Posts Tagged ‘general aviation’

Thinking, Fast and Slow

Wednesday, January 21st, 2015

Not long ago, I had a fascinating exchange with my friend and colleague Paul New. Paul is an A&P/IA and a truly extraordinary aircraft mechanic who was honored by the FAA as the National Aviation Maintenance Technician of the Year in 2007 (the year before I was so honored). But that’s where the historical similarity between me and Paul ends.

Paul New A&P/IA

Paul New, A&P/IA, owner of Tennessee Aircraft Services
and a truly extraordinary aircraft mechanic.

While I came to aircraft maintenance rather late in life, Paul has been immersed in it since childhood, helping his A&P/IA dad with numerous aircraft restoration projects well before he was tall enough to see over the glareshield without sitting on a phone book.

In 1981, Paul earned his degree in Avionics Technology from Southern Illinois University, and spent five years managing avionics shops for a commuter airline and an FBO. In 1986, he returned to Jackson, Tenn. to work with his dad in the aircraft restoration business once again, and in 1989 he purchased Tennessee Aircraft Services, Inc. from his dad and developed it into one of the premier Cessna Service Centers in the southeast US, performing both general maintenance and major structural repairs.

Over the years, Paul and I have formed an informal mutual admiration society, and frequently bounce problems, thoughts and ideas off one another. That’s exactly what was happening when we got into the conversation I’d like to share with you.

Cessna P210 engine problem

Paul emailed me about one of his customers who had recently encountered an engine problem shortly after takeoff on a recurrent training flight (with a CFI in the right seat). The owner/pilot told Paul that at about 400’ AGL, he noted a serious overboost, five inches over MAP red-line, and throttled back to bring the MAP back to red-line. At that point, according to the pilot, the engine started running very rough. The pilot elected to put the airplane down on the crossing runway, landed long and hot with a 17-knot tailwind, and took out the chain link fence at the far end of the runway. Paul was on his way to the scene of the incident to ferry the aircraft back to his shop for repairs.

Upon hearing his customer’s tale of woe, Paul’s first thought was that the pilot may have turned on the electric boost pump for takeoff, something you’re not supposed to do in the P210. According to Paul, “Leaving on the boost pump is a common mistake in Cessna 210s, particularly with pilots who are used to flying Lycoming-powered airplanes where turning on the boost pump for takeoff is SOP.”

Show me the data!

Paul arranged for his customer to dump the data from the P210’s JPI EDM-830 digital engine monitor data and to upload it to the SavvyAnalysis.com website. Paul asked whether I’d be willing to take a look at it and give him my impressions, and I told him I’d be happy to do that.

P210 Engine Monitor Data

The engine monitor data told a different story than the pilot did.
Which would you believe?

When I looked at the engine monitor data, it seemed to tell a very different story than the one that the pilot had related Paul. I couldn’t see any evidence that the pilot flooded the engine by using the electric boost pump; the fuel flow data looked normal. Nor could I see any evidence that the pilot throttled back the engine (as he told Paul he’d done), because throttling back would have reduced fuel flow and the engine monitor recorded no reduction in fuel flow. What the data indicated was simply that the wastegate stuck closed on takeoff (causing the overboost) and then subsequently unstuck, reducing MAP to what it was supposed to be without any pilot input.

I also observed that while five of the six CHTs were rising as expected after takeoff power was applied, the CHT for cylinder #3 was falling, suggesting that cylinder #3 wasn’t making full power. If one cylinder wasn’t making full power, that would certainly account for the engine running rough. My diagnosis was that something went wrong with cylinder #3 after takeoff—maybe a clogged fuel nozzle, maybe a stuck valve—that caused the engine to run rough and scared the pilot into making a hasty and poorly executed downwind landing.

In reporting this to Paul, I added that “when confronted with significant dissonance between what a pilot reports and what an engine monitor reports, I’m inclined to believe the engine monitor.”

Do mechanics know too much?

Paul’s reply intrigued me:

Mike, thanks for the analysis. I agree with your diagnosis. But what I find most telling is the difference between my “mechanic’s analysis” and your “analyst’s analysis.” At the end of the day, I think like a career mechanic with decades of history crammed into my head, and my experience as a mechanic prejudices my view. Because the pilot’s account of events made me think of many occasions when Lycoming pilots get into a Continental airplane and turn on the electric fuel pump for takeoff, I was already spring-loaded to look for information to support this hypothesis.

My takeaway from this is that I—and I believe career mechanics in general—are  the wrong people to analyze engine data. Career mechanics carry too much mental baggage to be effective as analyst. What I see mechanics not doing well is “connecting the dots” to analyze an unusual event. It also occurs to me that we mechanics might do better if we looked at the engine monitor data first before we talk to the pilot. I think that would help us to evaluate the data more objectively.

Of course, I’m also a mechanic, but I don’t consider myself a “career mechanic” like Paul. I haven’t been working on airplanes since before puberty the way Paul has, and I’ve never made my living swinging wrenches the way Paul does. I don’t have those decades of real-world experiences crammed into my brain, so I tend to analyze things more “from first principles” while career mechanics like Paul tend to analyze them through “pattern matching” against the historical library in their noggins.

Thinking, fast and slow

Daniel Kahneman's book "Thinking, Fast and Slow"

Nobel laureate Daniel Kahneman’s book discusses human “two-system thinking” and explains its pitfalls.

In his 2011 book Thinking, Fast and Slow, economist and Nobel laureate Daniel Kahneman postulates that the human brain operates in two fundamentally different modes:

  • System 1 thinking:Operates automatically and quickly with little or no effort. It is fast, intuitive, emotional, and subsconscious.
  • System 2 thinking:Operates deliberatively and requires conscious effort. It is slow, rational, logical and calculating.

A student pilot relies on controlled System 2 thinking, requiring focused concentration on performing a sequence of operations that require considerable mental effort and are easily disrupted by distractions. In contrast, an experienced pilot, relying on automatic System 1 thinking, can carry out the same tasks efficiently while engaged in other activities (such as talking to ATC or calming a nervous passenger). Of course, the pilot can always switch to more conscious, focused and deliberative System 2 processing when he deems that to be necessary, such as when encountering challenging weather conditions or dealing with equipment failure.

Similarly, career A&P mechanics rely primarily on fast, automatic System 1 thinking. (Imagine what your maintenance invoice totals would be if they didn’t!) The more experience a mechanic has, the stronger his System 1 skills become. This kind of thinking serves the mechanic well most of the time, but it can break down when a challenging troubleshooting problem demands switching to slow, deliberative, thoughtful, logical System 2 thinking. Career mechanics often don’t have the time or training to flip that switch.

System 1 thinking is fast and easy and economical and even magical at times. The problem is that sometimes it yields the wrong answer. Consider this simple problem:

A bat and a ball together cost $5.50. If the bat costs $5 more than the ball, what does the ball cost?

Most people who look at that problem find that an answer—50 cents—pops into their mind immediately, effortlessly and without any conscious calculation. It’s intuitive, not reasoned.

It’s also wrong. The correct answer is 25 cents. To get the correct answer, most people have to consciously switch into “System 2 mode” and recognize that this is an algebra problem:

x + y = $5.50
x = y + $5.00
y = ???

Presented in that fashion, most people get the right answer. But such problems generally do not announce themselves as algebra problems. It takes training and skill to recognize when the mental switch needs to be flipped.

Do we need a new mechanic rating?

I attribute my skill as a troubleshooter largely to my training as a mathematician and my 30-year career as a professional software developer, both fields that deal with complex abstraction and absolutely demand strong System 2 thinking. At SavvyAnalysis.com, most of our professional engine monitor data analysts are not A&P mechanics. One is a genomics researcher, two are aeronautical engineers, and yet another is an award-winning music composer—all fields that require a great deal of System 2 thinking. It’s rather rare to find career A&P mechanics with these sorts of backgrounds.

Other professions—notably medicine and education—recognize that diagnosis and therapy (or troubleshooting and repair, if you prefer) are dramatically different activities that require dramatically different skill sets. We don’t expect our neurosurgeons to interpret CT scans or analyze tissue samples or evaluate blood labs—we rely on radiologists, pathologists and hematologists for those things.

Similarly, I think perhaps it’s time that we stopped relying on career A&P mechanics—who are basically aircraft surgeons—to troubleshoot difficult problems, and started recognizing “mechanic-diagnostician” as a new aviation maintenance specialty. What do you think?

AOPA’s Regional Fly-Ins Connect Us All

Monday, January 12th, 2015
Plan now to attend

Plan now to attend

I was so happy to see the release of the dates and locations of AOPAs regional fly-ins last week. It reminds me of how big and small our world of aviation is. These free community events bring us together as lovers of all things aviation. A secondary benefit is to the communities that host the fly-in. Salinas, CA, Frederick, MD, Minneapolis, MN, Colorado Springs, CO and Tullahoma, TN will all experience the literal and figurative buzz from airplanes and helicopters as thousands make their way to the one-day events.

