FIKI Interpretation

January 29, 2009 by Bruce Landsberg

It’s still winter and in a predictable follow up to the Cirrus FIKI discussion last week we get into when is it OK to fly in ice in a non-approved aircraft. (This may stir up a hornet’s nest so bear with me.) Some of you commented “never” and others were less restrictive. Most of us are prone to be cautious, which is very smart relative to ice, so this is more of an academic discussion but some are prone to push it.

Before we get too deep into the esoterica, here are some solid references that make much of the discussion moot.

* ASF’s online course: Weather Wise: Precipitation and Icing

* ASF’s Safety Advisor on Icing: Aircraft Icing

Only in government dictionaries is it possible to equate the words “known” and “forecast”. But if you’re not to get cross threaded with the FAA on Flight into Known Icing (FIKI) in a non-approved aircraft, you need to understand. AOPA has just gotten an interpretation of FIKI from the FAA’s Chief Legal Counsel. A full explanation can be found at FAA letter offers new “known icing” definition”.

It took three and half pages, single-spaced, to describe FAA’s interpretation. Seemed like overkill. By my operational definition, it’s straightforward as to when a non-approved aircraft is operated in violation: 1) There is significant ice adhering to the airframe and there is an Inspector to greet me on landing to observe it, or 2) I caused a significant ATC disruption due to icing.

However, that is not what either the FAA or NTSB take as gospel. Earlier FAA interpretations were over broad, making a complex subject much too black and white.

After spending some time with the interpretation, it actually begins to make some sense. The topic of how and when to fly in potential icing is anything but black and white. There’s plenty of opportunity for pilots to hang themselves but also the chance for redemption. For example, to quote from the letter,” The FAA does not necessarily consider the mere presence of clouds…..at or below freezing temperatures…to constitute known icing.”

It also goes on to say, if there is ice on an aircraft, that is not the only factor FAA will consider. ….The FAA will evaluate those actions taken by the pilot …to determine if they were reasonable….” Essentially cases will be judged on their merits.

From a practical perspective the idea is to get as much utility out of our aircraft without getting caught between hard ground and hard ice. Regardless of good or not-so-good forecasts, we need to have a solid escape route available at any time. With that, chances are very good that if you need to ask ATC for a diversion or altitude change, it will never escalate to anything of consequence. Get the priorities straight: It’s not about legality – it’s about not crashing!

And please don’t forget to file a Pirep of either ice or no ice to help the next pilot. You won’t be violated for requesting an altitude change due to ice (and reporting it). If a violation’s filed it’s because of other more incriminating evidence. But just to be on the safe side, it doesn’t hurt to be a member of AOPA’s legal service plan.

Bruce Landsberg
President, AOPA Foundation

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16 Responses to “FIKI Interpretation”

  1. Bernard M. Freeman Says:

    My AOPA # 00905398. This discussion reminds me of a siuation that I encountered about thirty years ago. I got a complete a full brief from FSS and filed an IFR flight plan from BWI to FIT (Fitchburg MA) in a Cessna 182 that would keep me clear of expected icing . The clearance had no resemblance to my flight plan except for the departure and destination. After about an hour of negotiation with CD if received an acceptable route and alltitude. At each handoff the next facility tried to revise my clearance onto a route that I knew would send me into icing conditions. I refused each change and continued on my planned safe route. About forty or fifty miles sout of JFK where I was in the clear with no ice problems, I was told to climb to 7000 which I knew would probably put me into ice. I was told that I would have to reroute into the alleganies over EXT and LHY. I refused but eventually accepted the climb. The result was a sever ice encounter before I reached 7000 and an eventual emergency landing at Newark. It was the end of an ILS all the way to touch down becausethe windshield was completely iced over. I had to be guided to the Butler hanger by a pickup truck. It took over an hour in a heated hanger to deice the airplane. This was a C-182 that at full power and 90 knots would not climb and barley could maintain 2500 which was fortunately below the clouds. After deicing the airplane I complete the trip VFR below the clouds at about 1500. I few days later I received a visit from the GADO safety officer but I was not charged with a violation. He said that as PIC I could have and should have refused the climb into ice.
    The final answer. For the last twenty years I have had the pleasure of flying my Piper Malibu which is certified for flight in known icing but I always plan and I have refused on may occasions to accept a route or altitude that will put me in ice. my turbochargers do more to solve ice problems that my boots.

