Sunday,
April 8, 2007 Vol. IV No.
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Welcome
to the
Over the
Airwaves
aviation journal. This complimentary bi-weekly e-mailing
is being sent to pilots and aviation enthusiasts around the
world. Its aim
is to promote
flight safety, encourage students and new pilots, and to build
enthusiasm for aviation in general.
Dear Pilots and Aviation Enthusiasts:
Those Simulation
Blues!
Paradoxically, advancing aviation technology is quickly turning today's pilots into button-pushing cockpit automatons who one day will not know the difference between a departure stall and a reset button! Marketing to the masses, factory training departments tell us to climb aboard their newest creations, activate an electronic checklist that self-tests each major aircraft system, then it reminds us to fasten our seatbelts. "Hey . . . anybody can fly these airplanes," goes the hype! The worst manifestation of advancing technology is emerging in the lowly flight school. Once a place where weather-beaten freight dogs passed on their hard-earned lessons learned to curious students, many of today's flight schools are quickly becoming darkened rooms where "make believe" cockpits are fashioned out of computer screens and keyboards.
Beyond that, I believe these "make believe" cockpits to be mis-used convenient alternatives to enduring the hassles, discomforts, and risks of conducting real world flight training. And let's not forget that these "make believe" cockpits offer a far better return on financial investment to their flight school owners than real airplanes! Fortunately for the good guys, FAR 61.65(e) limits the use of flight simulators to 10 or 20 out of the required 40 hours required for the instrument rating. This means that the instrument student must actually fly a real airplane for a minimum of 20 to 30 hours in either simulated or actual instrument conditions. Enter the View Limiting Device!
Thus, the weather-adverse instructor is permitted to simulate instrument conditions by permitting the student to wear a view limiting device to keep the hapless student from "peeking" out the window (chuckle, chuckle). Putting it all together . . .
Hmmmm . . . anybody know where we are supposed to place our feet? No, I am not arguing against improved technology in the cockpit or reducing training costs through the use of simulators. But we cannot sacrifice what can and must be learned in real world flight operations.
So when it is time for recurrent training, don't be duped into simulated flight, whether in the box or under the hood. Get out in the actual stuff where the challenges are real and the decisions you make are lasting! Fly safe, Bob
Miller, ATP, CfII The Stark Reality of REAL WORLD Flying!
The pilot received a full weather briefing from the St. Petersburg, Florida FSS. The briefer assured the pilot that he would encounter VFR upon his arrival. The ceiling was forecasted to be between 2,500 to 3,000 feet with rain showers. Upon reaching Mooresville, the pilot discovered that the VFR forecast did not hold up. Instead, the ceiling and visibility had deteriorated to 200' overcast, 2 miles visibility, and mist. Thus, the pilot requested vectors to Statesville, NC where he was eventually cleared for the ILS runway 28 approach. No further transmissions were heard from the pilot.
The main wreckage of the airplane was found in a wooded area adjacent to the airport in a ravine on an embankment. Examination of the crash site revealed the airplane collided with 75 foot tree tops in a nose down, left wing low attitude. The crash debris line was 166 feet long. The pilot and one passenger survived. The other two passengers died in the crash. Here's a little more about the pilot . . .
As such, the pilot did not receive a final evaluation flight and was not awarded a completion certificate. The pilot did receive additional flight instruction after returning home from his flight instructor who attended the SR22 training with him. A review of the pilot's
logbook revealed that his last instrument flight occurred
four months prior to the accident on June 26, 2006.
His last six instrument approaches were flown
with a CFI 5 months and 26 days prior to the
accident on May 1, 2006. These instrument approaches
were conducted in simulated conditions. For starters, the NTSB ruled that the probable cause of the accident was as follows:
But what REALLY happened . . . No one but the pilot, who survived, will know what really happened on this tragic day. But we can surmise a good deal from the NTSB accident report. Below are examples of several factors that may have contributed to this fatal accident:
As in all such accident discussions, our purpose here is not to criticize or to make light of the pilot's actions. In the panic of the moment, any of us may have acted in the same way. Instead, we have an obligation to learn what we can from every tragic accident in the hopes that lessons learned may prevent them from being repeated. NTSB Report Memorize It!!!
