TMI?

January 22, 2013 by Bruce Landsberg

Jeppesen manualThe first time I heard that acronym, I wondered why anyone was talking about Three Mile Island before some smartphone-savvy type patiently explained that it was code for Too Much Information.

There’s much talk these days about how the government has made things too complex. Many pilots would agree, and President Obama has asked for a review of regulations to see what might be reduced. I’m not holding my breath as far as the FARs are concerned, but come along on my fantasy.

On a rainy afternoon recently there was just no better way to prime for a nap than by reading the Federal Aviation Regulations and the Aeronautical Information Manual, known affectionately as the FAR/AIM. Published annually and updated constantly, the latest volume is a weighty tome. The new version is 1,331 pages, up from 1,074 last year which was up from 1,049 the year before. To be fair, this includes Parts 105, 119, 135, 136, 142, and some other esoterica.

There’s lots of flight-critical safety information included, but some pruning is clearly in order. Some industry and most government publications just can’t seem to let go of things that may have been important once but have long been overtaken by events. Or, it was someone’s pet project and legacy.

Some examples from the AIM:

Table 1-1-4 Frequency Pairs Allocated for ILS: Shows how localizer and glide slope frequencies are paired—never had occasion to know that.

1-1-11 Microwave Landing System (MLS): A 2-page detailed system description that 99.999% of the aviation community can’t use because they don’t have the equipment on board and need special authorization—spare the rest of us.

1-1-15 Loran goes on for nine pages, five of which are in full color, outlining the various chains with the pulse and pulse groups—the system is not in much use these days, and this description is something only an engineer could use. Please explain why I need to know the amplitude and frequency of the 100 kHz pulse. Back in the years when I flew Loran, I never found the “tuning function” on the unit and it seemed to work just fine.

The other thing that would help tremendously is to stop speaking in the tongues of legalese and put the regs into normal English. For example, why does it take six paragraphs to tell pilots that except when nature calls, you should be at your seat with the seat belt fastened? For takeoff and landing, shoulder harnesses should be worn unless the aircraft is exempted from having harnesses or controls can’t be reached when the harness is in use.

You can certainly come up with other examples—so let’s hear ‘em, and submit them to the FAA for consideration. Don’t hold your breath, but perhaps some sanity would preserve both tree and electrons.

After we tilt this windmill, it’s on to the tax code!

Now it’s your turn to tilt some windmills. A donation to the AOPA Foundation can go a long way toward making positive changes for general aviation as we seek to grow the pilot population, increase our safety record, and move GA forward. Consider a tax-deductible donation today.

Bruce Landsberg
President, AOPA Foundation

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16 Responses to “TMI?”

  1. Mike Says:

    I’m a helicopter pilot… So how about a FAR/AIM version that does not include all the airplane information and rules?? =)

  2. Bruce Says:

    The AIM needs editing for length, but it also badly needs a thorough reorganization. Important information about a specific topic (for example, GPS) is fragmented and scattered in many places. Why is weather hidden inside the broad topic “Safety of Flight”? Surely that subject deserves its own heading. Chapter 1, verse 1 of the AIM is about…NDB?

    The AIM grew organically; unfortunately, now its sections and paragraphs, apparently as sacrosanct as the chapters and verses of scripture. Even in this age of Google, what we in the trade call a “developmental edit” is long overdue.

  3. Chris Says:

    Since ALL of the 14C.F.R. applies to us, even the Parts that start with “Except…unless…”, they should be cataloged in the FAR that we get.
    Indeed, there are parts of 49C.F.R. that should be included in our copy of the FARs.
    Keep, and even expand, our copy of the FAR- part of the FAR-AIM.
    (For example, ASA, at my suggestion, now includes the “Pilots Bill of Rights”.)

    Likewise, the AIM contains Information (as the “I” indicates) on current, prior, and rare or rarely applicable items, whether that be of navigation methods, definitions, usage, weather, etc.
    For example, how often, in a METAR or a TAF, do we see “DR”, “GS”, “MI”, “PO”, “SQ”, or “SS”? Should they NOT be included in the AIM? Of course they should.
    Same goes for NDB, LORAN, MLS, and Loc/GS freq. pairing. Why not? a “tree”?
    Good grief, kill the tree and print some paper already, you can plant another tree!

    I do agree, however, that the GNSS/GPS discussion in the AIM should both be consolidated and co-located. Some simplicity and practical usage advice would also help.
    For example, how many actually KNOW that you cannot fly a GPS approach to LPV minimums without WAAS? Such a simple sentence should be put in the AIM at several spots, one with the LPV discussion, one with the IAP discussion, one at the GPS discussion. The AIM should be helpful, not just dry reading.

  4. Bill Says:

    One thing the AIM should definitely clarify is whether the it is “advisory” or “mandatory” in nature. Somewhere a long time ago I thought that the AIM was advisory, unless a specific FAR made it mandatory, like the rule about all turns in the pattern being to the left unless specified otherwise by the airport operator (FAR91.126). But then again, I have heard at FAA safety meetings that some DPEs will fail your checkride if you make a right turn out of the pattern at an uncontrolled airport at 700 feet AGL.

