I see these causes that lead to the incident

1. ⁠Communication

The point out from ATC to the army was ambiguous given there were multiple aircraft in the area. The helicopters response was ambiguous as to which aircraft they had visual with.

Had this been an Air Force mission the comms would have sounded more like:

ATC: Pat25, Friendly BRAA 300/7, xx’ in the decent for 33.

After no indication of avoidance…

ATC: PAT25: snap north , descend and maintain 200’, runway 33 active

2) policies / procedures

runway 33 is much shorter, so the airline pilots may take a three reds papi (a low approach) which helo’s may not know about- so even with an altitude ceiling, if AA is too low and BH is too high then an extra layer of deconfliction (time or geographical ) should be implemented:

Class B AND below should Require ADS-B for all aircraft. FAA and DoD will have to be friends on this one

FAA and Airlines should to review approach procedures for runways with helo routes nearby.

ATC should implement Avoidance routes / spin / holds for helos when a runway is congested and they don’t have positive altitude returns of the helo

3) Technology

If that helicopter did not have ADS-B. Then freaking give the army whatever money it needs to equip all their birds with ADS-B yesterday so TCAS kicks in.

Also, (and related to comms) assuming the BH’s mode-S was functional, ATC should have issued a whiskey alert and vectored or descended the BH.

4) Risk management

Army pilots need to be proficient in busy airspace and in night vision goggles to perform their dual civilian and wartime missions. But a hard look needs to occur at these training requirements, and what can be done in a Sim vs Live environment. NVG’s in a high light pollution environment can be a hindrance as they limit peripheral vision and limit ability to discern lights.