We're not talking rocket science here. Why not commit the flight planning form to memory? Once done, we can breeze through the filing process any time, any place . . . like in the car while on the way to the airport. This presupposes, of course, that we have done all of our actual flight planning at home before getting into the car! More importantly, memorizing the form saves a lot of time when talking with the briefer . . . and we sound like more proficient pilots.
FAA Offers Revised "Known Ice" Letter of Interpretation
This entire matter began over a year ago when I sent a letter to the FAA requesting that they clarify their legal definition of "known ice." The answer I received back illustrated the naivete' of the FAA's legal eagles regarding meteorological factors that contribute to airframe icing. In a letter dated June 6, 2006, the FAA Eastern Region Office of Regional Counsel said, in essence, that "known icing conditions exist when visible moisture or high relative humidity combines with temperatures near or below freezing. Since clouds are a form of visible moisture, flying through clouds at an altitude that is near or below freezing would constitute flight into known icing conditions." The stumbling phrase was, of course, "high relative humidity." Anybody out there know what that is?? Angry responses This letter of interpretation sparked two angry responses from the general aviation community. First, I was criticized by many OTA readers for asking a question that we really didn't want to have answered! We had been flying in and around icing conditions sort of "between the lines" of the law for decades and few pilots were willing to risk having this "gap" closed.Second, following my asking of the question, the FAA clearly made it illegal to fly a non-known ice certified airplane into sub-freezing clouds. It quickly looked like this "gap" had, indeed, been slammed shut. This ruling, in effect, had the effect of closing down nearly 90% of all (legal) IFR flight instruction from October 30 to April 1 in the northern climates. It also threatened the continued operation of many Part 135 cargo flights in non-known ice certified airplanes during the same period here in the north. Was I wrong by asking the question?
I reasoned, however, that while the FAA may be viewed by some as an "angry dog," we're living in an enlightened world of aviation where most of us, including the FAA, really do operate rationally. Sure, there are skeptics and scoundrels on both sides of the FAA/pilot fence, but operating in winter skies "between the lines" of the law is no place for any of us to be, and still hope to avoid an FAA enforcement action taken against us. Closely related to this, how could we CFII's set a good example for FAR compliance and still provide a reasonable level of IFR flight instruction in the northern climates during the winter months? That's why I asked the question. AOPA to the rescue!
AOPA's Director of Regulatory and Certification Policy, Luis Gutierrez prepared a wonderfully worded letter to the FAA HQ Office of General Counsel demanding that it rescind that letter of interpretation. In its customary speedy way of responding, the FAA eventually rescinded the June 6 letter and on April 3, 2007 (10 months later) issued a proposed NEW letter of interpretation on what constitutes "known icing." They published this proposed NEW letter in the Federal Register for the purpose of soliciting public comment of over the next 30 days. You can view this Federal Register posting by clicking HERE. Is the proposed NEW letter of interpretation good or bad? In word, the proposed new letter of interpretation is GOOD! First, the new LOI removes the automatic "guilty" charge for entering a sub-freezing cloud in a non-known ice certified airplane. This, alone, allows us to legally resume IFR flight training during the winter months in the Northern Hemisphere. In essence, the new interpretation leaves the decision up to what a reasonable and prudent pilot would do based upon his or her analysis of all available information. Second, Part 135 flight operations in non-known ice certified airplanes can likewise legally resume here in the north during the winter months. A cautionary note is warranted, however. While the FAA can no longer make a prima facia case against a pilot of a non-known ice certified airplane for entering sub-freezing clouds, there is language in the proposed NEW LOI that bases any possible enforcement action on what a "reasonable and prudent pilot" might do in a similar circumstance. The "reasonable and prudent" doctrine has its origins in the old British Common Law and is the basis for many of our legal interpretations today. This leaves open, of course, as to who and what defines a "reasonable and prudent pilot" would do in a similar circumstance. The FAA invites comments The Federal Register posting has a web link through which anybody can submit comments on the proposed NEW letter of interpretation through May 3, 2007. Over the Airwaves has received hundreds of emails on this matter and the general consensus among pilots is that this is a good interpretation of "known icing." It recognizes that the ultimate decision regarding flight into sub-freezing clouds rests exclusively with the pilot, based upon his or her analysis of all available information (FAR 91.123). Like so many things that we do as pilots, it is impossible for the FAA to issue "black and white" rules governing each mile along our proposed route of flight. The variables are too complex and too varied to cover every possible situation. As for the "reasonable and prudent" pilot, we proficient pilots do understand the meteorology and physics of icing, including droplet size and temperatures. We NEVER find ourselves in icing conditions without an immediate and "golden" back door. We always have warmer temperatures or clear skies immediately above or below our route of flight. Nor do we ever penetrate clouds where PIREPs or AIRMETS warn of light to moderate icing. "Reasonable and prudent" pilots do not place their aircraft and their lives at risk in icing conditions. And if they do, FAR 91.13 (careless and reckless violation) works just fine! In summary, we did good. Articles published in Over the Airwaves prompted a fire-storm of discussion on numerous on-line chat forums regarding the "legality" of operating in sub-freezing clouds in non-known ice certified airplanes.