I believe that events at airports help the surrounding communities to see them as good neighbors. The more that we can bring folks to the airport for a positive experience, the more likely the public is to remember that when perhaps there is a noise issue. It also helps to highlight the multiple facets of our airports. Yes, airports are a transportation hub. But they are also an economic engine for the community bringing in business, pleasure, emergency response, recreational and charitable flights.

Having participated in all of the AOPA Regionals last year, with my service group, the Mooney Ambassadors, I have to say “hats off” to AOPA and whoever thought of the regional fly-in idea. The events were very well planned, implemented expertly and had a very friendly and approachable feel to them.

EAA's Jack Pelton, Mooney Ambassador Ed Mandibles

EAA’s Jack Pelton and Mooney Ambassador Ed Mandibles

I remember that early in the morning of the Chino, California event we had EAA’s Jack Pelton and nationally known aviation humorist Rod Machado stop by our display.  For me, these are famous people, yet they were sipping coffee strolling among the displays. It was so fun to have them look at Ed Mandible’s M18 Mooney Mite. This camaraderie to me means EAA supports AOPA, AOPA supports EAA. We all win.

EAA’s AirVenture at Oshkosh, WI is like Disneyland for aviators. It should be noted that I am a big fan of Oshkosh and have attended yearly for the past 6-7 years. One draw back to AirVenture might be work or geographical limitations that prevent us from attending a week-long show. With the regional format, I believe that we can might reach more aviation lovers. The day long event was also an avenue for meeting future pilots, and non-current pilots.

With the regional format I believe that any pilot would be hard-pressed to find a better opportunity to see nationally known speakers, authors and presenters in one place. When we consider that this event is free of charge that is just the icing on the cake. There will be volunteer opportunities as well, so if you can lend a hand, make sure to do so.

Now that the schedule has been published, make sure to mark your calendars, register and attend. Our aviation community is large, but these type events have a hometown feel that is just spectacular. Take advantage of the educational opportunities. Make sure to get there early to visit the exhibitors and vendors. Why not plan attendance with several planes from your home airport? Many of the venues offer free camping the day before and of the event. While there, when you see someone in the familiar khaki pants and blue AOPA shirt, thank them for their part. . Most of all come. When we join together, we have a unified voice. We need to protect our airports and promote General Aviation. Whether you fly-in or drive-in you will be happy you did.

AOPA PYM

AOPA PYM

Who’s the Best Pilot?

Monday, December 22nd, 2014

One of the many iconic scenes (so much so that it recurs several times in the film) from The Right Stuff has astronaut Gordon Cooper asking his wife, “Who’s the best pilot you ever saw?” before answering his own question: “You’re lookin’ at him!” Gordo was telling a joke, of course, but it got me thinking about what constitutes a great pilot in the real world.

Accident statistics show that when light GA pilots try to operate on a firmly fixed schedule — for example, around the holidays — the risk level increases. AOPA recently published an Air Safety Alert to that effect, noting “a cluster of GA accidents occurring in close succession.”

Some of this probably has to do with the fact that the holiday season occurs in the winter for those of us living in the northern hemisphere. While the hot months have their own set of challenges, they tend to consist of things which present equal hazard to all aircraft: thunderstorms, high density altitude, etc. But whereas large multi-engine turbojets are well-equipped for cold weather flying, single-engine recips typically operate with minimal anti- and de-icing equipment, if any.

Anyway, it occurs to me that this kind of flying is exactly what we do in the Part 135 world. We operate on someone else’s timetable, and rarely is that schedule created with weather, circadian rhythm, airport staffing hours, or other such operational concerns in mind. As you might expect, the 135 safety record — while far better than Part 91 — does not reach the rarefied heights of the scheduled airlines. Some people feel it should. There are plenty of folks who feel Part 91 should reach that strata as well.

I tend to disagree.

Part 135 has the flexibility to operate at random times and into a far wider variety of places than scheduled airlines. While we do everything possible to make the flights as safe as humanly possible, flexibility cannot help but exact a price. Flying worldwide charter, I don’t know if my next trip will take me to Liberia or Las Vegas. I have to be prepared to go anywhere.

If that sounds incredible, then light general aviation flying should really blow your mind! The non-commercial Part 91 aviating so many of us do for personal reasons takes that freedom and ramps it up a hundred fold. Not only can you go anywhere you want at any time it suits you, you can do it at night, in IMC, in formation, and fly some aerobatics or sight-see along the way. You can fly a weird experimental airplane that you built in your garage. You can tow banners. Drop things from your airplane, then cut them up as they fall to earth? Yes, that’s fine. Fly high… or low. You can change your destination in mid-flight without asking anyone’s permission.

Heck, you can even take off with no destination whatsoever; those are some of my most cherished flights. When I call the VFR clearance delivery frequency at John Wayne Airport and they ask where I’m headed, nothing says freedom quite like using William Shatner’s response from the first Star Trek film: “Out there. That-a-way!”

Wrapping your mind around having the liberty to do those things while not being able to install a radio in your panel without approval from a certification office somewhere in Oklahoma City could cause a migraine… but let’s leave that for another day.

The point is, with added freedom comes added risk. And responsibility. It’s ironic that we think of airline pilots as having the greatest weight on their shoulders when rules, procedures, and operational specifications dictate almost everything they do. I’m not saying their job is easy. It ain’t. But if you’re not in awe of the authority and self-determination placed on your own shoulders every time you launch, think about this: we could have the safety record of the major airlines. All we’d need are the same rules and requirements for flight that they use. Seems to me that would be an awful lot like asking Santa for a big, dirty lump of coal in your stocking.

If there’s a way to have the freedom to land on five hundred foot long strips on the side of a mountain, tackle water runways, engage in flight training, and — most of all — fly to that family Christmas in an airplane with just one reciprocating engine without significantly higher risk than you’ll find on a typical airliner, I’d be quite surprised. But one thing every pilot has in common is that risk management is a major part of the job.

So as you contemplate that cross-country flight to celebrate the holidays with your loved ones, remember that the best pilot isn’t the one who finds the cheapest fuel, stuffs the most presents into the baggage compartment, or makes the softest landing. It’s the one who best manages the risk inherent in that flight.

Right, Gordo?

It’s not about the nail! Well maybe it is.

Saturday, December 13th, 2014
Work to keep your airport an airport

Work to keep your airport an airport

 

This month’s blog is a bit eclectic I will admit. Perhaps it is because the holidays are right around the corner, or the New Year is about to begin. As I reflect on the past couple of months in our aviation world I keep getting drawn back to a beautiful and historic airport, KSMO Santa Monica. As many of you know, the citizens of Santa Monica, CA recently voted on two initiatives directly related to the health and vitality of the iconic GA airport.

The grassroots group Santa Monica Voters for Open and Honest Development Decisions was successful in placing a ballot measure which would have required the City of Santa Monica to get approval from the voters with any changes or re-development of the airport. The residents did not support the ballot measure or the airport. Yet, the work of keeping SMO an airport will continue. I believe we are called to take a larger and a smaller view, both in Santa Monica and for all of us around the country.  I will attempt to explain.

When I was in graduate school for social work, we were trained to look for the macro and the micro view of the presenting problems of our clients. In a nutshell we have to look at the big picture and the small, the global and the personal. When we think about change, loss, or transition we need to see the forest and the trees.  As a psychotherapist the majority of my work is with clients undergoing change and an opportunity for growth.

Embrace Growth

Embrace Growth

 

This blog post from Mystic Mamma seems to fit the micro-bill. “It is very likely that our personal metamorphosis may feel chaotic, painful and very uncomfortable. Breathe and allow it, know it won’t last and it is a moving energetic flow. Then we are moving along with it all than clenching down and blocking the flow of energy. Truly, we may not be in control over the evolutionary force or how long things last in the growth and or healing, yet we have the option to make a conscious powerful choice to move with ease and effortlessness through non-resistance and knowing we are guided and supported by all of life.”   http://www.mysticmamma.com/

For me, this means knowing that change is hard, that believing in something and having to change your view is tough psychological work.   I also remember some very early advice I got from a leader in the GA community. He said, “Always be positive, in public, in the media, in your writing,  always be positive.”

How does this apply to aviation? We all, are airport, and airplane, lovers. When it comes to our local airport, we need to think small. By that I mean local level, community-based. How can your airport serve your community in non-aviation needs? Perhaps this would look like a space for community meetings, a host of a canned food drive, or a fund-raiser for the local humane society. With our home airports, sometimes we need to step up, raise our voices and let our opinions be known. This might mean speaking in front of the airport board, or county commissioners. Use your local airport as a resource. Bring the community inside the fence. We need to be able to tell the truth. If someone wants to do something unsafe at an airport, speak up. We need to be on guard for encroachments, misapplications of directives, and oppressive policies.

The second level of involvement is in between micro and macro, it is the state level. Are you involved with your state aviation association? Do you know who your regional director for AOPA is? Do you have a Representative or Congressman from your state on the GA Caucus? Have you thought about becoming involved with aviation at the state or regional level?

It's not about the nail

It’s not about the nail

Click on  this photo to the left for a fun look at the macro view.

 

In sum, let’s see the forest and the trees. Do what you can locally, today. Check in to your regional and state opportunities. Be an active member in our national associations. Together we can all see the nail, and pull it out!

