For those who are interested and for the record, a full English version of Polish comments to the Russian Interstate Aviation Committee's (MAK) draft report is published on the Internet. The document “Comments of the Republic of Poland as the State of Registry and the State of the Operator on the Final draft Report from the investigation into the accident involving the Tu-154M aircraft tail number 101, which took place on 10 April 2010, prepared by the Interstate Aviation Committee IAC” (172 pp.) is available to download at the address: http://www.freedom-speech-image.eu/files/Polish_Comments_IAC.pdf.
Sort of conclusion of the document:
Sort of conclusion of the document:
3.2. Causes
The only goal of the examination of the causes and circumstances of aviation
accidents, according to procedures and directions included in Appendix 13, is to prevent such
events from happening in the future. In the examination conducted by IAC, results of which
are included in the Report, the Russian side referred in detail to shortcomings of the Polish
side in preparation for the flight on 10.04.2010, training of the crew of the Tu-154M aircraft,
tail number 101 and the way in which the flight was conducted.
Information included in the Report, documentation given to the Polish side and an
analysis conducted by the Polish side indicate that there were many shortcomings in the
preparation of the Smolensk “Severny” Airdrome which contributed to a lowering of the level
of safety of flights made by aircraft of both countries to that airdrome on 7 and 10 April 2010.
The Russian side did not refer to those shortcomings in any findings in the Report.
There were many statements in the Report that the Polish side cannot accept or that are
not supported with sufficient evidence.
It also appears that some areas of examination of the accident were intentionally
omitted by the Russian side or their analysis was conducted superficially. An analysis of
recordings in the Report, regardless of the amount of presented documents and explanations
given by the Accredited [Representative] and his advisors, indicates that many of the
documents presented by the Polish side were analysed superficially and imprecisely, and
explanations given by Polish specialists that could have been helpful in understanding
transcription within those documents were not taken into consideration. As a result of which a
lot of information in the Report is not compliant with the facts. The shortcomings mentioned
above negatively affect the credibility of the message included in the Report.
In regard to this, the Polish side finds, that the proposed causes and circumstances of
the accident of the Tu-154M aircraft do not include all influencing factors. It concerns in
particular:
- the giving of permission by the Russian Ministry of Foreign Affairs for the flights of
the Tu-154M and Yak-40 aircraft to Smolensk “Severny” Airdrome without a
leaderman on board, which is against the Russian AIP regulations;
- failure to give the current aeronavigation data for the Smolensk “Severny” Airdrome
by the Russian side despite written requests from the Polish side;
- lack of data from the Russian side about actual and forecasted weather conditions at
the Smolensk “Severny” Airdrome before the departure of the Tu-154M aircraft;
- failure to warn Poland about weather conditions occurring at 05.09 UTC below the
Smolensk “Severny” Airdrome minima (before the departure of the Tu-154M aircraft
from Okecie);
- lack of a decision to divert the aircraft to an alternate airdrome or other airdrome with
proper weather conditions despite having the information about weather conditions
preventing any aviation operations at the Smolensk “Severny” Airdrome;
- the failure to provide information about vertical visibility by the Smolensk “Severny”
Airdrome controller to the crews of the planes;
- the lack of reaction from the Landing Zone Controller during the approach to land of
the Tu-154M aircraft in regard to its deflection from the scheduled glide path;
- ATC group’s instruction to abort the descent which was given too late;
- the lack of evaluation of the preparation of the Russian side to arrange a VIP flight,
particularly as such evaluation was presented in regard to the Polish side;
According to the Polish side, some statements in chapter 3.2 Causes are not confirmed
by the facts, are not sufficiently explained in the analysis or the analysis is conducted in an
improper way. These reservations concern among others the statements below:
- There were serious shortcomings in the arranging of the VIP flight concerning the crew
training, composition, monitoring of its preparation and selection of alternate airdromes;
- The departure was conducted without available actual and forecast weather and the actual
aeronautical information for the destination airdrome. According to available information the
Polish side refused the leaderman (navigator) services;
- On contacting the ATC group of Smolensk “Severny” airdrome the crew did not report the
selected approach system to them which deviated from the Russian AIP requirements. Further
the crew continued approach using the on-board equipment without utilizing ground navigation
aids;
- The PIC had a break of over 5 months in approaches in complicated meteorological conditions
(corresponding to his weather minima 60x800) on Tu-154M. The PIC had not has enough
training on approaches in manual steering mode using non precision type of approaches.
- The approach was made using the autopilot in pitch and roll channels as well as the
autothrottle. This type of approach is not provided by the Tu-154M FCOM and the weather
minima and SOP for this type of approach are not described there;
- The crew did not terminate the descent at the established minimum descent altitude of 100m, but
continued descent with a vertical speed two times higher than the estimated without establishing
visual contact with the ground references;
- Despite numerous TAWS (TERRAIN AHEAD and PULL UP) alerts, the triggering of the radio
altimerer decision height alert at 60mand the ATC instruction, the crew continued descent
which can be an evidence of their attempt to establish visual flight before passing the middle
marker in order to conduct a visual landing;
- The operation of the ground based navigation and lighting equipment did not affect the
accident;
- The presence of high-ranked persons in the cockpit including the Commander-in-Chief of the
Polish Air Forces and the Protocol Director, and the negative reaction of the Main Passenger
expected by the PIC exposed psychological pressure on the crew members and influenced the
decision to continue approach in the conditions of unjustified risk.
Due to the aforementioned reasons the Polish side requests reformulation of the causes
and circumstances of the accident involving the Tu-154M aircraft as well as the preventive
measures, after taking into consideration all the factors influencing the accident, including
those described in this document.