carmody left the NTSB in April after nearly five years as a member, two of them as vice chairman. During that time she served twice as the Safety Board’s acting chairman.

During her tenure on the NTSB, Carmody was the on-scene member at the 2001 crash of American Airlines Flight 587 in Queens, N.Y., and several high-profile general aviation accidents, including the fatal crashes involving Sen. Paul Wellstone (D-Minn.) and a Gulfstream III in Aspen, Colo.

Now back in the private sector as director of transportation initiatives for the National Academy of Public Administration, she can step back and make some observations about her former agency and the transportation modes it investigates.

One of her longstanding concerns has been about the FAA’s ability to oversee aircraft maintenance procedures. “The FAA will tell you–and I don’t disagree with the premise–that it cannot check every airplane, every workshop, every maintenance,” Carmody said recently during an interview in the academy’s Washington offices. “So it has to set up an oversight system that relies on good faith and relies on people following the rules and procedures.”

“And that’s fine as far as it goes,” she continued. “That said, I still think there needs to be an FAA presence and an FAA visibility, especially when you have things subcontracted out two or three times and nobody ever sees an FAA inspector.”

The FAA counters that it is the airlines’ responsibility to ensure that their maintenance is done properly. “Yes it is,” Carmody retorts. “But I’m a regulator at heart and I think we rely on the federal government to look out for us, and if the FAA is not looking out for us, who is?” The FAA is the government, she said, and it should be more vigilant about ensuring these things.

FAA Oversight

Carmody opined it is a matter of money and people, as evidenced by the current FAA budget discussions. “They don’t have enough money for inspectors,” she said, “and the money–if there is much–is going for controllers.” The agency is not hiring in the inspector workforce, she added.

In a number of accident investigations the Safety Board found inadequate oversight of maintenance by the FAA as a causal or contributing factor, and she described the 2003 crash of an Air Sunshine Cessna 402C as “absolutely chilling.” In that accident, the NTSB acknowledged that the FAA had done everything it was required to do, but clearly it was not enough for it to identify and address the problems at Air Sunshine.

“That’s what unnerves me,” Carmody said. “It’s not that the FAA doesn’t have systems in place and that it [doesn’t] have good inspectors; I think it needs more inspectors and I think it needs to ensure that whatever oversight system it has in place really exercises oversight and doesn’t just rely completely on airlines to comply.”

Carmody remains a strong supporter of the mandatory installation of video recorders to assist accident investigators in situations where no flight data recorders (FDRs) or cockpit voice recorders (CVRs) are required.

“There’s a very real frustration when you get to an accident scene and you don’t have any FDRs or CVRs and you are picking up pieces and trying to figure out what happened,” she explained. Video would enable investigators to see what was going on in the cockpit, what the pilot or pilots were doing and what the instruments were doing.

“The instruments are the key, and we’ve tried to tell the pilots this,” she emphasized. “We are not trying to catch the look on their faces, God forbid. We’re trying to see what they were doing, what their hands were doing, what the cockpit instrument panel looked like.”

Aircraft that don’t have any other recorders were the first ones for which the NTSB recommended cockpit video recorders, which are less expensive, less sophisticated and less difficult to install than cockpit voice recorders and flight data recorders.

“We have said for those aircraft that don’t have anything else–the charters, the 135s–let’s put that in,” she said. “Then we extended it– and again I don’t feel as strongly about it–to other aircraft that do have the recorders, which would be the Part 121s.” She said that latter recommendation was based on a few Part 121 accidents where a cockpit video recorder would have saved millions of dollars if investigators had been able to see what happened.

“But I think the ones we need are where there is nothing else,” she said. “It would be very, very helpful to the investigation, and by helping the investigation, you would be helping safety because you would get to the end of it more quickly, you would figure out what went wrong or what didn’t happen and you could make better recommendations. So I feel pretty strongly that needs to happen.”

In light of vigorous opposition from the Air Line Pilots Association (ALPA), Carmody suggested that the NTSB might eliminate ALPA’s objections if the recommendation did not include Part 121.

Runway Incursion Avoidance

During her tenure on the Board, Carmody made runway incursions a cause celebre. But she admitted that she has no suggestions about how to reduce runway incursions, which have been on the NTSB’s “Most Wanted” list since its inception in 1990.

“I made a lot of speeches about runway incursions and beat up on the FAA mightily,” she said, “because of its reliance on AMASS [airport movement area safety system],” which she called a perfectly good, useful system but one that does not go all the way. Now installed at about 30 airports, it notifies only controllers about runway incursions.

The NTSB continues to recommend that the FAA develop another system that alerts the cockpit at the same time that it alerts the control tower. “But then I have said in the meantime, ‘Why don’t you do some operational things, like some of these [warning light systems]?,’” said Carmody. “That seems to be very practical at big airports.” She added, however, that the FAA has rejected some of the operational procedures the Board suggested because the agency feels it would slow traffic.

Revamping Accident Investigation

Carmody also believes that the NTSB could improve the way it investigates accidents. One of those would be removing the requirement that it investigate every aviation accident.

The Board does not investigate every rail, marine or pipeline accident, but it is mandated by Congress to probe every aviation accident. In other transportation modes, the Board is at liberty to choose the ones that are going to teach it something.

“We don’t need to investigate every single aviation accident; we need to confine ourselves a little bit,” Carmody said. “Of course, in general aviation accidents we don’t do full-blown investigations, but still it’s staff, it’s people, it’s paper, it’s taking time to find what the cause was and write it up. So if we didn’t have to do all of those, I think it would be beneficial.”

Carmody is uncertain how that suggestion might be received in Congress, and it has been pointed out in the past that the high visibility of and interest in aviation accidents–sometimes called the “wow” factor–make it easier for the NTSB to secure its funding. “The wow work is not the small general aviation accident that happens every single weekend; nobody pays much attention to those, quite frankly,” she said. “And having to investigate them all is just excess work, it seems to me.”

Before joining the NTSB, Carmody held posts in the aviation community for 20 years, including serving as the U.S. representative to the International Civil Aviation Organization from 1994 to 1999.

“One of the things I learned when I was at ICAO is the esteem in which the rest of world holds the FAA and the NTSB,” she recalled. “We are really the premier agencies, and it’s pretty exciting to see that.”

But it results in the NTSB’s doing a lot of work on investigations around the world, even when a U.S. manufacturer or aircraft is not involved.

“We are frequently called in just to assist,” said Carmody, “and we usually don’t turn those requests down. But it means that our staff is stretched.”

While all that is positive, the NTSB is a small staff. “So obviously, I will make the pitch for more resources for the NTSB,” Carmody offered.