The general aviation world is better served by having both the FAA and the pilot community on board, together, with rules and regulations we both understand. Lastly, we need to thank Phil Boyer and Luiz Gutierrez of AOPA for quickly and forcefully picking up the sword on this important matter. Private and Instrument Practical Tests Passed on Same Day!
That's just what young Mr. Barnhard did this past week. Greg took his first GA plane ride at age 10 and his first logged lesson at age 14. In the tradition of a former era in aviation, Greg washed airplanes in exchange for flight lessons. Avgas was in his blood and he wasn't going to let his young age get in the way of learning to fly!
Greg came along with us to Sun 'n Fun and Oshkosh each year where he would challenge us with increasingly difficult aeronautical questions! The photo (right) shows Greg at the controls of Dan Maloney's RV-4 tucked up under the wing of my Cessna 210 on the way back from Sun 'n Fun last year. Good going, Greg. We expect to see you make a difference in aviation! Controllers can make or break the flight training experience!
What could I offer this pilot? Hmmmm . . . how about a partial panel, no-gyro, ILS approach ?I had attempted this exercise many times before but was nearly always turned down by controllers whose apparent workloads prevented them from participating. Oh well, I thought. Let's try again.
And so it went as the otherwise busy Syracuse controller, who was handling a sector full of other traffic (134.27 Sunday, March 30, 1745Z - if the SYR TRACON facility manager is reading), skillfully turned us on to the final approach course.
If you ever encounter a grump, note the date, time, facility, and frequency. On the ground, call the facility supervisor. He or she will pull the voice tape and will take it from there. Good going, Syracuse Approach . . . have a cup of coffee and a donut on us! Runway Signage . . . Know them!!!
Some have suggested that today's airport signage was designed by a disgruntled FAA employee on LSD. It's often poorly positioned, difficult to see, and easy to misunderstand. Unfortunately, flight students who are trained exclusively around the same homedrome airports are not given opportunity to witness the challenges they will one day face when at an unfamiliar Class B or C airport on their own. One of my favorite flight training exercises is the New York/Philadelphia TRACON tour. This tour includes landings at LaGuardia, JFK, Newark, and Philadelphia International. This full day exercise that exposes students to both the busiest airspace in the world as well as some of the most complicated airport signage. This is "must" training for any pilots planning on traveling up and down the busy east coast corridor.
Take a minute to review the above airport signage. Be certain that you understand each sign. When taxiing around ANY airport and you encounter an unfamiliar sign, stop. Call the tower or airport unicom and ask what it means. Carburetor Icing . . . and No Apparent Back Door!
You search the gauges for an indication of what is wrong. Plenty of gas. Oil pressure and temperature gauges are both in the green. RPM is dropping slightly. You cycle the mags, switch fuel tanks, turn on the fuel boost pump, and apply carb heat. Your brain is spinning. You begin losing altitude as you search for answers. This is likely what happened this past August to the president of the Pueblo Community College as he was flying on a VFR flight plan from Pueblo to Durango, CO in his Piper PA-24-180 Comanche. Prior to departure, the pilot received a full FSS briefing. He was told that VFR flight was not recommended due to an AIRMET for occasional IFR conditions and another current AIRMET forecast mountain obscuration. At the time of the weather briefing, current weather conditions had not been loaded into the FSS computer system, so the briefer gave the pilot the previous hour's observations where Pueblo, Alamosa, and LaVeta reported VFR conditions. At the conclusion of the briefing, the pilot said: "I'll go ahead and give it a shot." Those final words . . . "I'll Give it a Shot!" We pilots often pride ourselves in taking charge of the situation. We can look risky weather in the face and boldly bet the farm on our decision to launch. Sometimes, as in this case, we lose . . . and we lose more than the farm! According to the NTSB report, the probable accident cause was:
Given the right combination of high humidity and proper
temperature, carburetors can ice up in VFR conditions while
in full cruise power setting.