A Self-Evident Solution

Monday, November 24th, 2014

Times are tough for general aviation, and we need a solid partner and advocate in Washington now more than ever. Unfortunately, the FAA is proving to be the exact opposite—a lead weight—and it’s becoming a big problem.

Complaining about the FAA has been a popular spectator sport for decades. I feel for those who work at the agency because most of the individuals I’ve interacted with there have been pleasant and professional. They often seem as hamstrung and frustrated with the status quo as those of us on the outside. In fact, I took my commercial glider checkride with an FAA examiner from the Riverside FSDO in 2004 and consider it a model of how practical tests should be run. So I’m not suggesting we toss the baby out with the bathwater.

But somewhere, somehow, as an organization, the inexplicable policy decisions, poor execution, and awful delays in performing even the most basic functions lead one to the conclusion that the agency is beset by a bureaucratic sclerosis which is grinding the gears of progress to a rusty halt on many fronts.

Let’s look at a few examples.

Example 1: Opposite Direction Approaches Banned

If you’re not instrument-rated, the concept of flying an approach in the “wrong direction” probably seems… well, wrong. But it’s not. For decades, pilots have flown practice approaches in VFR conditions for training purposes without regard for the wind direction. There are many logical reason for doing so: variety, the availability of a specific approach type, to practice circling to a different runway for landing, and so on. John Ewing, a professional instructor based on California’s central coast, described this as “going up the down staircase”.

For reasons no one has been able to explain (and I’ve inquired with two separate FSDOs in my area), this practice is no longer allowed at towered fields. Here’s what John wrote about the change:

…the FAA has decided that opposite direction approaches into towered airports are no longer allowed. To the uninitiated, practice approaches to a runway when there’s opposite direction traffic may seem inherently dangerous, but it is something that’s been done safely at many airports for as long as anyone can remember. One example in Northern California is Sacramento Executive where all the instrument approaches are to Runway 2 and 90% of the time Runway 20 is in use.

At KSAC, the procedure for handling opposite direction approaches is simple and has worked well (and without incident, to my knowledge): The tower instructs the aircraft inbound on the approach to start their missed approach (usually a climbing left turn) prior to the runway threshold and any traffic departing the opposite direct turns in the other direction.

For areas like the California Central Coast, the restriction on opposite direction instrument approaches has been in place since I arrived in June and it has serious implications for instrument flight training since the ILS approaches for San Luis Obispo, Santa Maria, and Santa Barbara are likely to be opposite direction 90% of the time. For a student to train to fly an ILS in a real aircraft, you need to fly quite a distance. Same goes for instrument rating practical tests that require an ILS because the aircraft is not equipped with WAAS GPS and/or there’s no RNAV approach available with LPV minima to a DA of 250 feet or lower.

The loss of opposite-direction approaches hurts efficiency and is going to increase the time and money required for initial and recurrent instrument training. As good as simulators are, there’s no substitute for the real world, especially when it comes to things like circling to land. Between the low altitude, slow airspeed, and division of attention between instruments and exterior references required for properly executing the maneuver, circling in low weather can be one of the most challenging and potentially hazardous aspects of instrument flying. If anything, we need more opportunities to practice this. Banning opposite-direction approaches only ensures we’ll do it less.

Example 2: The Third Class Medical

Eliminating the third class medical just makes sense. I’ve covered this before, but it certainly bears repeating: Glider and LSA pilots have been operating without formal medical certification for decades and there is no evidence I’m aware of to suggest they are any more prone to medical incapacitation than those of us who fly around with that coveted slip of paper in our pocket.

AOPA and EAA petitioned the government on this issue two years and nine months ago. The delay has been so egregious that the FAA Administrator had to issue a formal apology. Obviously pilots are clamoring for this, but we’re not the only ones:

Congress is getting impatient as well. In late August, 32 members of the House General Aviation Caucus sent a letter to Department of Transportation Secretary Anthony Foxx urging him to expedite the review process and permit the FAA to proceed with its next step of issuing the proposal for public comment. Early in September 11 Senators, who were all co-sponsors of a bill to reform the medical process, also asked the Department of Transportation to speed up the process.

So where does the proposed rule change now? It is someplace in the maze of government. Officially it is at the Department of Transportation. Questions to DOT officials are met with no response, telling us to contact the FAA. FAA officials comment that “it is now under executive review at the DOT.”

The rule change must also be examined by the Office of Management and Budget.

When the DOT and OMB both approve the proposal—if they do—it will be returned to the FAA, which will then put it out for public comment. The length of time for comments will probably be several months.

After these comments are considered, the FAA may or may not issue a rule change.

It occurs to me that by the time this process is done, it may have taken nearly as long as our involvement in either world war. Even then, there’s no guarantee we’ll have an acceptable outcome.

Example 3: Hangar Policy

The commonsense approach would dictate that as long as you’ve got an airplane in your hangar, you should be able to keep toolboxes, workbenches, American flags, a refrigerator, a golf cart or bicycle, or anything else you like in there. But the FAA once again takes something so simple a cave man could do it and mucks it up. The fact that the FAA actually considers any stage of building an airplane to be a non-aeronautical activity defies both logic and the English language. Building is the very essence of the definition. People who’ve never even been inside an airplane could tell you that. In my mind, this hangar policy is the ultimate example of how out of touch with reality the agency has become.

Example 4: Field Approvals

These have effectively been gone from aviation for the better part of a decade. It used to be that if you wanted to add a new WhizBang 3000 radio to your airplane, a mechanic could get it approved via a relatively simple, low-cost method called a field approval. For reasons nobody has even been able to explain (probably because there is no valid explanation), it became FAA policy to stop issuing these. If you want that new radio in your airplane, you’ll have to wait until there’s an STC for it which covers your aircraft. Of course, that takes a lot longer and costs a boatload of money, if it happens at all. But the FAA doesn’t care.

Homebuilts put whatever they want into their panels and you don’t see them falling out of the sky. Coincidence? I don’t think so.

Example 5: RVSM Approvals

Just to show you that it’s not only the light GA segment that’s suffering, here’s a corporate aviation example. The ability to fly in RVSM airspace—the area between FL290 and FL410—is very important. Being kept below FL290 is not only inefficient and bad for the environment, it also forces turbine aircraft into weather they would otherwise be able to avoid. The alternative is to fly at FL430 and above, which can mean leaving fuel and/or payload behind, or flying in a paperwork-induced coffin corner.

Unfortunately, RVSM approval requires a Letter of Authorization from the FAA. If the airplane is sold, the LOA is invalidated and the new owner has to go through the paperwork process with the FAA from step one. Even if the aircraft stays at the same airport, maintained by the same people, and flown by the same crew. If you so much as change the name of your company, the LOA is invalidated. If you sneeze or get a hangnail, they’re invalidated.

From AIN Online:

Early this year the FAA agreed to a streamlined process to handle RVSM LOA approvals, but for the operator of a Falcon 50 that is not the case. He told AIN that he has been waiting since April for an RVSM LOA.

Because the LOA hasn’t been approved, this operator can fly the Falcon 50 at FL290 or lower or at FL430 or above. On a hot day, a Falcon 50 struggles at FL430. “The other day ISA was +10,” he told AIN, “and we are just hanging there at 43,000 at about Mach 0.72. If we had turbulence we could have had an upset. We’re right there in the coffin corner. Somebody is going to get hurt.”

On another recent flight in the Falcon, “There was a line of storms in front of us. We’re at FL290. They couldn’t let us climb, and I was about to declare an emergency. I’m not going to run my airplane through a hailstorm. It’s turbulent and the passengers are wondering what’s going on.”

When forced to fly below FL290, the Falcon burns 60 percent more fuel, he said. The company’s three Hawkers have a maximum altitude of FL410, and LOA delays with those forced some flights to down to lower altitudes. “We had one trip in a Hawker before it received its RVSM LOA,” he added, “and they got the crap kicked out of them. Bobbing and weaving [to avoid thunderstorms] over Iowa, Minnesota and Nebraska in the springtime, you’re going to get your [butt] kicked.” The Hawker burns about 1,600 pph at FL370, but below FL290 the flow climbs to more than 2,000 pph.

It’s bad for safety and the FAA knows it. If they were able to process paperwork quickly, it might not be such an issue, but many operators find that it takes many months—sometimes even a year or more—to get a scrap of paper which should take a few minutes at most.

Show Me the Money

So what’s behind the all this? Americans love to throw money at a problem, so is this a budget cut issue? Perhaps the FAA is a terribly cash-starved agency that simply isn’t given the resources to do the jobs we’re asking of it.

According to the Department of Transportation’s Inspector General, that’s not the case. He testified before the House Committee on Transportation and Infrastructure earlier this week that the FAA’s budget has been growing even as traffic declines:

The growth of the agency’s budget has been unchecked, despite the managerial failings and the changes in the marketplace. Between 1996 and 2012, the FAA’s total budget grew 95 percent, from $8.1 billion to $15.9 billion. During that same period, the agency’s air traffic operations dropped by a fifth. As a result, taxpayers are now paying the FAA nearly twice as much to do only 80 percent of the work they were doing in the 1990s.

