Posts Tagged ‘Cessna’

Assault on GA Down Under

Friday, October 9th, 2015
Nick McGlone

Nick McGlone with one of his Cessna 210s.

I just got off the phone with my good mate Nick McGlone from Sydney, Australia. For decades, Nick has operated Nautilus Air Services at Sydney’s Bankstown Airport. His firm operates a fleet of Cessna 210 Centurions whose primary mission is to haul sushi-grade fresh fish every day from Tasmania to Sydney. It’s roughly 650 miles from Sydney to Tasmania as the crow flies, about one-third of it overwater.

Now 70, Nick might just be the highest time Cessna 210 pilot in the world, with well over 30,000 hours in type. He’s also a master mechanic (they call them “LAMEs” down there) who maintains his airplanes in tip-top shape. He has to because he depends on them to be mission-ready every day.

After we exchanged a few pleasantries, Nick told me that his airplanes hadn’t flown for months and he was not confident that they would ever fly again. That stopped me dead in my tracks; he had my attention.

CASA’s War on Aging Aircraft

Nick explained to me that in recent years, Australia’s Civil Aircraft Safety Authority (CASA)—the Aussie counterpart to our FAA—had been implementing a series of draconian policies calculated to make it economically impossible for owners of legacy GA aircraft to keep them flying. He said that Bankstown Airport—traditionally the busiest GA airport in Australia—had become a virtual ghost town.

It seems that in 2014, the powers-that-be at CASA handed down a startling ruling that all operators of Australian-registered Cessnas would be required to comply with Cessna’s Supplemental Inspection Documents (SIDs). These SIDs set forth an extraordinarily extensive program of structural inspections that Cessna wants performed on a regular basis.

Some of the inspections in Cessna's SIDs are invasive, labor-intensive, and expensive.

Some of the inspections in Cessna’s SIDs are invasive, labor-intensive, and expensive.

Some of these inspections are relatively easy, but some are extraordinarily invasive and labor-intensive and costly. The SIDs specify a complex matrix of initial and repetitive compliance times for these various inspections. The most invasive and labor-intensive ones are to be done initially when the aircraft reaches 20 years old, and then repetitively every 3, 5, or 10 years thereafter. Of course, since all Cessna 300/400-series piston twins and all 200-series singles and the vast majority of 100-series singles are 30-60 years old, all of them are now past due for these inspections.

The FAA has ruled that compliance with these SIDs is strictly voluntary—NOT compulsory—for U.S.-registered aircraft that are maintained in accordance with the U.S. FARs. But CASA’s 2014 ruling was the exact opposite, and mandates that all Australian-registered aircraft MUST comply with the SIDs, whether the aircraft are in commercial service or private use.

Nick said that this is a catastrophe for Cessna owners in Australia (and in other nations like New Zealand and Germany and Spain who have also ruled that the SIDs are compulsory). Although the FAQ on CASA’s website says that compliance with the SIDs should cost about $20,000, Nick indicated that owners are finding that the actual cost of compliance is between $80,000 and $120,000 for Cessna singles, and close to $200,000 for Cessna twins. This is more than many of these aircraft are worth—or WERE worth before CASA made its ruling. Now, says Nick, the market value of these aircraft in Australia has dropped to near-zero, and many Australian owners are being forced to crate up their aircraft and ship them for sale in the U.S. (where compliance with the SIDs is not required).

Not Just Cessnas, Not Just SIDs

This catastrophe isn’t just limited to Cessnas, either. Now that Cessna’s parent company Textron Aviation owns Beechcraft, they’re feverishly working on developing a SID program for Bonanzas and Barons and other aging Beech airplanes. CASA has made it clear that the moment these Beech SIDs are published, CASA will mandate their compliance. There is even a rumor that Piper is working on a SID program for aging Piper airplanes.

All stainless steel control cables on Australian aircraft have to be replaced by the end of 2017.

All stainless steel control cables on Australian aircraft have to be replaced by the end of 2017.

And if that wasn’t bad enough, CASA has a few other tricks up its sleeve to make operation of aging GA aircraft unaffordable in the land down under. There’s a new Australian AD issued last February that requires that all primary flight control cables that use stainless steel end fittings (as almost all do) must be replaced with new cable assemblies by the end of 2017.  And another Australian AD that requires that all propellers undergo a complete disassembly inspection every six years and a major overhaul at the prop manufacturer’s specified TBO. None of these things are mandated by the FAA for U.S.-registered airplanes, nor is there a history of accidents or incidents in either country to justify such costly maintenance burdens on the owners of GA aircraft.

