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The NTSB deflected blame to the FAA, claiming the FAA provided inadequate oversight of National's military 'special cargo' procedures. www.AviationPros.com 63 The probable cause started correctly, finding National's cargo loading procedures insufficient. However, instead of pursuing contributing factors, the NTSB deflected blame to the Federal Aviation Administration (FAA), claiming the FAA provided inad- equate oversight of National's military 'special cargo' procedures. Why didn't the FAA do surveillance? The State Department doesn't allow the FAA to conduct surveillance inside war zones. The recommendations began with A-15-13: Rewrite or revise Advisory Circular (AC) 120-85: Air Cargo Operations. Pushing this recommendation first demonstrates the NTSB's confusion with what an AC does. Although Advisory Circulars are considered guidance, they are advisory — not regulatory. ACs are normally employed during the air carrier's certification phase, prior to approving/accepting their programs, procedures or limitations. Furthermore, operators are not required to follow an AC if their plan is better. Five other recommendations proved ineffective, as well. A-15-14 proposed creating job specifications for an uncertificated position: Cargo Load Master (CLM). A CLM, or any job title resembling this, is a position defined by, e.g. the air carrier's operations manual, which, if they run charters, has already been approved. A-15-16 and A-15-18 suggested beefing up guidance, amounting to using stronger language. A-15-15 was a productive recommendation: Revising FAA Order 1800.56O to review all air operators' weight and balance manual procedures. However, A-15-15 ignored the DoD's involvement in the auditing process, thus overlooking a major contributor to this accident. A-15-17 demonstrated the Board's inexperience. The NTSB rec- ommended providing initial and recurrent training for "Principal inspectors who have oversight responsibilities for air carrier cargo handling operations …" A principal — whether operations, avi- onics, or maintenance — has already received training before they take the position; cargo handling procedures are part of any certificate course, whether a passenger or cargo air carrier. Recurrent training is a broad term. All aircraft, e.g. general aviation, Part 135, or Part 121, carries cargo in some form, so oversight of these operators is the best form of recurrent train- ing. Certifying operators is involved; the FAA cannot revoke certification without just cause. What about the FAA; how would they comply with such a recommendation? All air carrier and repair station FAA principals receive certification training; it takes them through the whole certification process; instruction supplemented with regulations and guidance. The FAA Academy does teach an Air Cargo course; it is a familiarization (FAM) course — not certification. Cargo air carrier certification is no different than passenger air carrier certification, whether Part 121 or 135; the only difference is how one uses the seat tracks. Another point: Air cargo is an operations-intensive industry. Airworthiness's part is limited to manufacturing, modification, and maintenance of the aircraft and cargo components. Operations deals with everything and everyone else; from training to loading to scheduling, Operations controls every aspect of the air car- rier's cargo movements. Without understanding this, the NTSB is putting all principals in the same boat. This accident investigation was phoned in from the start. The DoD will hopefully learn from these mistakes to prevent another accident. The NTSB had an opportunity to make good solid changes; it instead settled for an incomplete report, wasting a chance to make right a curable problem. This investigation let the entire aviation industry down. AviationPros.com/company/12274364