The pilot in this case apparently encountered the problem while either in or above the clouds at some altitude higher than the 11,589' MSL point where he impacted mountainous terrain during descent about 16 miles northwest of Mosca, Colorado, near the Great Sand Dunes National Monument. No Back Doors!! Okay, stuff happens to the best of us. But when it happens without our having back doors, shame on us! I vividly recall a flight several years ago with my good friend, Kelly Brannen, from San Francisco to Buffalo, NY in his newly purchased Piper Archer. We encountered suspected carburetor icing at 13,000' over the Rocky Mountains while passing eastward near Elko, Nevada. We had been following Victor 2 which kept us well clear of the highest peaks. I had been keeping my eye on the GPS moving map noting passing airports as well as the highways and roadways meandering through the valleys below. Suddenly, the engine began missing. The very FIRST thing we did was initiate a right 170 degree turn to the Elko, NV Airport just 8 miles behind us. I notified Salt Lake Center of our emergency and was immediately re-cleared as requested. Our back door was secured and we landed safely. College may not have been so prepared . . .
Perhaps it was his intention to remain VFR to keep an eye on the mountains below. Did he have a GPS moving map up and running displaying any highways below? Remember, highways are seldom constructed over mountain ridges. There are an entire host of things we can do to build back doors for ourselves. For example, when crossing high mountains in a non-turbocharged airplane, follow the Victor airways. Their MEAs (minimum enroute altitudes) are always lower than the OROCAs (Off-route obstruction clearance altitudes). When all other back door options fail, fly along interstate highways!
Donations needed to keep OTA coming!!If you found Over the Airwaves helpful to you personally and/or beneficial to general aviation and would like to support its continued publication, please consider making a donation to the effort. Simply click on the button below to access a secure link through which donations can be made. Those wishing to mail a contribution can do so by making a check payable to R. J. Miller, 124 Delaware Street, Tonawanda, NY 14051. Seen one . . . you've seen them all, right? Think again! After a while one instrument approach looks like the next. We pull and review the instrument approach plate, slow the airplane to the approach speed, secure our approach clearance, and voila', we slither down the final approach course to a textbook landing. Not so fast, Charlie. Take a look at the VOR-A approach to Wellsville, NY (KELZ). Pay particular attention to the placement of the final approach fix (FAF). It's just 1.1 miles from the runway! Next, look at the profile view of the above IAP. You cross the FAF inbound at 3,600 feet, reduce the power, point the nose down, and you have 44 seconds (at 90kts) to lose 440 feet to reach circling minimums. In other words, this is one approach where, in low weather, you could reach the Minimum Descent Altitude (MDA), Missed Approach Point (MAP), make visual contact with the runway, and arrive directly over the airport all in the same instant. Wow . . . are you ready to land? Note: Observe the several towers surrounding the airport! Arrived Unprepared!
Arriving over the FAF just a bit fast, we reduced power for the final descent to a hopeful landing. Not taking special note of the fact that the FAF was only 1.1 miles from the runway, it quickly became apparent that we would need a quick descent to the MDA before reaching the MAP to have any chance of seeing the runway. This, of course, pushed our airspeed up to 120 knots.
Remember . . . the required visibility is generalized. It is NOT the distance from the runway. Had we been able to see 1.25 miles in any direction while over the airport, we could have "legally" landed. Unfortunately, we did not have this visibility. The lesson in all of this is . . . never assume that one instrument approach is like the next. This one is UNIQUE. Flying it in low IFR weather requires consummate planning and absolute speed control, and careful attention to details. Mess it up and you could become an aerial dart in one of the surrounding hills! VOR Change-Over Points We see VOR change-over points (COPs) as a vertically shaped "Z" on some victor airways. They tell us when we should shift our primary VOR navigation from the VOR behind us to the VOR ahead of us. Note the example below, the COP on V344 occurs 45 miles east of the VOR on the left. This graphic also illustrates the rationale for some COPs. In this example, it is due to the interference of a mountain with the VOR signal.