Nick told me that he is convinced that Textron and perhaps other manufacturers simply want their older aircraft to go away, and that they’ve been successful in enlisting CASA and various other national CAAs in helping them to achieve that goal. All of this is shrouded in the mantle of “aviation safety” despite the fact that there’s virtually zero history of accidents being caused by structural failure, control cable failure, or failure of high-time propellers. Nick could be right.

So next time you start griping about the high cost of personal flying, you might pause and thank your lucky stars that you’re based in the U.S. and not in the land down under. Compared to the rest of the world, we American aviators have it mighty good.

The Back Door is Locked

Friday, June 12th, 2015

Cessna 210In my AOPA Opinion Leaders Blog post of September 2014 (“Backdoor Rulemaking?”), I discussed the unprecedented action taken by the Cessna Aircraft Company intended to compel the owners of cantilever-wing Cessna 210s to perform repetitive eddy-current inspections of their wing spars. Finally, I can fill you in on the punch line.

By way of background: Normally, if an aircraft manufacturer believes that an unsafe condition exists that justifies imposing special inspections, component life limits, replacement or overhaul times, or similar burdens on aircraft owners, they go to the FAA and ask for an Airworthiness Directive (AD) to be issued. If the FAA is persuaded that the alleged unsafe condition actually constitutes a significant safety concern and that the burden on owners is reasonable given the safety risk, then the FAA issues a Notice of Proposed Rulemkaing (NPRM) announcing its intention to issue an AD and soliciting comments on the proposal from the affected public. The FAA is then required to consider and respond to all public comments submitted during the comment period before issuing its final rule that makes the AD effective. This same notice-and-comment protocol is required of all executive-branch regulatory agencies of the U.S. federal government by a law called the Administrative Procedure Act (APA).

Indeed, that’s precisely what Cessna did in 2013: It asked the FAA’s Wichita Aircraft Certification Office (ACO) to issue an AD mandating repetitive eddy-current inspections on all cantilever-wing Cessna 210s. But to Cessna’s chagrin, the Wichita ACO turned down Cessna’s request and declined to proceed with an AD, presumably because the ACO was not persuaded that such an AD was justified.

That should have been the end of the matter. But it wasn’t.

In February 2014, Cessna very quietly published a revision to the Cessna 210 service manual that added three new pages to the manual. Those three pages constituted a new section 2B to the manual, titled “Airworthiness Limitations,” that called for the repetitive eddy-current spar inspections. Somehow Cessna persuaded the Wichita ACO to approve this amendment—something the ACO really shouldn’t have done, as you shall see.

Cessna then publicly took the position that compliance with the repetitive eddy-current spar inspections was compulsory because those inspections were now part of an FAA-approved Airworthiness Limitations Section (ALS). Indeed, FAR 91.403(c) compels aircraft owners to comply with mandatory replacement times, inspection intervals, and related procedures specified in an ALS. And FAR 43.16 compels maintenance personnel to perform any inspections or maintenance specified in an ALS precisely “by the book.”

David vs. Goliath?

SlingshotI first learned about this at the beginning of September 2014, when my colleague Paul New—owner of Tennessee Aircraft Services, Inc. (a well-known Cessna Piston Aircraft Service Center) and honored by the FAA in 2007 as National Aviation Maintenance Technician of the Year—discovered the new section 2B in the Cessna 210 service manual, and immediately realized its significance. Paul and I discussed the matter at length, and both felt strongly that Cessna’s actions could not be allowed to go unchallenged.

“If Cessna gets away with this,” I told Paul, “then any manufacturer will be able to effectively impose their own ADs whenever they want, bypassing the notice-and-comment protocol and the other safeguards built into the APA to protect the public from unreasonable government regulation.”

I helped Paul draft a letter to the Rulemaking Division (AGC-200) of the FAA’s Office of General Counsel, questioning the retroactive enforceability of Cessna’s newly minted ALS against Cessna 210s that were manufactured prior to the date the ALS was published (i.e., all of them, given that Cessna 210 production ceased in 1986). Our letter questioned whether Cessna could do what it was trying to do (i.e., make the eddy-current inspections compulsory) within the confines of the APA. We asked AGC-200 to issue a formal Letter of Interpretation (LOI) of the thorny regulatory issues that Cessna’s unprecedented actions raised.

And then we waited. And waited.

AGC-200 initially advised us that they had a four-month backlog of prior requests before they would be able to respond to our request. In fact, it took seven months. It turns out that our letter questioning the enforceability of Cessna’s ALS opened a messy can of worms. AGC-200 assigned two attorneys to draft the FAA’s response, and they wound up having to coordinate with AFS-300 (Flight Standards Maintenance Division), AIR-100 (Aircraft Certification Division), ACE-100 (Small Airplane Directorate), and of course ACE-115W (Wichita Aircraft Certification Office) who mistakenly approved Cessna’s ALS in the first place.