Over that same 16-year span, the FAA’s personnel costs, including salary and benefits, skyrocketed from $3.7 billion to $7.3 billion—a 98 percent increase—even though the agency’s total number of full-time workers actually fell 4 percent during that time.

Self-Evident Solutions

Okay, we’ve all heard the litany of issues. From the inability to schedule a simple checkride to big problems with NextGen development or the ADS-B mandate, you’ve probably got your own list. The question is, how do we fix the problem?

I think the answer is already out there: less FAA oversight and more self-regulation. Look closely at GA and you’ll see that the segments which are furthest from FAA interference are the most successful. The Experimental Amateur-Built (E-AB) sector and the industry consensus standards of the Light Sport segment are two such examples. The certified world? Well many of them are still building the same airframes and engines they did 70 years ago, albeit at several times the cost.

Just as non-commercial aviation should be free of the requirement for onerous medical certification, so too should it be free of the crushing regulatory weight of the FAA. The agency would make a far better and more effective partner by limiting its focus to commercial aviation safety, promoting general aviation, and the protection and improvement of our infrastructure.

Carbon Monoxide, Silent Killer

Monday, October 20th, 2014

Danger, Carbon Monoxide
On January 17, 1997, a Piper Dakota departed Farmingdale, New York, on a planned two-hour VFR flight to Saranac Lake, New York. The pilot was experienced and instrument-rated; his 71-year-old mother, a low-time private pilot, occupied the right seat. Just over a half-hour into the flight, Boston Center got an emergency radio call from the mother, saying that the pilot (her son) had passed out.

The controller attempted a flight assist, and an Air National Guard helicopter joined up with the aircraft and participated in the talk-down attempt. Ultimately, however, the pilot’s mother also passed out.

The aircraft climbed into the clouds, apparently on autopilot, and continued to be tracked by ATC. About two hours into the flight, the airplane descended rapidly out of the clouds and crashed into the woods near Lake Winnipesaukee, New Hampshire. Both occupants died.

Toxicological tests revealed that the pilot’s blood had a CO saturation of 43% — sufficient to produce convulsions and coma—and his mother’s was 69%.

On December 6 that same year, a physician was piloting his Piper Comanche 400 from his hometown of Hoisington, Kansas, to Topeka when he fell asleep at the controls. The airplane continued on course under autopilot control for 250 miles until it ran a tank dry and (still on autopilot) glided miraculously to a soft wings-level crash-landingin a hay field near Cairo, Missouri.

The pilot was only slightly injured, and walked to a nearby farmhouse for help. Toxicology tests on a blood sample taken from the lucky doc hours later revealed CO saturation of 27%. It was almost certainly higher at the time of the crash.

Just a few days later, a new 1997 Cessna 182S was being ferried from the Cessna factory in Independence, Kansas, to a buyer in Germany when the ferry pilot felt ill and suspected carbon monoxide poisoning. She landed successfully and examination of the muffler revealed that it had been manufactured with defective welds. Subsequent pressure tests by Cessna of new Cessna 172 and 182 mufflers in inventory revealed that 20% of them had leaky welds. The FAA issued an emergency Airworthiness Directive (AD 98-02-05) requiring muffler replacement on some 300 new Cessna 172s and182s.

About 18 months later, the FAA issued AD 99-11-07 against brand new air-conditioned Mooney M20R Ovations when dangerous levels of CO were found in their cabins.

Sidebar: CO Primer

Click on image above for high-resolution printable version.

Not just in winter

A search of the NTSB accident database suggests that CO-related accidents and incidents occur far more frequently than most pilots believe. Counterintuitively, these aren’t confined to winter-time flying with the cabin heat on. Look at the months during which the following accidents and incidents occurred during the 15-year period from 1983 to 1997:

March 1983. The Piper PA-22-150 N1841P departed Tucumcari, N.M. After leveling at 9,600, the right front seat passenger became nauseous, vomited, and fell asleep. The pilot began feeling sleepy and passed out. A 15-year-old passenger in the back seat took control of the aircraft by reaching between the seats, but the aircraft hit a fence during the emergency landing. None of the four occupants were injured. Multiple exhaust cracks and leaks were found in the muffler. The NTSB determined the probable cause of the accident to be incapacitation of the PIC from carbon monoxide poisoning. [FTW83LA156]

February 1984. The pilot of Beech Musketeer N6141N with four aboard reported that he was unsure of his position. ATC identified the aircraft and issued radar vectors toward Ocean Isle, N.C. Subsequently, a female passenger radioed that the pilot was unconscious. The aircraft crashed in a steep nose-down attitude, killing all occupants. Toxicological tests of the four victims revealed caboxyhemoglobin levels of 24%, 22%, 35% and 44%. [ATL84FA090]

November 1988. The Cessna 185 N20752 bounced several times while landing at Deadhorse, Alaska. The pilot collapsed shortly after getting out of the airplane. Blood samples taken from the pilot three hours after landing contained 22.1% carboxyhemoglobin. The left engine muffler overboard tube was broken loose from the muffler where the two are welded. The NTSB determined probable cause to be physical impairment of the pilot-in-command due to carbon monoxide poisoning. [ANC89IA019]

July 1990. While on a local flight, the homebuilt Olsen Pursuit N23GG crashed about three-tenths of a mile short of Runway 4 at Fowler, Colo. No one witnessed the crash, but post-crash investigation indicated that there was no apparent forward movement of the aircraft after its initial impact. The aircraft burned, and both occupants died. Toxicology tests of the pilot and passenger were positive for carboxyhemoglobin. [DEN90DTE04]

August 1990. About fifteen minutes into the local night flight in Cessna 150 N741MF, the aircraft crashed into Lake Michigan about one mile from the shoreline near Holland, Mich. Autopsies were negative for drowning, but toxicological tests were positive for carboxyhemoglobin, with the pilot’s blood testing at 21%. [CHI90DEM08]

July 1991. The student pilot and a passenger (!) were on a pleasure flight in Champion 7AC N3006E owned by the pilot. The aircraft was seen to turn into a valley in an area of mountainous terrain, where it subsequently collided with the ground near Burns, Ore., killing both occupants. A toxicology exam of the pilot’s blood showed a saturation of 20% carboxyhemoglobin, sufficient to cause headache, confusion, dizziness and visual disturbance. [SEA91FA156]

October 1992. The pilot of Cessna 150 N6402S was in radio contact with the control tower at Mt. Gilead, Ohio, and in a descent from 5,000 feet to 2,000 feet in preparation for landing. Radar contact was lost, and the aircraft crashed into a wooded area, seriously injuring the pilot. Toxicological tests on the pilot’s blood were positive for carbon monoxide. Examination of the left muffler revealed three cracks and progressive deterioration. The NTSB found probable cause of the accident to be pilot incapacitation due to carbon monoxide poisoning. [NYC93LA031]

April 1994. Fifteen minutes after takeoff from Long Beach, Calif., the Cessna 182 N9124G began deviating from headings, altitudes and ATC instructions. The aircraft did several 360- and 180-degree turns. The pilot reported blurred vision, headaches, nausea, labored breathing, and difficulty staying awake. The aircraft ultimately crashed in a vineyard near Kerman, Calif., and the owner/pilot was seriously injured. Post-crash inspection revealed numerous small leaks in the exhaust system. The pilot tested positive for carbon monoxide even after 11 hours of oxygen therapy. [LAX94LA184]

October 1994. A student pilot returned to Chesterfield, Mo., from a solo cross-country flight in Cessna 150 N7XC, complaining of headache, nausea, and difficulty walking. The pilot was hospitalized, and medical tests revealed elevated CO which required five and a half hours breathing 100% oxygen to reduce to normal levels. Post-flight inspection revealed a crack in an improperly repaired muffler that had been installed 18 hours earlier. [CHI95IA030]

March 1996. The pilot of Piper Cherokee 140 N95394 stated that she and her passenger became incapacitated after takeoff from Pittsburg, Kan. The airplane impacted the terrain, but the occupants were uninjured. Both were hospitalized, and toxicological tests for carbon monoxide were positive. A subsequent examination found holes in the muffler. [CHI96LA101]

August 1996. A Mankovich Revenge racer N7037J was #2 in a four-airplane ferry formation of Formula V Class racing airplanes. The #3 pilot said that the #2 pilot’s flying was erratic during the flight. The airplane crashed near Jeffersonville, Ind., killing the pilot. The results of FAA toxicology tests of the pilot’s blood revealed a 41% saturation of carboxyhemoglobin; loss of consciousness is attained at approximately 30%. Examination of the wreckage revealed that the adhesive resin that bound the rubber stripping forming the firewall lower seal was missing. The NTSB determined probable cause of the accident to be pilot incapacitation due to carbon monoxide poisoning. [CHI96FA322]

January 1997. The fatal crash of Piper Dakota N8263Y near Lake Winnipesaukee, N.H. (described previously). [IAD97FA043]

December 1997. Non-fatal crash of Piper Comanche 400 N8452P flying from Hoisington to Topeka, Kansas (described previously). [CHI98LA055]

December 1997. A new Cessna 182S was being ferried from the factory in Independence, Kan., to a buyer in Germany when the ferry pilot felt ill and suspected carbon monoxide poisoning (described previously). [Priority Letter AD 98-02-05]

Overall, deaths from unintentional carbon monoxide poisoning have dropped sharply since the mid-1970s thanks mainly to lower CO emissions from automobiles with catalytic converters (most CO deaths are motor vehicle-related) and safer heating and cooking appliances. But CO-related airplane accidents and incidents haven’t followed this trend. The ADs issued against Independence-built Cessna 172s and 182s and Mooney Ovations demonstrates that even brand new airplanes aren’t immune.