The changeover point also has an effect on the primary and secondary obstacle clearance areas. For example, on long airway or route segments, if the distance between two facilities is over 102 NM and the changeover point is placed at the midpoint, the system accuracy lines extend beyond the minimum widths of 8 and 12 NM. This produces flare or spreading outward of the secondary safety area at the COP, as shown in the illustration below.
While the GA world is rapidly changing to GPS navigation, unless we have an IFR certified, panel mounted GPS, we're still obligated to navigate by ground-based navigation systems. Let's not forget the rules under which these land-based navigation systems operate!
Fatal Graveyard Spirals are Preventable
The last radar track on the doomed aircraft measured a descent rate of 1,300 feet in 4 seconds. This translates to over 19,000 feet per minute, which explains, of course, why pieces of the aircraft were observed by witnesses to be falling from the sky prior to impact. Circumstances surrounding this flight were all too familiar. A low time, non-instrument rated pilot launches in marginal VFR weather, encounters IFR conditions, and loses control of the airplane. This, in fact, is the most common scenario of all fatal accidents. The Typical Accident Chain . . . Most pilots understand that fatal accidents are a result of a string of contributing factors rather than just one or two. In this case, the accident chain likely began several days before the ill-fated flight. Had the pilot reviewed the weather forecast several days before the flight, he would have likely concluded that VFR flight would likely not be possible. To the pilot's credit, however, he did receive a standard Flight Service Station (FSS) weather briefing just prior to his departure. Here is the message the pilot received from the FSS briefer:
The "Sucker" Briefing! The FSS briefer was doing his job. He informed the pilot of the IFR conditions followed by the "VFR flight was not recommended." But then he held out a ray of hope that the pilot globbed on to. Noting that the forecasts called for improving weather, the pilot elected to launch. It's human nature to search for reasons to justify our actions. In this case, the briefer's simple declaration that the forecast called for improving conditions may have been the trigger that caused the pilot to go ahead with the flight. In essence, the pilot likely allowed this bit of good news to sucker him onward with his plans! This was the second link in the accident chain. Shortly after launching, the pilot apparently entered instrument conditions and failed to execute a safe 180 degree turn or descent back to VFR conditions. Instead, he allowed the airplane to reach an excessive bank angle. As the bank angled increased, his altitude no doubt began to drop. Unaware of his steepening bank angle, he likely pulled back on his yoke and added power to restore his lost altitude. This was the third and final link in the accident chain. With the airplane in a steep bank angle, pulling back on the yoke serves to tighten the turn and quickly place the airplane into a steep, descending spiral. The addition of power hastens this process. Wings-Level vs. Spiral Dive: It is very difficult to over-speed an airplane in a wings-level dive. As the speed increases, lift increases and it requires ever-increasing forward pressure on the yoke to maintain the dive. In a spiral dive, on the other hand, airspeed can quickly increase to a point where the airframe can self-destruct in flight. I asked OTA reader and supporting sponsor, Paul "BJ" Ransbury, President of APS Emergency Maneuvers Training, to explain the aerodynamics difference between a wings-level and a spiral dive. By the way, BJ is a graduate of the Royal Military College of Canada with a B.Sc. in Honors Mathematics and Physics. He has served 12 years as a military officer and fighter pilot in the Canadian Armed Forces flying the F/A-18 Hornet.
So what really happened in this Piper Dakota Crash? According to the NTSB report, "the
main wreckage came to rest inverted about 20 feet
beyond the initial impact point. It included the fuselage, empennage, and
inboard 7 feet of both wings. Portions of the
stabilator, outboard portions of the left wing, and
the right aileron were clustered in an area between
1,000 and 1,500 feet from the main wreckage.
The outboard portion of the right wing was located
about 2,000 feet from the main wreckage."
In summary, like so many fatal accidents, the accident chain began when the pilot failed to follow the FSS briefer's recommendation that VFR flight not be pursued. It continued with the pilot's inability to execute a safe retreat from IFR conditions.