    Bernard M. Freeman
    978-502-2000

  2. chris Says:

    I’ve always wondered about “known icing” while flying with my old instructor I was climbing through clouds and encountered light icing in the last 500 ft before breaking out on top. I keyed the mike to give ATC a heads up and my instructor stopped me worried ATC would bust me. There was no forcast for ice, as a matter of fact it wasn’t IMC clouds where scattered and we happen to fly through one. It was my first and only icing incident. At what point does it become a violation? thanks Chris

  3. Brian Turrisi Says:

    Bruce:
    I could not agree with you more. There is more heateddiscussion on this topic than almost anything in aviation. The FAA makes it worse by constantly changing its interpretation of their own rule. This is one time where being legal and being safe do not match.
    As a pilot I always prefer to be safe first and hope that means I am legal. With the icing rules that principal does not work. That speaks loudly for the need to chnage the rule. This is no regulation against flying into a thunderstorm yet most of us know it is not safe. The same approach should be used for icing as well.
    Above all , the strategy is to leave your self an “out” when ice is possible. But all of us who fly will encounter ice at some point. Why should we have to fear legal action when we should be focused on safety?
    Finally flying a FIKI airplane has the potential to give that pilot a false sense of security. After all, he/she may think, this plane is legally certified so I can go in ice anytime I desire. That attitude will kill someone.
    Thanks,
    Brian
    Brian

  4. Brian Turrisi Says:

    Bruce:
    I could not agree with you more. There is more heateddiscussion on this topic than almost anything in aviation. The FAA makes it worse by constantly changing its interpretation of their own rule. This is one time where being legal and being safe do not match.
    As a pilot I always prefer to be safe first and hope that means I am legal. With the icing rules that principal does not work. That speaks loudly for the need to chnage the rule. This is no regulation against flying into a thunderstorm yet most of us know it is not safe. The same approach should be used for icing as well.
    Above all , the strategy is to leave your self an “out” when ice is possible. But all of us who fly will encounter ice at some point. Why should we have to fear legal action when we should be focused on safety?
    Finally flying a FIKI airplane has the potential to give that pilot a false sense of security. After all, he/she may think, this plane is legally certified so I can go in ice anytime I desire. That attitude will kill someone.
    Thanks,
    Brian

  5. Bruce Landsberg Says:

    Chris…..

    Take this as opinion – not guarantee but base on experience. I’ve never had any repercussions with FAA flight standards or ATC on passing along information or making requests, sometimes strongly, that I needed an altitude change.

    If you’ve done your planning and know where the escape is – the odds are very good that you’re not going to mess up ATC much or create a problem for yourself. Where it gets complicated is when you’re closing off escape routes as you fly farther into a bad situation.

    Again, fly to survive and then to fly legally – chances are if you do the first the second won’t be an issue. Thanks for your comment!!

  6. David S. Twining Says:

    Years ago, on my first non-training IFR flight, (from BLI to CVO) there was an airmet for ice above 8000 ft. I filed and was cleared to 6000 but at the OLM vortac ATC had me climb to 7000. It was dark and my first indication that my 182 was picking up ice was a decrease in airspeed. I used carb heat and alternate air but soon realized the engine was putting out full power. At max MP, my speed to maintain level flight went down to 85 kts. OAT was 29 F and I was sure that a descent to the MEA (6000) would get me out of the ice. I asked ATC for 6000 but did not use the “icing” reason for what I now know was an irrational fear of FAA enforcement. ATC replied unable but said I could get 5000 ft, south of the Columbia (about 20 min off). The ice had stopped accumulating and since I was able to maintain altitude I just slogged on, without considering that 85 kts with an iced up wing might be dangerously close to a stall. At length, ATC had me descend to 5000 ft, the OAT came up to 35 F and great chunks of ice came off with loud bangs and chipping of paint. It was only later that thought of how lucky I had been. Since then, I never file IFR when the MEA’s are not comfortably below the freezing level (uncommon, in Pacific NW winters). Otherwise I go VFR underneath, if reasonable, or not go at all.