CO Checklist

Click on image above for high-resolution printable version.

Close calls

In addition to these events in the NTSB accident database where CO poisoning was clearly implicated, there were almost certainly scores of accidents, incidents, and close calls where CO was probably a factor.

In January 1999, for example, a Cessna 206 operated by the U.S. Customs Service was on a night training mission when it inexplicably crashed into Biscayne Bay a few miles off the south Florida coast. The experienced pilot survived the crash, but had no recollection of what happened. The NTSB called it simple pilot error and never mentioned CO as a possible contributing factor. However, enough carboxyhemoglobin was found in the pilot’s blood that the Customs Service suspected that CO poisoning might have been involved.

The agency purchased sensitive industrial electronic CO detectors for every single-engine Cessna in its fleet, and discovered that many of the planes had CO-in-the-cockpit problems. On-board CO detectors and CO checks during maintenance inspections have been standard operating procedure for the Customs Service ever since.

How much CO is too much?

It depends on whom you ask.

EPA calls for a health hazard alert when the outdoor concentration of CO rises above 9 parts per million (ppm) for eight hours, or above 35ppm for one hour. OSHA originally established a maximum safe limit for exposure to CO in the workplace of 35 ppm, but later raised it to 50 ppm under pressure from industry.

The FAA requires that CO in the cabin not exceed 50 ppm during certification testing of new GA airplanes certified under FAR Part 23 (e.g. Cessna Corvallis, Cirrus SR22, Diamond DA-40). Legacy aircraft certified under older CAR 3 regs required no CO testing at all during certification.

Once certified, FAA requires no CO testing of individual aircraft by the factory, and no follow-up retesting during annual inspections. A March 2010 FAA SAIB (CE-10-19 R1) recommends checking CO levels with a hand-held electronic CO detector during ground runups at each annual and 100-hour inspection, but in my experience very few shops and mechanics do this.

UL-approved residential CO detectors are not permitted to alarm until the concentration rises to 70 ppm and stays there for four hours. (This was demanded by firefighters and utility companies to reduce the incidence of nuisance calls from homeowners.) Yet most fire departments require that firefighters put on their oxygen masks immediately when CO levels reach 25 ppm or higher.

It’s important to understand that low concentrations of CO are far more hazardous to pilots than to non-pilots. That’s because the effects of altitude hypoxia and CO poisoning are cumulative. For example, a COHb saturation of 10% (which is about what you’d get from chain-smoking cigarettes) would probably not be noticeable to someone on the ground. But at 10,000 feet, it could seriously degrade your night vision, judgment, and possibly cause a splitting headache.

After studying this hazard for many years and consulting with world-class aeromedical experts, I have come to the following conclusions:

  1. Every single-engine piston aircraft should carry a sensitive electronic CO detector.
  2. Any in-flight CO concentration above 10 ppm should be brought to the attention of an A&P for troubleshooting and resolution.
  3. Any in-flight CO concentration above 35 ppm should be grounds for going on supplemental oxygen (if available) and making a precautionary landing as soon as practicable.

Smokers are far more vulnerable to both altitude hypoxia and CO poisoning, since they’re already in a partially poisoned state when they first get into the aircraft. Because of COHb’s long half-life, you’d do well to abstain from smoking for 8 to 12 hours prior to flight.

Choosing a CO detector

Five CO detectors

Five CO detectors (left to right): chemical spot, UL-compliant residential (Kidde), non-UL-compliant (CO Experts 2015), industrial (BW Honeywell), TSO’d panel-mounted (CO Guardian 551).

Chemical spot detectors:Stay away from those ubiquitous el-cheapo adhesive-backed cardboard chemical spot detectors that are commonly sold by pilot shops and mail-order outfits for under trade names like “Dead Stop,” “Heads Up” and “Quantum Eye.” They have a very short useful life (about 30 days), and are extremely vulnerable to contamination from aromatic cleaners, solvents and other chemicals routinely used in aircraft maintenance.

These things often remain stuck on the instrument panel for years, providing a dangerous false sense of security. What’s worse, there’s no warning that the detector is outdated or has been contaminated—in some ways, that’s worse than not having a detector at all.

Even when fresh, chemical spot detectors are incapable of detecting low levels of CO. They’ll start turning color at 100ppm, but so slowly and subtly that you’ll never notice it. For all practical purposes, you’ll get no warning until concentrations rise to the 200 to 400 ppm range, by which time you’re likely to be too impaired to notice the color change.

Residential electronic detectors:Although battery-powered residential electronic detectors are vastly superior to those worthless chemical spots, most are designed to be compliant with Underwriter’s Laboratory specification UL-2034 (revised 1998). This spec requires that

(1)   The digital readout must not display any CO concentration less than 30 ppm.

(2)   The alarm will not sound until CO reaches 70 ppm and remains at or above that level for four hours.

(3)   Even at a concentration of 400 ppm, it may take as much as 15 minutes before the alarm sounds.

For aircraft use, you really want something much more sensitive and fast-acting. I like the non-UL-compliant CO Experts Model 2015 ($199 from www.aeromedix.com). It displays CO concentrations as low as 7 ppm and provides a loud audible alarm at concentrations above 25 ppm. It updates its display every 10 seconds (compared to once a minute for most residential detectors), which makes it quite useful as a “sniffer” for trying to figure out exactly where CO is entering the cabin.

Industrial electronic detectors:Industrial CO detectors cost between $400 and $1,000. A good choice for in-cockpit use is the BW Honeywell GasAlert Extreme CO  ($410 from www.gassniffer.com). This unit displays CO concentrations from 0 to 1,000 ppm on its digital display, has a very loud audible alarm with dual trigger levels (35 and 200 ppm).

Purpose-built aviation electronic detectors:Tucson-based CO Guardian LLC makes a family of TSO’d panel-mount electronic CO detectors specifically designed for cockpit use. These detectors detect and alarm at 50 ppm (after 10 minutes), or 70 ppm (after 5 minutes), and will alarm instantly if concentrations rise to 400 ppm. The digital display models ($599 and up) will show concentrations as low as 10 ppm. Available from www.coguardian.com. Obviously, panel-mount detectors cannot be used as a sniffer to locate the source of a CO leak.

For more information…

There is an outstanding October 2009 research paper titled “Detection and Prevention of Carbon Monoxide Exposure in General Aviation Aircraft” authored by Wichita State University under sponsorship of the FAA Office of Research and Technology Development. The paper is 111 pages long, and discusses (among other things):

  • Characteristics of CO-related GA accidents
  • Evaluation of CO detectors, including specific makes and models
  • Placement of CO detectors in the cabin
  • Exhaust system maintenance and inspection

This research paper is available online at:

http://www.tc.faa.gov/its/worldpac/techrpt/ar0949.pdf

Another Successful Flight of Haywire Airlines…Fly it Forward!

Saturday, October 18th, 2014
Haywire Airlines Captain and First Officer

Haywire Airlines Captain and First Officer

 

I was an airport kid. As a family we attended airport days. Heck I even learned to drive a car, at an airport. We flew a lot, in state, and out to visit relatives. Most times as we taxied or parked my father would exclaim, “Another successful flight of Haywire Airlines!” That would always make me laugh and today makes me smile.

My father, now 92, is the one who inspired me to become a pilot. But I didn’t get the bug right away or even as a young person. In 2002, I was visiting our hometown for a family reunion and it was airport day. My Dad landed in his Mooney. My brother landed in his V-tail Bonanza. I thought “What is wrong with this picture?” that was in July and I had my license in September.

My Dad made flying look easy.  He was a primary trainer in WWII at Rankin Field in Tulare, CA. He tells great stories of antics with Tex Rankin and Sammy Mason. During his time at Rankin he met my Mom on a blind date, then took her for a ride in the Stearman. He said she liked the flight and he knew that she was going to be a great mate.  64 years later they were still in love, when she flew West.

So thanks to my Dad, I am a pilot. I try to Fly It Forward to kids and adults alike. Mid-October brings cool, crisp flying weather and a close to the busy airport day and air show season for me. Recently I took an opportunity to re-read some posts from an AOPA Red Board thread I began in 2012 about who inspired us to become pilots. This quote on mentoring by Benjamin Franklin sums this concept up nicely: “Tell me and I forget, teach me and I may remember, involve me and I learn.” My hope is that as we reflect on those who mentored us that we might take up the mantle and Fly it Forward for another. Enjoy the stories, perhaps put your own in the comment section, and better than that, be someone else’s inspiration.