Flight schools and many CFIs are fond of saying, in their own defense, that non-instrument rated pilots have no business penetrating IFR conditions. These instructors FAIL to acknowledge the fact that IFR conditions are sometimes not predictable. Summer haze in the late afternoon setting sun over large bodies of water is an excellent example of unpredicted IFR conditions. A sudden temperature drop of a single degree or two that results in fog is another example. If you are a non-instrument rated pilot and have never been in real IFR conditions, hire a CFII and get comfortable in the clouds. It just might save your life and the lives of your passengers.
The above quote is real! It comes from a student who presented himself last week to a Designated Pilot Examiner (DPE) for the CFII checkride. The examiner looked at the candidate's logbook and noted that he had 256 hours of "simulated" instrument time. He had logged 136 instrument approaches in the previous six months. He had zero ACTUAL instrument hours over his entire flying career! When the examiner commented upon the candidate's total absence of actual instrument time, the candidate reminded the DPE that the FAA does not require any ACTUAL instrument experience to qualify as an instrument instructor. Why GA pilots die! If anybody is curious why general aviation continues to be plagued by one fatal accident nearly every day of the week, with most of them due to weather related causes, this is a large part of it! This is ludicrous. No, it's insane and nobody is doing anything about it! Imagine signing up for instrument training and your CFII has never been in the clouds before. Worse, imagine if this CFII travels north and begins teaching in the winter where IMC occasionally comes with freezing rain and ice. Unfortunately, flight schools like the one referenced in the above quote, would rather push their graduates through the checkride than to realistically prepare them for the real IFR world they will one day face. Tragically, there are FAA approved Part 141 flight schools throughout the United States that have similar weather restrictions governing their instrument flight training. Once the ceiling drops below marginal VFR, they corral their instrument students into simulators rather than provide them with the real world training they will need to remain safe aloft. Consequently, hundreds of new CFIIs are turned out every year who have NO real, in-the-clouds, experience. Want to know why?? The reason why so little instrument training is provided in ACTUAL instrument conditions is that many flight schools employ their own graduates who likely have little or no ACTUAL instrument training themselves. This self-perpetuating system of training mediocrity is producing CFIIs totally incapable of providing genuine instrument instruction. And the FAA is making this all possible through their permissive regulations. Where is the AOPA and the National Association of Flight Instructors (NAFI) on this issue?? Through their silence, are they endorsing this absurd practice? You be the judge. In reality, it's likely that very few people are actually aware of this practice of producing CFIIs who have no actual IFR experience.
And so it goes . . . another CFII enters the system who believes it is "absolute insanity" to take off into a 400' overcast ceiling. Do you believe that any of his future students will ever see the inside of a REAL cloud? What about you and me? Frankly, there is little you or I can do about this absurdity other than to protect our own safety interests and the safety interests of our friends. We need to recognize that the CFII credential, alone, reveals very little of its holders' qualifications and experience to teach instrument flying. Similarly, we need to know which flight schools set artificially high weather minimums for instrument flight instruction. If you are engaging a CFII to provide instrument training, it's fair game to look at his or her logbook. Ask how much actual instrument experience they really have. Check their references. Remember, it's your money and your life! If you are an instrument student or are contemplating the pursuit of an instrument rating, be certain that you are provided training in ACTUAL instrument conditions. Later on, you will know why!!
Fly safe, Bob
Miller, ATP, CfII Upcoming Events of Note April 17 - 23 - Sun 'n FunYou can be there OR you can access many of the live seminars right through your computer! The FAA's production facilities located on the grounds at Sun 'n Fun will be streaming live video of many of the seminars. To access these videos, simply click on http://www.faaproductionstudios.com/, then click on View Seminars Live! I'll be attending Sun 'n Fun and will be reporting the events daily back to OTA readers.
May 4 and 5 - Rochester WINGS - Rochester International Airport (KROC) Over the Airwaves will be hosting an exhibit booth. OTA collaborator, Keith Harlock and I will be signing up new OTA readers. Please stop by and say hello! Click HERE for more information. Supporting Sponsors APS Emergency Maneuver Training specializes in upset recovery training, stall/spin awareness, aerobatics and spin recovery training.
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