  7. Joe St.Clair Says:

    Bruce:
    Thanks for a clear and concise statement regarding FIKI. I used to fly pretty loose on this subject as a General Aviation Pilot (no more details please, 5th Amendment and all that) and really learned what I was suppose to do after getting into the Regional Airline business. I very much appreciate the work of AOPA in this particular interpretation request, and agree wholeheartedly in having an “out” available.
    Joe St.Clair
    Grover Beach, CA
    AOPA Member

  8. катринна Says:

    Привет всем!!!
    Можно и такое предположить, хотя…

  9. Jim Byrnes Says:

    I think too few pilots provide iicing PIREPS, perhaps because of concern over violations. Flying in the Northeast and Finger Lakes, icing is very common, especiallly on climb out or descent into fields. When encountered, I try to report it via PIREP or to the controller. It is very helpful to other pilots to know what to expect. The new interpretation may make it less risky for pilots to report icing,since they can normally “pass through” a light icing layer safely and with good alternatives to exit the icing encounter– hopefully providing a resonable defense if ever needed.

  10. Buz Allen Says:

    For all you folks out there who like to temp the ICE Queen, she takes her time in Killing You! Flying a Boeing Kc-135 in the South China Sea on a WX Recon mission at FL 280 we encountered clear ice which locked onto our airframe in a matter of seconds that Flamed Out Three of our Four engines over the ensuing 15 seconds and sent us Plunging Toward the Sea at over 3,000 ft./min. Regaining our composure and double checking the anti-ice switches in the ON position descending through 12,000 ft we managed a RE- Start on 2 Engines all the while completing a 180 degree TURN. Never had I heard of Such an ICE encounter. All four engines were straining at full power at 8,000 ft when massive sheets of ICE departed allowing us to see a Positive indication on the VVI. Lesson Learned. TURN BACK FROM WHERE YOU CAME ! NOW ! FIKI or NOT. The ICE QUEEN HAS No Mercy for the Young or OLD !! HOT Leading edges and Nacelles had been ON for hours before ! NEVER AGAIN !!

  11. Ralph Mahoney Says:

    I flew a P-210 for 7 years certified for FIKI. It took the better part of two years to get all the problems out of the various systems and it was only the grace of god that I wasn’t dropped out of the sky due to deficiencies in the enginieering of the systems (primarily the electrical systems). The electical systems to mitigate ice involved heated boots on the three blades of the propellor, the windshield and the pitot tube. What the POH or instructors that checked me out never told me was if you turned on two or more of these systems at the same time, you would cook (burn out) the alternator and be left without any electrical power — which is what happened to me the first time I used thsse deice systems. I was at 16,000 msl on a flight from Klamath Falls, Oregon to Bellingham, Washington (near the Canadian Border) on an IFR clearance in solid cloud conditions when i noticed a slight build up of ice on the windshield. Since it was not building up rapidly and was in the catefory of “trace ice” I soldierred on. To be on the cautious side, I urned on the prop deice, pitot heat and windshield heater. About 30 minutes later, ATC was losing my TXP and told me to recycle (which did not fix the problem). Then the ADF needle began to wander aimlessly in a 360 degree circle. I reported this failure to ATC. About 5 minutes later, the panel flashed 3 times and everything went dark. I had lost the entire electrical system. No Navigatiion, No Communication — nothing eletrical. I tried recycling the electrical system to no avail and finally turned off the master switch.
    I still had my vacuum pump which powered the Artificial Horizon but I had lost my D.G. I though I was a dead man as here I was in the clouds with a major systems failure and wih no navigation instruments and no compass I thought “it’s all over.” I followed the 1st rule “FLY THE AIRPLANE” and by using the Artificial Horizon was able to keep the wings level and by scanning the airspeed and VSI and Altimeter used that for pitch control.
    About 5 minutes into this emergency, I notice my little Garmins GPS which I had just purchased and mounted on my yoke was alive and well (running off 3 AA batteries). I had pre-programmed in my route so the course line on the little 2.5″ screen gave me heading information — which is what saved me and the airplane that fateful day.
    My $40,000 panel of expensive King equipment was useless but my little cheap Garmin GPS saved the day to get me to my destination. When I landed I felt likd I had come back from the dead. The icing conditions did not give ma any bother as just trace amounts were visible.
    It took several other icing encounters — each one burning out the alternator — before I connected the dots and realized it was the electrical overload of the deicing equipment that was the problem. I assumed Cessna had engineered the plane for FIKI and had taken in to consideration the electical load necessary to support the onboard deicing equipment.
    After replacing 5 alternators in about as many months at $275 each — I finally worked with my local A&P mechanic to have an alternator customised to raise the 90 amp alternator to 200 amps. The guy that did this for me built alternators for Ambulances and Police Cars and thus had lots of experience in this field. By putting in a 200 Amp Stator, Rotar and diode base — I now had sufficient power to handle the deice equipment and flew another 5 years without an electical system failure in dozens of icing encouners.