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When I was growing up, my dad was a controller at a Class D airport- Camarillo, CA. I hung out there a lot when I was 11-15 years old, and knew the make and model of planes by sight. One day when I was 12, a pilot offered rides to the controllers, and my dad talked him into taking up our family. I got to the airport and there was a beautiful yellow PT-17 Stearman, done in the Navy trainer scheme. I waited anxiously for my turn to go up- watching him take off and land from the base of the tower with my other family members. Finally, it was my turn.

The ride was unbelievable! Wearing a leather cap, we flew around Saticoy and over by Santa Paula. Early on in the flight, he showed me how to control the plane with the control stick, and let me fly just about everywhere! I was speechless during the whole flight! When we were back on the ground, I looked up at him and offered him the $6 I had in my pocket for gas. I looked at him like he was a god. He just smiled, put his hand on my shoulder and said, “Keep your money, but if you ever have the chance to pass this along, do it.” To this day, I still do!
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I’ve been fascinated, even obsessed, with aviation my entire life, but never got around to becoming a pilot. In 2001 at the Watsonville (WVI) airshow, I went for a flight in CAF’s B-17 “Sentimental Journey”.

After the flight, I was talking with the pilot, last name Kimmel. I told him that I had wanted to be a pilot forever but hadn’t gone ahead and started taking lessons. Kimmel grabbed me by the shoulders and said, “What are you waiting for? Get off your butt and do it!” Two days later I was back at WVI taking my first lesson.

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I grew up in a very poor family and area and no one I knew had any interest in aviation. I can remember times when there was no money and very little food to eat even though my father worked hard. Because we had nothing as kids we dreamed of things we would one day do. One summer day when I was four years old I was lying on my back in the shade of a tree just looking up at all the big fluffy white clouds sailing across the sky, and then I heard a noise coming closer. Out of the clouds came a beautiful 4-engine airplane and having never seen one I had no idea what it was but it was huge! It was the most beautiful thing I had ever seen, and it was just dancing in and out of the clouds. And right then and there my dream of one day flying an amazing machine like the bomber I had seen was born. That was in 1961 and when I announced that evening to my family that I was one day going to be a pilot, you can guess the reaction. Sitting at the dinner table eating corned beef hash because potatoes were about the only thing we could afford, I was laughed at by my brothers and sister, and mom said she hoped I would one day be rich and I could fly her all around the world. Dad told me that a man has to have a dream to work toward and that was a grand one.

The years rolled by and every time I heard an airplane I would look up and dream. Finally I graduated high school and 6 weeks later I married my high school sweetheart and I was due to leave for boot camp in 60 days. During this time I flew for the first time, it was on the day of my first lesson. It was everything I ever dreamed of in an old 172 and I was in love. As so often happens life soon got in the way and I stopped taking lessons after about 8 hours. Off to boot camp and later we built our own home. Some more years went by and finally my wife told me that I should go back to flying since I loved it so much. What a wonderful wife. I started taking lessons again but with a different instructor and he was amazing. When I was ready to quit because I could not learn to land he kept encouraging me and let me continue to beat up his airplane. Never once did he get upset and believe me he had good reason. He has the patience of a saint. After many hours and many bad landings I finally got it. I went for my check ride in 1985 and I passed!

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I was 14, my cousin was an instructor, and got my parents’ permission to fly me from Meadowlark airport in Huntington Beach (where she was teaching) to Reno. It was a T210 (N732WF), and she was checking out a new pilot in this plane. I sat in the back seat. I don’t remember much about the flight, but I do recall going through some clouds shortly before landing, and she turned around and asked me if I saw the landing gear down. I didn’t know it was a retract, and I was concerned that she was concerned that we might not see a wheel out there! It was a little rough during the approach and she was convinced I’d never get in another airplane as long as I lived! The truth was, I actually thought, “This is SO COOL! I’m gonna be a pilot in TEN YEARS!”
The next summer, I spent a few more weeks in the Reno area. She took me for a ride in a Mooney (N201DK), and this time I got to sit in the right seat. I got to fly over Lake Tahoe and got a real taste for it. This time, I updated my goal: “In FIVE YEARS, I’m gonna be a pilot!” She gave me the best piece of advice a 15-year-old kid could get: Just identify your goal, eliminate the obstacles, and all that’s left is success!

Just over one year later, and two days after my 17th birthday, I earned my PPL. That was many years ago, and I’m now a 737 Captain for a major airline, and she’s an inspector supervisor with the FAA. We haven’t flown together since then, but I do try to Fly it Forward through Young Eagles 20-some kids last year, and 40-ish this year. I sit right seat in my 182 for those flights, and put the kids in the pilot seat. I enjoy it, but they LOVE it, and if even one of those kids decides to take it further, it’ll have been worth it.

High Flight

High Flight

Liability: The Price We Pay

Wednesday, October 1st, 2014

As large as the aviation industry looks to those on the outside, once you’re on the other side of the fence, it doesn’t take long to realize that it’s a very small world. One of the big challenges facing that world has been from product liability issues.

The $100 screw. The $9.00 gallon of fuel. The $5,000 part that costs $50 at a local hardware store. We’ve all seen it. I recall the day a friend told me the seat back for my Pitts S-2B, which is literally a small flat piece of ordinary plywood, cost something like $600. I’m not averse to parts manufacturers turning a profit, but that left my mouth hanging open. My friend? He just shrugged and walked away, as though this was ordinary and normal. The saddest part is that I realized he was right. It is.

Liability concerns are a major expense and motivator for many industries. That’s why Superman costumes come with warnings that “the cape does not enable the wearer to fly”, Zippo cautions the user not to ignite the lighter in your face, and irons are sold with tags advising against ironing clothes while they’re being worn. But for general aviation, this sort of thing is dragging the lot of us down as surely as a cement block tossed into the murky waters of the East River.

The classic example of this phenomenon can be seen in the high cost for new products like airplanes. Look at the sharp rise in the price of a new Skyhawk over the past thirty years. The first one was built in 1955, so the research and development costs for this model must have been recouped decades ago. A new Bonanza is a cool million. Low production volumes and high liability costs — a chicken and egg pair if there ever was one — are prime culprits for that inflation.

In fact, for about a decade, the general aviation industry essentially stopped producing new piston airplanes. From the mid-80s to the mid-90s, product liability was such that nearly every major OEM exited the business. The insurance costs rose, the manufacturers had no choice but to pass that on to the consumer, who was summarily priced out of the market. Sales fell, per-unit liability costs rose further, and the cycle spiraled downward until even those companies which still had an operating production line were only turning out a handful of airplanes per year.

The General Aviation Revitalization Act of 1994 helped somewhat. Aircraft manufacturers started producing planes again. The Cirrus, DiamondStar, Columbia, and other such advanced aircraft were brought to market. New avionics systems were developed. But the liability problem never went away. Frivolous lawsuits still abound, grinding away at our diminished world like a wood chipper consuming a sturdy log. Manufacturers have been sued for things as idiotic as not telling a pilot that the engine wouldn’t operate without fuel. I don’t have to tell you how this lunacy looks to people from other countries, do I?

I often wonder, what would an aircraft like the RV-6 cost if it was certified? You can buy one for as little as $45,000 today. Speaking of Amateur-Built aircraft, liability is one of the primary reasons advancements such as electronic ignition proliferate in the E-AB world when they’re almost unheard of in aircraft with a standard airworthiness certificate.

Mike Busch has penned many articles about the ways liability concerns drive decisions in the maintenance business. The result? Lower efficiency, higher cost, and at times even a decrease in the level of safety that is supposedly paramount. But it goes beyond that. Many products which would otherwise be brought to market are not because liability issues tilt the scale away from taking that risk in the first place.

Even proven, well-established products are sometimes lost to this phenomenon. Seven years ago, the largest manufacturer of aircraft carburetors, Precision Airmotive, abruptly decided to stop making, selling, and supporting them. In a letter to customers on their web site, they wrote:

Precision Airmotive LLC has discontinued sales of all float carburetors and component parts as of November 1, 2007. This unfortunate situation is a result of our inability to obtain product liability insurance for the product line. Precision Airmotive LLC and its 43 employees currently manufacture and support the float carburetors used in nearly all carbureted general aviation aircraft flying today. Precision has been the manufacturers of these carburetors since 1990. These FAA-approved carburetors were designed as early as the 1930s and continue to fly over a million flight hours a year. After decades of service, the reliability of these carburetors speaks for itself.

Nonetheless, Precision has seen its liability insurance premiums rise dramatically, to the point that the premium now exceeds the total sales dollars for this entire product line. In the past, we have absorbed that cost, with the hope that the aviation industry as a whole would be able to help address this issue faced by Precision Airmotive, as well as many other small aviation companies. Our efforts have been unsuccessful.

This year, despite the decades of reliable service and despite the design approval by the Federal Aviation Administration, Precision Airmotive has been unable to obtain product liability insurance for the carburetor product line. While we firmly believe that the product is safe, as does the FAA, and well-supported by dedicated people both at Precision and at our independent product support centers, unfortunately the litigation costs for defending the carburetor in court are unsustainable for a small business such as Precision.

