A Rational Way to Deal With ECI Cylinders

The FAA is simply determined to get rid of thousands of ECI cylinders used on big-bore Continental engines.

Last August the FAA issued a proposed AD that would have required approximately 36,000 aftermarket cylinders built by ECI to be junked, most of them after only 500 hours of operation. The proposed rule also called for repetitive inspections and grouped cylinders by serial number.

The NPRM drew many, many comments, most of them against the proposed AD. But earlier in January the FAA came right back at airplane owners with a revised proposal that essentially requires the cylinders to be removed from the engine after 1,000 hours of operation.

It’s true that 1,000 hours is better than 500, but to me it still isn’t necessary to accomplish the FAA’s objective. Even the NTSB, not exactly a devil may care outfit when it comes to safety, commented that the cylinders should be allowed to fly on until recommended TBO. But the FAA has again ignored the NTSB’s advice, and the advice of everyone else who commented.

The FAA says it has determined that the affected ECI cylinders suffer head separation at a much higher rate than other cylinders. There have been a few instances where the aluminum head did crack and break free from the steel cylinder barrel. Obviously that cylinder no longer functions, and there is at least some risk of fire because fuel and probably spark is still being fed to the failed cylinder head. By there have been no fatal accidents caused by these failures.

It’s impossible for the FAA to know with certainty anything about the failure rates of any cylinder or piston engine component because the data just doesn’t exist. The FAA does get service difficulty reports if shops take the time to file them, but there is absolutely no way to know how much of the universe the reports represent. It’s just hit and miss.

But, I fear the evidence fight is over. For whatever reasons the FAA is absolutely determined that the affected ECI cylinders are “unsafe”–the FAA word. So the FAA objective should be to remove the cylinders from engines in the least disruptive and costly way.

Here is how that can be accomplished. Issue an AD that forbids any ECI cylinder in the affected group from ever being reinstalled in any engine after it has been removed for any reason.

The fundamental problem is that piston engine parts are certified without life limits and without any requirement to document time in service. A cylinder, for example, remains airworthy as long as a licensed mechanic or repair station says it is. And that cylinder can be repaired in all kinds of ways and be returned to an airworthy condition.

But absolutely nothing is known about cylinders once they are removed from an engine because there is no requirement to record anything. For example, at the last annual two cylinders on my high-time engine were simply worn out. The shop bought two overhauled cylinders to replace them. The overhauled cylinders came with the required yellow tag saying they had been repaired and inspected and are airworthy.

But nobody has any clue how many hours are on those cylinders, or even what type of engine they came from. Those cylinders could have been on a turbocharged engine with the higher heat and stress involved but are now on my naturally aspirated engine. They could have come from a 520 and are now on my 550 engine. And the cylinders that came off my engine went to that overhaul shop as a “core” and were most likely repaired and are on yet another engine.

It is this “certified forever” concept of piston engine parts that is, or should be, the issue with ECI cylinders. Without an AD the ECI cylinders the FAA is worried about could fly on being repaired and overhauled repeatedly with no records kept about time in service.

My idea of an AD that simply doesn’t allow reinstallation of one of the covered cylinders would cost owners only the “core” credit we get when a cylinder is replaced or the engine is overhauled. The core credit is typically a few hundred dollars because the overhaul shop that sells you the repaired cylinder needs your old cylinder–the core–to repair and resell. So in this case you wouldn’t have a cylinder to exchange so you would be charged the core credit.

The reality is that many, even most, cylinders will develop some sort of problem during their run between major overhauls. Leaking valves are common, but rings and cylinder barrels wear, valve guides wear and so on. That means the affected ECI cylinder replacement would be spread out. When a cylinder needed to come off for any work that would be it. The cylinder would be retired. And the cost of complying with the AD would be the cost of the core credit as each cylinder is retired.

At major overhaul time all six cylinders would be trashed. The extra cost to the airplane owner would be six core credits. That’s a lot, but still so much better than junking all of your cylinders at the arbitrary 1,000 hours the FAA is proposing.