  5. Jeff Says:

    The number one thing in my mind to improve safety and make flying “easier” is to put all weather, Pireps, Notams etc in plain English, ditch the acronyms. To have to carry a decoding book or smartphone to translate is counter productive.
    We don’t use teletype or telegraph any more so why the proliferation of acronyms. Plain and simple folks and then someone won’t screw up due to thinking they knew what something said.
    After all the real hazardous stuff is broadcast in plain English.

  6. JON M NELSON Says:

    How about organizing the FAR/AIM so that pertinent, related inforamtion can be found together? For example, I dare anyone to show me in one place where I can find which documents must be in the aircraft during flight. We all know what “AROW” stands for, but where in the regs can we find the requirements? It turns out we must look in FOUR different places: FAR 91.203 for Airworthiness Certificate and Registration; FAR 91.9 for Approved Flight Manual and Placards; FAR 23.1519 for Operating Limitations; and FAR 23.23 for Weight and Balance.

  7. Owen Says:

    The FAR/AIM isn’t an FAA publication… right? It is, however, bits and pieces of the FARs that ASA thought would be nice to consolidate into one book for pilots (along with the AIM of course). ASA does not include all of part 91 or even all of part 61. If you want the full and complete part you have to go online to http://www.ecfr.gov to get the most up to date and complete set of regs.

    As for the AIM, a re-organizing would be nice. Things like LORAN and NDB’s are becoming outdated. I still believe access to this information would be nice and I believe the way to fix this would be for ASA to just not publish that part of the AIM in their next revision of their book. All of the FAA’s publications are available for free online so there shouldn’t be any real issue with access these publications in their entirety if need be.

    It sounds like people have an issue with the book being too thick… this is easily solved by ASA cutting out parts that are out of date from the AIM. I don’t see the FAA ever cutting parts of the regs out. ASA has already determined what is pertinent to us as pilots and has published those parts in their version of the FAR/AIM book.

  8. Avi Weiss Says:

    Bruce;

    In the software business, when a large, unwieldy legacy system get too outdated, the only way to modernize it is to create a parallel track effort to do a ground-up “re-write” of the system, using functionality as a guide to drive the new design, and using the old / current system as a algorithmic guide, but create a new software architecture, and implement in a modern language. The same solution can and should apply to the FARs.

    The FARs have evolved over many years as a patchwork of regulations, most of which were created in response to accidents after which the agency determined that rule changes would be much more effective than education, rather than following any coherent structure of reason. As such, not only is there no overall structure or cohesiveness to the regulations, but in numerous instances, one section of regs may actually be in conflict with another, leaving much gray area for FSDO and lawyers to argue over.

    The time has most decidedly come for a “ground up” rewrite of the the entire FARs, which should accomodate the large tectonic shifts that have occurred in airframe materials and manufacturing, avionics, weather analysis, forecast, and decision making, flight and business operations, medical science, and even human aging itself.

    While the current FARs can serve as a valuable reference, a small but effective “rules standards” committee made up of FAA flight standards and industry leaders needs to be formed to architect a meaningful and supportable outline of a new set of regulations. Upon completion of the outline and passing of an NPRM review, it should then be submitted for detailed regulatory formulation by competent and RATIONAL writers.

    …and let’s see if we can get this done by next week, shall we? ;-)

  9. Bruce Landsberg Says:

    We’ll get right on it :-) But as noted, you may want to lay ina large supply of salt.

  10. George Read Says:

    I wrote an article about the FARs being TMI, which was tentatively accepted for AOPA Pilot, but was not published, possibly because it might offend the FAA. If you will send me your e-mail address I would like to send you the article as it is relevant to your point.

    Aloha, George Read.

  11. Christian Says:

    The FARs need a ground-up rewrite, taking into account technological improvements and actual accident studies.

    I routinely fly 91/91K/135 on the same airplane. So why are my oxygen, lifejacket, and emergency equipment requirements different based on the passenger in the back?

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  14. John Scarry Says:

    FARs Condensed is a web page and app that aims to remedy that situation described in this article by displaying only the parts that apply to private pilots—with links that display the full text if more details are desired. For example, when I was a student pilot, I cared about the rules that apply only to students, but I don’t care right now. I also have no interest in rules specific to helicopters, balloons, and airships. So I’ve hidden that information—it’s there if you need it but it can be easily skipped if it doesn’t apply to you right now.

    I also hide information that is relevant to only a small subset of pilots, e.g. special training for Mitsubishi MU-2B pilots and regulations specific to Alaska. And does anyone ever care that if you have a private or commercial pilot certificate issued before July 1, 1945 it will not be renewed?

    The first draft of the content is available at http://touringmachine.com/FARs/ and comments would be appreciated. It has the complete content of the relevant FARs—the only changes I made are to formatting, (so that the sub-sections are easier to follow) and ellipses (…) to hide content that I don’t think private pilots would be interested in. If you’d like to comment on my choices, you can send an email to FARsCondensed at my company, LearningFundamentals.com, or PM me.

    I need to proof the content a few more times before I put it on the main page of my website. The app will be available in a couple of weeks and the first iteration of the app will have just the content on the website. Future versions will have links to discussions of parts that are ambiguous. I have a collection of links but if you have some good ones you like to share, I’d appreciate you forwarding them.

    I have a collection of the FAA Knowledge Tests and answers but I haven’t looked at them for a while, so I need to verify that the answers and links are still correct. At some point I’ll put the relevant questions and answers into the app.

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