Even if you don’t own an airplane, you’ve probably noticed that aircraft rental is prohibitively difficult and expensive. Companies like OpenAirplane are trying to make a dent in this formidable problem, but many aircraft types simply cannot be rented at all for solo flight anymore. Seaplanes, aerobatic aircraft, twins, turbines, and many other types might as well not exist unless you have the cash to buy them outright. And those that are still rented require extensive checkouts, form filling, and a large expenditure of time, money and energy. Why? To check every possible box off when it comes to liability. The manager of one FBO here in Southern California told me in no uncertain terms that it wouldn’t matter if Bob Hoover himself walked through the door, he wouldn’t get one iota of consideration in that regard. Does that sound right to you?

There’s an obvious answer here. If you’re thinking tort reform, you’re only half-right. Suing manufacturers for accidents that are clearly not their fault simply because the plaintiff knows they’ll settle is only ensuring the next generation won’t be able to fly. The real solution is to — in the words of a pilot I know — put on our big-boy britches and come to terms with the fact that life in general, and aviation in particular, involves risk. From the Doolittle Raiders to the folks at Cirrus Aircraft, history shows over and over again that risk is a part of every successful venture. We’d all love to live in a world where there is no risk, where following the dictates of Title 14 would ensure nothing ever goes wrong and nobody ever gets hurt. It’s a fallacy.

Crushing liability costs aren’t limited to carbs. And many parts of our airplanes are manufactured by a very small number of companies. Prop governors come to mind. Vacuum pumps. Brakes. Fasteners. If one firm is having trouble staying in business, odds are the others might be as well. It doesn’t portend a rosy future for the industry, especially when you consider that many of the advances we now enjoy came from small companies just like Precision Airmotive.

Sure, with Experimentals you have more freedom to put what you want on your aircraft. But many of the components on experimental aircraft are certified anyway. Most of them essentially have certified engines, props, skins, wiring, brakes, tires, fasteners, etc. This liability issue affects everyone regardless of what it says on the plane’s airworthiness certificate. This sort of thing isn’t limited to aviation. But GA is particularly vulnerable to abuse because of the implication that anyone involved in it must have deep pockets. The end result is a case like this one, where a jury awarded $480 million verdict against an aircraft manufacturer even though the NTSB indicated pilot error was the cause.

Liability concerns hurt everyone in aviation, not just those with reciprocating single-engines. I’ll give you one example from the corporate and charter business that I work in: time and time again, thousands of dollars of catering from one of our charter flights will go untouched by the passengers. We’ll land at our destination with a eighty pounds of beautifully packaged and prepared food. Five-star presentation of the highest-quality and healthiest food you’ll see anywhere.

At the same time, just beyond the airport fence are people who go to bed hungry. Logic dictates that we might want to put two and two together. But because the operators and customers of these aircraft are high net worth individuals who would certainly find themselves on the receiving end of a lawsuit at the first indication of food poisoning or other malady, load after load of this food goes into the trash every single day all across the country. Over the past three years I’d imagine the total weight of the food from flights I’ve flown that went into the trash would total a couple of tons.

While lawsuits and courtrooms certainly have their place, I personally think it’s high time our society acknowledged the fact that safety does not equate an absence of risk. Failure to do so is putting us, our industry, our economy, and even our way of life at risk. That’s the cost of the society we’ve built. Is it worth it?

Backdoor Rule Making?

Wednesday, September 24th, 2014

On February 10, 2014, the Cessna Aircraft Company did something quite unprecedented in the history of piston GA: It published a revision to the service manual for cantilever-wing Cessna 210-series airplanes that added three new pages to the manual. Those three pages constituted a new section 2B to the manual, titled “Airworthiness Limitations”:

Cessna 210 Service Manual Section 2B

This section purports to impose “mandatory replacement times and inspection intervals for components and aircraft structures.” It states that the new section is “FAA-Approved” and that compliance is required by regulation.

Indeed, FARs 91.403(c) and 43.16 both state  that if a manufacturer’s maintenance manual contains an Airworthiness Limitations section (ALS), any inspection intervals and replacement times prescribed in that ALS are compulsory. FAR 91.403(c) speaks to aircraft owners:

§91.403(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an Airworthiness Limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section … have been complied with.

and FAR 43.16 speaks to mechanics:

§43.16 Each person performing an inspection or other maintenance specified in an Airworthiness Limitations section of a manufacturer’s maintenance manual or Instructions for Continued Airworthiness shall perform the inspection or other maintenance in accordance with that section…

Sounds pretty unequivocal, doesn’t it? If the maintenance manual contains an ALS, any mandatory inspection intervals and replacement times have the force of law.

The new ALS in the Cessna 210 maintenance manual mandates eddy current inspection of the wing main spar lower caps. For most 210s, an initial spar inspection is required at 8,000 hours time-in-service, with recurring inspections required every 2,000 hours thereafter. However, for 210s operated in a “severe environment” the inspections are required  at 3,500 hours and every 500 hours thereafter:

Cessna 210 inspection times

For P210s, the new ALS also imposes a life limit of 13,000 hours on the windshield, side and rear windows, and ice light lens.

What’s wrong with this picture?

To be fair, the eddy current inspection is not that big a deal.  An experienced technician can do it in a few hours. The most difficult part is that most service centers have neither the eddy current test eequipment nor a trained and certificated non-destructive testing (NDT) technician on staff. So most Cessna 210 owners will need to fly their airplane to a specialty shop  Since most airplanes will need to do this only once every 2,000 hours and since most of them fly less than 200 hours per year, one could hardly classify this recurrent eddy current inspection as Draconian. Similarly, not too many P210s are likely to reach the 13,000-hour life window life limit.

No, the issue isn’t the spar cap inspection or window life limits themselves—it’s the extraordinary method by which Cessna is attempting to make them compulsory.

Normally, if the manufacturer of an aircraft, engine or propeller wants to impose a mandatory inspection interval or a mandatory replacement or overhaul time on the owners of its aeronautical product, the manufacturer goes to the FAA and requests that an Airworthiness Directive (AD) be issued. If the FAA agrees and decides to issue an AD, it does so by means of a formal rule-making process prescribed by the federal Administrative Procedure Act (APA). Ultimately, the AD is published in the Federal Register and becomes an amendment to Part 39 of thee FARs. That’s what gives the AD its “teeth” and makes it compulsory for aircraft owners to comply with it.

§91.403(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.

The APA governs the way that administrative agencies of the federal government (including the FAA) may propose and establish regulations. It has been called “a bill of rights” for Americans whose affairs are controlled or regulated by federal government agencies. The APA requires that before a federal agency can establish a new regulation, it must publish a notice of proposed rule making (NPRM) in the Federal Register, provide members of the public who would be impacted by the proposed regulation an opportunity to submit comments, and then take those comments seriously in making its final rule. The APA also establishes rights of appeal if a person affected by the regulation feels it is unjust or should be waived.

Because of the APA and other federal statutes, it is difficult for the FAA to issue ADs arbitrarily or capriciously. The agency first has to demonstrate that a bona fide unsafe condition exists, and that its frequency and severity of the safety risk rises to the level that makes rule making appropriate. It has to estimate the financial impact on affected owners. It has to provide a public comment period, give serious consideration to comments submitted, and respond to those comments formally when issuing its final rule.

As someone who has been heavily involved in numerous AD actions on behalf of various alphabet groups, I can tell you that the notice-and-comment provisions of the APA is extremely important, and that concerted efforts by aircraft owners and their representative industry organizations have often had great impact on the final outcome.

Through the back door?

That’s what makes Cessna’s action last February so insidious.

The addition of an Airworthiness Limitations section to the Cessna 210 maintenance manual was done without going through the rule making process. There was no NPRM and no comment period. Affected owners never had an opportunity to challenge the need for eddy current inspections of their wing spars. Cessna was never required to demonstrate that a genuine unsafe condition exists, nor weigh the cost impact against the safety benefit.Cessna 210 service manual By adding an ALS to the maintenance manual rather than ask the FAA to issue an AD, Cessna is attempting to bypass the APA-governed AD process and impose its will on aircraft owners through the back door.

Granted that the initial contents of the new ALS is not excessively burdensome. But if Cessna’s action is allowed to go unchallenged, it could set a terrible precedent. It would mean that any aircraft, engine or propeller manufacturer could retroactively impose its will on aircraft owners.

And if that happens, Katy bar the (back) door!

That’s why I’ve been working with my colleague Paul New—owner of Tennessee Aircraft Services, Inc. and honored by the FAA in 2007 as National Aviation Maintenance Technician of the Year—to challenge what Cessna is doing. On September 15th, Paul sent a letter that we jointly drafted to Mark  W. Bury (AGC-200), the FAA’s top regulations lawyer in its Office of General Counsel at FAA headquarters, asking him to issue a formal letter of interpretation as to whether compliance with the so-called mandatory inspection intervals set forth in section 2B of the Cessna 210 maintenance manual is actually required by regulation. We specifically ask Mr. Bury to rule on the question of whether retroactive enforcement of such a maintenance manual amendment by the FAA would constitute an APA violation.