  12. Ralph Mahoney Says:

    I flew a P-210 for 7 years certified for FIKI. It took the better part of three years to get all the problems out of the various systems and it was only the grace of god that I wasn’t dropped out of the sky due to deficiencies in the enginieering of the many systems (primarily the electrical systems) that supported this complex aircraft.
    The electical systems to mitigate ice involved heated boots on the three blades of the propellor, the windshield and the pitot tube. What the POH or instructors that checked me out never told me was if you turned on two or more of these systems at the same time, you would cook (burn out) the alternator and be left without any electrical power — which is what happened to me the first time I used thsse deice systems.
    I was at 16,000 msl on a flight from Klamath Falls, Oregon to Bellingham, Washington (near the Canadian Border) on an IFR clearance in solid cloud conditions when i noticed trace ice on the windshield. Since it was not building up rapidly and was in the catefory of “trace ice” I soldierred on. To be on the cautious side, I turned on the prop deice, pitot heat and windshield heater. About 30 minutes later, ATC was losing my TXP and told me to recycle (which did not fix the problem). Then the ADF needle began to wander aimlessly in a 360 degree circle. I reported this failure to ATC. About 5 minutes later, the panel flashed 3 times and everything went dark. I had lost the entire electrical system. No Navigatiion, No Communication — nothing eletrical. I tried recycling the electrical system to no avail and finally turned off the master switch.
    I still had my vacuum pump which powered the Artificial Horizon but I had lost my D.G. I though I was a dead man as here I was in the clouds with a major systems failure and wih no navigation or communication instruments and no compass. I thought “it’s all over.” I followed the 1st rule “FLY THE AIRPLANE” and by using the Artificial Horizon was able to keep the wings level and by scanning the airspeed and VSI and Altimeter used that for pitch control.
    About 5 minutes into this emergency, I noticed my little Garmins GPS (which I had just purchased and mounted on my yoke) was alive and well (running off 3 AA batteries). I had pre-programmed in my route so the course line on the little 2.5″ screen gave me heading / course information — which is what saved me and the airplane that fateful day.
    My $40,000 panel of expensive King equipment was useless but my little cheap Garmin GPS saved the day to get me to my destination. When I landed I felt likd I had come back from the dead. The icing conditions did not give ma any bother as just trace amounts were visible.
    It took several other icing encounters — each one burning out the alternator — before I connected the dots and realized it was the electrical overload of the deicing equipment that was the problem. I assumed Cessna had engineered the plane for FIKI and had taken in to consideration the electical load necessary to support the onboard deicing equipment.
    After replacing 5 alternators in about as many months at $275 each — I finally worked with my local A&P mechanic to have an alternator customised to increase the 90 amp alternator to 200 amps. The guy that did this for me built alternators for Ambulances and Police Cars and thus had lots of experience in this field. By putting in a 200 Amp Stator, Rotar and diode base — I now had sufficient power to handle the deice equipment and flew another 5 years without an electical system failure in dozens of icing encouners.
