A fatal V-35 Bonanza crash in New York earlier this month highlights some desperately needed changes to our aging aircraft. Comments about the crash are speculative as the investigation is in the preliminary stage. Early information said the pilot mentioned a loss of the vacuum pump and flight instruments while on an IFR flight in weather. Without solid backup equipment or expert pilot response that usually leads to a spiral dive and an unhappy outcome. And, when the autopilot is needed the most, the brains (the attitude indicator) are rendered inoperable. This is, unfortunately, a timely reminder of something that both the National Transportation Safety Board (NTSB) and the AOPA Air Safety Institute (ASI) have been focusing on over the last several years—loss of control (LOC). See ASI’s Aerodynamics Safety Spotlight for an arrangement of LOC-prevention education, such as the benefits of angle of attack indicators, how to prevent power-on stalls, as well as understanding the pros and cons of maneuvering flight, and preventing and recognizing spatial disorientation.
While earning the instrument rating, we all demonstrated our partial-panel prowess a few times under controlled circumstances—it can be done, as you’ll see below, but it’s challenging. In my view, it’s better to have solid instrumentation (redundancy and an autopilot) that’s easy to use, reliable, and affordable rather than depend on one’s obviously superior piloting skills!
Years ago, a 25-hour vacuum pump failed me in solid IMC near Peoria, Illinois. The Piper Turbo Arrow had no alternate vacuum, just the good old turn coordinator to keep things upright. Called Peoria approach for vectors to the ILS with weather reported at about 400 overcast and two miles visibility. Perhaps I was luckier than being good, and a backup system was installed before the next IFR flight.
That 1977 aircraft was built long before we learned that vacuum pumps are about as reliable as campaign promises. In the early 80’s, the industry standard became two pumps for any new IFR-certificated aircraft and accidents due to pump failure declined. We’ll have to wait for the final report on the Bonanza to learn more and perhaps why the pilot didn’t have another instrument power supply if that’s the case. With the arrival of electronic flight bags (EFB) and synthetic vision, there’s yet another alternative so everyone’s encouraged to have an out when flying in any serious IMC.
There’s some hope on the artificial horizon but it can’t come fast enough for the victims of the New York accident and the others that will die in IMC loss-of-control accidents before the rules change. The FAA, AOPA, General Aviation Manufacturers Association ( GAMA), and EAA have been working on this for years. Finally, Congress got involved, directing the agency to have a new rule in place by the end of 2015. You may have noticed we’re a little behind.
It’s hard to believe, but in this 21st century experimental aircraft are flying every day in IMC with non-technical standard order (TSO) approved avionics. I don’t recall hearing of many loss-of-control accidents due to failed electronic primary flight displays (PFD) because they have the needed redundancy built in.
The FAA and EAA recently announced a supplemental type certificate project for a Dynon non-TSO’d attitude indicator that has been used on many experimental aircraft to be allowed in certificated aircraft. The FAA defines, “A supplemental type certificate (STC) is a type certificate (TC) issued when an applicant has received FAA approval to modify an aeronautical product from its original design.” That’s good but still only a half step forward since it only applies to a very small subset of aircraft, many of which don’t spend much time in IMC.
More than 30 years ago the FAA made a change when FAR Part 23 was developed that mandated any required equipment must meet an FAA TSO. “A TSO is a minimum performance standard for specified materials, parts, and appliances used on civil aircraft. When authorized to manufacture a material, part, or appliances to a TSO standard, this is referred to as TSO authorization…” Wait, there’s more, “Receiving a TSO authorization is not an approval to install and use the article in the aircraft.” Only in Federal regulation can there be such an Alice-in-Wonderland rule.
This was a major change because non-TSO’d equipment was perfectly acceptable under the FAA’s predecessor manufacturing rule, CAR 3. There was absolutely no data showing that it was unsafe and this also was about the time prices started a rapid upward spiral. Coincidence? It also set a bad precedent by lumping all Part 23 aircraft into one bucket—anything from a Cessna 172 to a Citation was treated the same! That will presumably change under the revised rule.
AOPA and GAMA have been pushing the FAA to go well beyond the recent STC discussion to allow proven non-TSO’d equipment in certificated aircraft. There are some other paths through the woods, as well, such as a parts manufacturing approval (PMA.) It opens the door for some desperately needed upgrades. The equipment could be signed off as a minor modification, as appropriate, by a mechanic or avionics technician.
Might there be some miscues in the transition? Possibly, but rest assured that the marketplace will self-correct much faster than the regulatory system through the courts and social media. Remember that a TSO, STC, or PMA doesn’t shield a manufacturer from liability—an interesting interpretation of federal preemption in all matters aviation—but that’s another discussion.
It’s well past time to recognize that while a fully TSO’d avionics upgrade may be the perfect solution it is unaffordable and thus unobtainable for much of the aging fleet that needs it the most. The “perfect” is the enemy of the “much better.” Non-TSO’d PFD systems (that have been tested tens of thousands of times without failures resulting in a fatal accident) from major avionics manufacturers, with every redundancy included, cost about half of the currently approved systems.
Let’s be clear, nobody wants lousy, poorly engineered, possibly dangerous equipment installed, but the pendulum has swung too far. I’m certain there will be a provision to keep Bruce’s New-Age Avionics & Storm Door Company products from being approved until there is a solid track record or other means acceptable to the administrator. Perhaps the industry will rapidly embrace the idea of consensus standards.
The overhaul to FAR Part 23 is just completing the public comment stage. It will likely be at least another year or more before any real change is seen in the field to start installing equipment. Please prove me wrong! To my FAA friends—please, there needs to be a sense of urgency. Perhaps the NTSB will join in the quest.
The New York accident and others like it result in massively expensive litigation with lives lost, general aviation gets another black eye, and this industry continues in its own LOC spiral. Bottom line: The new equipment works very well, costs considerably less, and requires much less partial-panel training to save lives. Sign me up.