FAA Legal Does the Right Thing

FAA Headquarters

FAA Headquarters
800 Independence Ave.
Washington DC

Finally, on May 21, 2015, AGC-200 issued the Letter of Interpretation (LOI) that we requested. It was five pages long, and was everything we hoped it would be and more. It slammed shut the “rulemaking backdoor” that Cessna had been attempting to use to bypass the AD process, locked it once and for all, threw away the key, and squirted epoxy glue in the lock for good measure. You can read the entire LOI in all its lawyerly glory, but here’s the CliffsNotes version of the letter’s key bullet points:

  • Under FAR 21.31(c), an ALS is part of an aircraft’s type design.
  • The only version of an ALS that is mandatory is the version that was included in the particular aircraft’s type design at the time it was manufactured.
  • Absent an AD or other FAA rule that would make the new replacement times and inspection intervals retroactive, Cessna’s “after-added” ALS is not mandatory for persons who operate or maintain the Model 210 aircraft, the design and production of which predate the new ALS addition. The “requirements” set forth in the ALS would only be mandatory for aircraft manufactured after the ALS was issued. And of course, production of the Cessna 210 ceased in 1986.
  • If operational regulations were interpreted as imposing an obligation on operators and maintenance providers to comply with the latest revision of a manufacturer’s document, manufacturers could unilaterally impose regulatory burdens on operators of existing aircraft. This would be legally objectionable in that the FAA does not have legal authority to delegate its rulemaking authority to manufacturers. Furthermore, “substantive rules” can be adopted only in accordance with the rulemaking section of the APA (5 U.S.C. § 553) which does not grant rulemaking authority to manufacturers. To comply with these statutory obligations, the FAA would have to engage in its own rulemaking to mandate the manufacturer’s document, as it does when it issues ADs.

The bottom line is this: Manufacturers of certificated aircraft* are not permitted to impose regulatory burdens on aircraft owners by changing the rules in the middle of the game. Only the FAA may do that, and only through proper rulemaking action that complies with the APA (including its notice-and-comment provisions and other safeguards). If you ever encounter a situation where the manufacturer of your aircraft tries to do this, call their cards—the FAA lawyers will back you up.

*NOTE: The rules are completely different for S-LSAs.  The manufacturers of S-LSAs can do pretty much anything they like, and their word is the law. (A seriously flawed situation IMHO.)

The LOI concluded with the following surprising paragraph:

On February 19, 2015, the FAA’s Small Airplane Directorate sent a letter to Cessna that addressed some of the above issues, and pointed out the non-mandatory nature of the after-added ALS for the Model 210 aircraft. The FAA asked Cessna to republish the replacement times and inspections as recommendations that are encouraged, but optional, for those in-service aircraft, unless later mandated by an AD. To date [three months later –mb] Cessna has not provided a written response outlining its position on this matter.

Are we having fun yet?

Happy Birthday Garmin G1000 – 10 Years

Wednesday, May 28th, 2014

G1000 Birthday Cake 10th AnniversaryCongratulations to Garmin on introducing the G1000 ten years ago. I bet most readers are surprised that this wildly successful glass cockpit has been around so long. If you still haven’t flown one of these fun systems yet, don’t let another ten years slip by before you do!

A Brief History
Rarely in the last fifty years has General Aviation experienced such a tidal wave of change. In only two years, the industry converted nearly 100% of piston aircraft shipments from round gauges to glass cockpits. And for the first time, it meant that a student pilot could learn behind the same glass panel that he or she might later use in a jet!

Cirrus and Avidyne led the revolution in 2003 by adding a PFD (Primary Flight Display) to the MFD (Multifunction Display) that already shipped in the SR20 and SR22. That glass cockpit system, the Avidyne Entegra had its greatest success at Cirrus until the Cirrus Perspective, a G1000 derivative, debuted in the SR22 in May 2008.

The Garmin G1000 was first shipped in a Diamond DA40 in June 2004. Meanwhile, in Independence, Kansas, nearly completed Cessna 182’s were filling the ramp as the factory awaited their G1000 deliveries. The first Cessna 182/G1000s were delivered in July 2004 and 172s began shipping with the G1000 in early 2005.

By mid-2005, five aircraft OEMs including Cessna, Diamond, Beechcraft, Mooney, and Tiger announced shipment of the Garmin G1000 in most of their piston aircraft. Columbia, which previously offered the Avidyne Entegra in their 350 and 400 aircraft, converted to the G1000 in early 2006, though not without a major problem from Mother Nature. Nearly 50 new Columbias were parked outside the factory, all awaiting delivery of G1000 systems, when a freak hailstorm pelted the planes. Months were spent quantifying the damage and determining how and if to repair the composite wings, which had hundreds of micro dents from the hail.