    Later on, a vacuum system failure in IFR at 17,000 msl presented me withh another opportunity to survive by putting my partial panel practice on my simulator to good use. The oversize vacuum pump on the P-210 also inflated the deice boots — so again it left me “naked” for deice capability along with the loss of attitude indication, and the other vacuum driven instruments. Fortunately the air was smooth so the “wings” on the turn co-ordinator served to help me keep the wings level and pitch was maintained as described above. However, it was a challenge to fly an IFR approach in clouds down a valley betwen two mountain ranges to get safely on the ground at the Ely, Nevada airport.
    In 2,500 hours of VFR and IFR flying in American Yankee trainers, Cessna 150′s, 172′s, 182′s 210′s and turbo 210′s, a Piper 160 and a V-tail Bonanza I had never had a failure of any kind. I did a lot of hard IFR and night IFR in several of those planes. Ignorance is bliss indeed. I think back to what could have happened if I had lost electrical systems or a vacuum pump in some of those plane in night IFR in the clouds without a backkup GPS or other backup systems and I tremble.
    Never take a flight without planning for system failures. I had a back up generator and vacuum pump on the P-210 — but both failed when i activated them after the primary system failed. So much for back up systems. What can I tell you?
    1. Whatever happens FLY THE AIRPLANE. The time gained may give you time to sort out what has happened and fly your way out of disaster.
    2. Practice your partial panel flying religiously on a simulator if you fly IFR.
    3. Always have a battery powered GPS (with extra batteries) activated and programmed for your flight. That alone can save your life, especially those newer Garmins which give you simulated Artificial Horizon, HSI, VSI, Airspeed and Altimeter on one screen as well as your course, time to destinaion etc.
    4. And has been said many times already, If flying iinto ice or any IFR flight — always have a plan of escape if your systems go to hades in a handbasket. These airplanes we fly are fragile devices that will let you down at the most inopportune time.
    It took 7 years in a P-210 to teach me how vulnerable you are when you put your trust in these machines. Besides the above, I had hydraulic system faillures (gear wouldn’t come down to locked position and backup hand pump, wouldn’t work), magneto failures due to spark leaping to wrong contact ground at high altitude, pressurization system failures etc,
    By the time I got around to selling my plane, I had overhauled and replaced everything firewall forward and had the 3 last years of ownership without too many system failures. Despite that, I never took a night flight without two flashlights at the ready (one around my neck) to give instant illumination of the panel in case of electrical failure. I carried a good supply of extra batteries and charged up all my backup devices before every trip and kept spares at the ready by me in the cockpit. These devices included a hand held radio, GPS, flashlights etc.
    These are “must have” items for every pilot who wants to live a long life. The old saying is true, “There are BOLD pilots and there are OLD pilots — but there are NO OLD, BOLD PIILOTS. Fate is the hunter but constant vigilance and back up equipment can help you survive the hunter. Be safe up there.