The wheels of justice turn slowly at FAA Headquarters. We have been advised that AGC-200 has a four-month backlog of requests for letters of interpretation, so our request probably will not be looked at until the first quarter of 2015. But at least our request is in the queue. I am cautiously optimistic that AGC-200 will see things the way Paul and I see them, and will rule that a manufacturer’s publication of an ALS cannot be retroactively enforceable against aircraft owners unless the FAA issues an AD making it so.

Life on the Trailing Edge

Tuesday, August 26th, 2014

"Manifesto" is the first book by Mike Busch A&P/IA.

I just got back from EAA AirVenture in Oshkosh. It was a grueling week for me that included ten different Forums Plaza lectures, two “stump the IA” sessions at the AOPA seminar tent, and my first-ever AirVenture press conference. I’m still recovering.

AirVenture marked the release of my new book Manifesto, the first of what I expect to be a four- or five-volume series that anthologizes the most important of my aviation articles written over the past several decades. Manifesto is a short, pithy volume about maintenance philosophy. The next volume will be devoted to aircraft engines, and I’m hoping to have it out by the end of 2014.

One chapter of Manifesto is titled “How Mechanics Think” and addresses their extreme concerns about liability (both civil and regulatory), resulting in a compulsion to do everything exactly “by the book” and an aversion to trying anything new or different. It’s this aversion that is the subject of my blog post this month.

Tire Tactics

For the first decade after I purchased my Cessna 310 in 1987, I used Goodyear Flight Custom tires, which mechanics told me were “the gold standard” for GA aircraft tires. In 1998, I switched to Michelin Air tires because they were less expensive than the Flight Customs and were rated for the same weight and speed and reported to last just as long. I had just as good luck with the Michelins as I did with the Goodyears.

Then, in 2005, I decided to try Desser retreads after Aviation Consumer did a big competitive torture test of various tire brands (Goodyear, Michelin, McCreary, Condor), and found that Desser retreads fared even better than top-of-the-line Goodyear Flight Customs, even though they cost half as much.

Goodyear vs. Desser retreads

Are new tires (left) worth twice the price of retreads (right) that last longer?

I’ve used Desser retreads ever since, and Aviation Consumer was right: The darn things wear like iron. They’re dimensionally identical to new tires, so there’s never been any question about their fit in the wheel wells. Half the price, equal or better lifespan, perfect fit…what’s not to like? Could this be why most commercial aircraft operators and flight schools use retread tires, as do virtually all airlines?

In 2008, I started recommending Desser retreads for my company’s managed-maintenance clients. The reaction from shops and mechanics was astonishing. You’d have thought I’d just lit a stink bomb in church!

A number of shops flatly refused to install retreads, claiming they were taking this position “for liability reasons.” Others reacted with contempt and derision: “You’re serious about nickel-and-diming the maintenance by installing el-cheapo recaps on a half-million-dollar aircraft? Are you out of your mind?”

The fact that the biggest customers for retreaded aircraft tires are commercial operators, flight schools, and airlines didn’t seem to carry any sway with these mechanics. Nor the fact that Desser retreads beat Goodyear’s and Michelin’s top-of-the-line new tires in the Aviation Consumer torture test.

Silly me. I always considered saving money a good thing. To paraphrase the late Senator Everett Dirksen, “A hundred bucks here, a hundred bucks there, and pretty soon you’re talking real money.”

Six years later, all of my clients who followed my advice and opted for retreads and are very happy with their decision. Other clients demurred and sprung for the pricey Flight Custom IIIs, and they’re happy, too. I have learned not to push the issue. I still use Desser retreads on my airplane.

Spark Plug Wars

In 2006, I needed to replace the spark plugs on my airplane. My Cessna 310 has 24 spark plugs, so a full set of new plugs represents a non-trivial expense. While pricing out a set of Champion RHB32E massive-electrode plugs, I noticed that Autolite spark plugs were four bucks cheaper, a savings of $100 on 24 plugs. A hundred here, a hundred there….

Aviation spark plugsI’d used nothing but Champion plugs for the past 35 years, but as a world-class cheapskate I just couldn’t resist saving a hundred bucks, so I ordered the Autolites. When the new plugs arrived, I installed them and was very impressed. For one thing, the Autolite plugs are nickel-plated so they are much more corrosion-resistant than Champions (which are painted). For another, the Autolite threads start with a taper that makes them much easier to start in the cylinder spark plug boss. Subsequently, I learned that the Autolite plugs incorporated a fired-in sealed resistor assembly that solved the problem of high-resistance plugs that long plagued Champions.

Champion had dominated the aircraft spark plug market for as long as I could remember (and that’s a long time), but these Johnny-come-lately Autolites (first introduced in 2002) seemed like a better mousetrap. I’ve used Autolite plugs (which are now called “Tempest” after Unison sold the product line to Aero Accessories) ever since, and I love them. In 2008, I started recommending Autolite plugs to my managed-maintenance clients, and the blowback from their mechanics was truly breathtaking.

“My A&P was appalled that anyone would consider using Autolite plugs”, one owner told me. “Since he’s something of a curmudgeon, I asked my hangar neighbor (who’s an A&P) and was treated to a tirade about how he once tried a set of Autolites and they all died after 150 to 250 hours. I then wandered to another FBO on the field to take a straw poll of the two A&Ps on coffee break and was treated like a dummy who would sacrifice my airplane to save a few bucks.”

“I told my A&P this morning that I’d just installed Autolite plugs,” another owner said. “It was like throwing gasoline on a barbecue. I got out of there very quickly.”

Yet another owner received this inscrutable response from his A&P: “We like Champions, they’re better—but we use Autolites in our rental fleet and haven’t had any problems.” Translation: “If you’re paying for the plugs, we recommend the high-priced spread, but if we’re paying for them, well….”

I’ve never had an aircraft owner report any problems with the Autolite/Tempest plugs. Several manufacturers have issued service bulletins calling for Champion fine-wire plugs to be removed from service because they fail so often. Continental Motors now ships their new, rebuilt and overhauled engines strictly with Tempest plugs instead of Champions. Yet still I find that few A&Ps in the field stock anything but Champion plugs, and a few still refuse to install Tempests even when their customers specifically request them.

Where’s the Beef?

Why do so many A&Ps badmouth Desser retreads and Tempest plugs in the face of improved performance and cost-effectiveness? I’ve heard some owners suggest that it’s because there’s less mark-up on Desser tires than on Goodyears and on Tempest plugs than Champions. I’m not sure I buy that. In my experience, an A&P’s decisions are rarely motivated by greed, and are much more likely motivated by fear—specifically, fear of the unknown and fear of getting sued. Besides, a genuinely greedy A&P could find much more lucrative outlets for his greed than spark plugs and tires.

Tortoise and hare

Why are so many A&Ps late-adopters?

This resistance to trying new things—a “late-adopter” mentality—seems disturbingly common among A&Ps in my experience. It’s same psychology that causes some mechanics to discount the benefits of borescope inspections (often because they don’t own a borescope), spectrographic oil analysis, and digital engine analyzers (because they’re never learned to interpret the results), and to blame most cylinder problems on lean-of-peak operation (because they’ve never studied combustion theory and don’t realize that their Toyota runs LOP on the drive home from work).

Why are so many A&Ps skeptical of new-to-them products, methods and ideas? Why do so many choose to live life on the trailing edge of technology? Two reasons: lack of training and fear of being sued.

When I first earned my mechanic certificate (after having been a certificated pilot for 35 years), I was astonished to learn that the FAA has no regulatory requirements for an A&P to receive recurrent training of any kind. I found that shocking. If pilots have to go through recurrent training at least every two years, why doesn’t a similar requirement exist for the mechanics who maintain our airplanes?
In 2005, the FAA finally amended Part 145 to require mechanics who are employed by FAA certified repair stations to undergo initial and recurrent training. That’s certainly a step in the right direction. But the majority of A&Ps who work on our piston-powered aircraft are not employed by a certified repair station, so they still are not required to get any recurrent training. And the recurrent training that repair station mechanics receive often tends to reinforce the old way of doing things rather than teaching them about new ones. As a result, it’s not uncommon to find piston-GA mechanics whose knowledge is seriously stale and out-of-date.

Fear of being sued—liticaphobia—is a serious deterrent to mechanics trying something new. Lawsuits against shops and mechanics once were rare, but they have exploded over the last two decades for reasons I will discuss in a future blog post. The cost of defending such lawsuits can be ruinous for an individual mechanic or small business. Mechanics and shops have become very reluctant to try anything new or different, for fear it might come back to bite them in court.

I am certainly not suggesting that all piston-GA mechanics suffer from stale knowledge and a fear of trying new products and methods. The smartest and most talented A&Ps I know are information junkies and leading-edge thinkers. But many mechanics are incredibly resistant to change, very reluctant to adopt new technologies and methodologies, and their opinions often lack any basis in actual hard data. Owners are wise to seek expert second opinions rather than accepting their mechanics recommendations as gospel.

It can take real work for an aircraft owner to find a mechanic who is willing to consider new products and modern maintenance methods, but in my opinion it’s worth the effort.