The Revolution
Reading or hearing about a glass cockpit for the first time is akin to reading or hearing about EAA’s AirVenture at Oshkosh. Until you actually experience it, it’s hard to imagine just how great it is and how much it will exceed your expectations.

I was initially skeptical when I read magazine reports about the then new G1000. I’d spent 25 years working in the high technology industry, where occasionally I saw technology thrown at problems that could have been solved in simpler ways. So when I first read about the G1000, I recall thinking “What a waste of a computer,” to install one in the instrument panel of a GA aircraft. How wrong I was.

By early 2005, curiosity led me to get an hour of dual instruction in a G1000-equipped Cessna 182. Immediately I knew it was different, but I didn’t want to rush to judgment until I’d had time to reflect on the experience.

I wrote about my conclusion in Max Trescott’s Garmin G1000 and Perspective Glass Cockpit Handbook

“The single biggest benefit of the G1000 and Perspective, compared to competitive products, is that it allows you to aviate, navigate and communicate from a single 10-inch or 12-inch display. In contrast, competitive products have pilots looking in multiple places to see data and reaching in multiple places to operate controls.”

Having your eyes near the primary flight instruments all the time reduces the odds of entering an unusual attitude while tuning a radio or entering a GPS flight plan. Plus, the 10-inch wide artificial horizon is far superior to the 2-inch airplane symbol found in most round gauge attitude indicators. But that’s just the beginning. Glass cockpit aircraft contain many safety features, like traffic, terrain, and weather information that have the potential to reduce accidents when pilots are trained in their use and use them properly.

Glass cockpits have also changed the paradigm for avionics. Historically, avionics stayed on the market for many years with few changes until entirely new models replaced them. Quoting again from my G1000 Book, “The G1000 system clearly breaks this paradigm. First, with two large software-driven displays, new features can be continually be added to the G1000 in far less time than it took to design, manufacture, and release traditional avionics…The Ethernet bus architecture also makes it easy for new devices to be designed and connected to the G1000.”

But if engineering school taught me anything, it was that there are tradeoffs in every design decision. Today’s new computer and software-based avionics, as good as they are, occasionally suffer from the same woes seen in the computer world. For example, one time a Columbia 400 equipped with TAS, an active traffic system, came back from maintenance with TIS, a less capable traffic system. It turned out the maintenance personnel forgot to reload the software for the TAS system, so it effectively disappeared!

The Future
So where are we headed? Undoubtedly, Garmin will pack a few more new features into the G1000 and Perspective through software upgrades and possibly more hardware additions. So existing owners can expect some new features. Eventually the speeds of the now ten-year old processors will limit upgradability. But it is a modular architecture, so Garmin might in the future offer new hardware modules to provide G1000 and Perspective owners with an upgrade path that adds robust new features.

The G1000 and Perspective may appear in a few more aircraft types, possibly as retrofits to older turbine and jet aircraft and perhaps in a few new aircraft types. But Garmin now offers the G2000, G3000, and G5000 on the high end and the G300 on the low end, so that keeps the Garmin G1000 from moving up or down into these markets. I don’t expect to see the G1000 being retrofitted into many older single engine piston aircraft. With the average age of the GA fleet approaching 40 years, the cost of the upgrade would exceed the value of most of these planes, so the market opportunity is too small for Garmin to pursue. However these older aircraft are an excellent target market for partial glass cockpit upgrades using solution like Aspen Avionics and portable iPad solutions.

Of course someday the G1000 will be replaced with something new. The workhorse Garmin 430 shipped for about 14 years. But the G1000 is more upgradeable, so it could conceivably have a longer product life cycle. And there’s always the possibility that Bendix/King, or another competitor, could introduce a new product that replaces the G1000 in a future refresh of new aircraft cockpits.

The impact of the G1000 and other glass cockpits cannot be overstated. For years, airline pilots told me the G1000 “was better than what I have in the airliner I fly.” But sadly, glass cockpit-equipped aircraft are still a small fraction of the overall GA fleet, partially because of the slowdown in new aircraft sales since the 2008 recession. Most pilots still aren’t flying in them and thus aren’t benefiting from their safety advantages.

So on the tenth birthday of the G1000, we should thank Avidyne and Cirrus for starting the glass cockpit revolution in GA aircraft, and thank Garmin and Cessna for making it such a widespread phenomena. Kudos to all of these companies for their great work! Now let’s get started on the next revolution in General Aviation…What do you think it will be?