  13. Ralph Mahoney Says:

    When I moved to Montana and purchased a FIKI Cessba P-210 I knew little about the weather patterns in that part of the country. I had done most of my flying prior to that in Southern California and up and down the coastal ststes/provinces of California, Oregon, Washington and British Columbia.
    The pilots in Monatna who flew the Air Freight 6 days/nights a week became my mentors to teach me where the ice was, when to expect it and how to get through it. One rule that stuck with me: Never fly FIKI unless the temperature on the ground you are fllying over is above Zero Centigrada (above freezing). That way, you can melt off the accumulation on final approach if your ground temperatures are a few degrees above freezing…That rule saved me in my worst ice encounter in my FIKI P-210.
    I was flying from Dillon, Montana to Kalispell, Montana on New Years day with 5 souls on board. Winds aloft were 40 to 50 knots out of the west. This reduced my groundspeed on about half the trip to about 115 to 125 knots. When flying west into a headwinds from the west in the mountains, the ice is going to be severe when overflying the east slopes of a valley The rising air coming up those slopes is going to be loaded with ice. My Freight hauler pilot buddies had taught me that.
    On this particular flight, i had to make it over such a ridge line to get into the Flathead Valley. The freight hauler pilots had told me how they did it. Gain about seven or eight thousand feet of extra altitude before you get to the severe ice areas. You can use this extra altitude to “fly downhill into and through the ice” by building up extra speed. This also gives you room to descend safely if your lose partial lift from ice build up.
    So on my new years day flight, I climbed to 18,000 msl so I could “fly downhill” through the ice to 10,000 msl to intersect the victor airway that I would fly northbound up the Flathead Valley to Glacier Park International Airport where I was based. The temperature on the ground was about 42 degrees Fahrenheit and freezing level was about 8,000 MSL so I knew I could go down as low as 5,000 msl if necessary to melt off ice.
    When I was about 10 minutes from the area where I expected possible severe icing, I dropped the nose and started building up airspeed to hasten my trip through the ice. Sue enough, as expected, I hit ice that built so fast you could litterally hear it “whamp” on to the winshield and leading edges. I was cycling the boots about every 30 seconds to shed the two or three inch accumulation on the leading edges.
    The nose down attitude gave me plenty of momentum (about an extra 30 to 40 knots aiirspeed) to descend at a predetermined rate to the intersection and get me through the ice in the minimum time possible. This experience would not have been surviveable without the extra altitude, airspeed and planned penetration through this 5 mile wide wall of ice. At 150 knots plus ground speed, it only took a few minutes to clear this severe ice. But to see ice building at a rate of 4 or 5 inches a minute is something you will never forget. Had I not have been instructed well by the freight hauler pilots about where to expect he worst icing and a mehod of getting through it, I might not be here to tell the story.
    These guys flew their FED EX Cessna Caravans loaded with freight 310 days/nights a year through all kinds of weather. They went eastbound 200 or 300 miles over the mountains to the prairies — leaving about 6 p.m. every week night. After about 3 hours sleep while their plane was unloaded and reloaded they would usually depart about 2 or 3 a.m. arriving back at Glacier International airport about 5 a.m.
    To my knowledge, in the 10 years I lived in Montana nonte of the Caravan Pilots lost their planes or their lives. These Caravans had boots on the landking gear struts as well as the wings and horizontal and vertical stabilizer. They also had eledctric heat around the turbo air intakes, pitot tubes, prop and windshields.
    Some of the crews flying old Beech 99 Turbo Twins were involved in fatal crashes — all of which were blamed on Pilot Error — mistakes on IFR approaches to Airports out on the Prairies with blizzard conditions etc. I was told the Beech 99′s were “a bear to fly” and worked the Pilots to overload due to heavy control pressures etc. In bad turbulence, I was told it took both Pilots to keep the plane under control.
    These guys knew their weather, their airplanes and had techniques to get them safely through the ice, snow, rain and wind. We who have lsesser aircraft and experience should never attempt to match their expertise. There were times, such as freezing rain when they were grounded, but it was rare for them to ever cancel a flight.
    Their highh altitude capability (25,000+ msl) contributed a lot to their ability to survive what would otherwise have brought them down from severe icing conditions. Don’t try what they do unless you’ve flown right seat for a year or so with an old experienced Pilot in a similar aircraft. With thei knowledge of terrain, weather and aircraft limitations, you can survive even Montana Winter weather — which according to FAA stats — is second only to Alaska in weather hazardous to flight.

  14. Steve McCann Says:

    The new icing interpretation makes me reluctant to pirep ice when I find it. I consult and currently use my Mooney (not rated for known icing) to commute twice to three times a month from upstate NY to my home in the Carolinas, (~600 NM). I’ve a commercial ticket and am IFR. Ice and CB scare me enough that I’ve taken Dennstaedt’s courses in both icing and thunderstorms as well as AOPA’s and FAASafety’s.

    That all having been said, yesterday I departed into partly cloudy skies up north, climbed to 8000 and headed home. The only airmets for icing were NY and north 10k to 30k. Over Lancaster, Pa the tops rose around me and I started picking up trace to light rime. I requested and got 10k, (about 1500 ft above the tops) and had no further problem. My normal practice is to call in a pirep to flight watch every flight. The fear of having someone call me later with the interpretation that a “prudent pilot” would have known and avoided… prevented me from doing so.
    While I see some benefit from the new interpretation, if the subtle campaign against GA, started by the previous administration’s FAA administrator continues, (and given the publicity attack on corporate jets, there is in my opinion, no reason to suspect it wont) I’m afraid valuable safety info will be lost.

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