You can read and comment on the proposed ECI cylinder AD here: http://www.regulations.gov/#!documentDetail;D=FAA-2012-0002-0600

Comments are open until February 23. It may make you feel better to comment that the AD is simply not necessary, but the way the FAA blew off all of those thoughtful and supported comments in the first round I just don’t expect the AD to go away. I think the best we can hope for is to fly the affected cylinders until they need work, and then throw them away when they come off the engine. That’s bad, but not as bad as what the FAA is proposing.

Posted in Mac Clellan's Left Seat Blog | 4 Comments

What We Will Learn From Self-Driving Cars

It’s been nearly a century since gyroscope pioneer Elmer Sperry created the first true autopilot. And autopilots have come a long way since. The most sophisticated can even land the airplane, steer it down the centerline on roll out, and brake the airplane to a stop.

What hasn’t been as successful is creating and maintaining the man-machine interface between the human pilot and iron mike. In many respects the more capable the autopilot has become, the more difficult it is for the human to correctly use and manage the machine.

Now the self-driving car–autonomous operation, if you prefer–is here. Several automakers claim they could deliver a car that drives itself right now if regulators allowed it. And there seems to be wide agreement that many cars will be driving themselves down the streets and highways of the civilized world by 2020.

What this means is that instead of thousands of pilots learning to successfully use autopilots we will soon have millions, maybe many millions, of drivers doing the same thing. The expected explosion in autonomous driving machines will allow us to discover new problems, and new solutions at a very rapid pace. Nothing teaches what works and what doesn’t better and faster than having a whole bunch of people trying to learn the same thing at once.

The lessons from airplane autopilot use is that the machines are not 100 percent reliable, but the bigger problem is that more frequently the autopilot is performing as designed but the human pilot doesn’t understand how it should be functioning.

My favorite story about autopilot mismanagement came from the old King Radio company. King had a service hangar on the airport near its headquarters in Olathe, Kansas. One day an irate Bonanza owner arrived screaming that his King autopilot was trying to kill him.

The Bonanza owner said the airplane, with autopilot engaged, pitched down unexpectedly. He grabbed the controls and pulled back as hard as he could. Luckily he had a friend in the right seat who got on the controls and helped him pull. Together they pulled as hard as they could while one finally was able to pull the autopilot circuit breaker.

But the autopilot was still fighting them. It wouldn’t disengage. They both battled the nose-down control force all the way to touchdown cursing the autopilot that wouldn’t let go.

What happened, of course, is that the pilot started pulling on the controls before disengaging the autopilot. Sensors in the autopilot interpreted the pilot’s actions as the need for nose-down trim and automatically started rolling the trim in, and kept at it. By the time the pilots got the breaker pulled and the autopilot truly dead they still had full nose-down trim fighting them. They didn’t understand their original actions, and so didn’t know to simply re-trim the airplane and go land.

That’s an example of the most basic mismanagement of autopilots. More common errors are failing to understand what a mode selection will do. Or why it may or may not capture a glideslope from above. Or why it didn’t switch from roll steering to approach mode. Or what the heck is FLCH mode? And on and on.

There is a little standardization in autopilot design and function, but there are often differences in how the same autopilot operates from one airplane type to another. And, except for newer airplanes with totally standardized cockpits, there is very little complete training on how to use autopilots at the GA level.

My question is will the car guys do better? No matter how incomplete pilot training is, driving training is essentially zero. That means the car autopilot will have to be so intuitive that drivers get it right the first and every time with about the same level of instruction on how to operate the entertainment system. Well, actually it needs to be easier to use the car autopilot than the radio or there will be cars driving off to who knows where.

Driving a car in the close confines streets and roads, along with the stop and go that is part of traffic, is daunting compared to the relatively wide open spaces we fly through. But the car guys aren’t bound by evolutionary designs as we are in aviation. The car autopilot can start from scratch, using very advanced technology, and can be integrated fully during original design of the car.

But I believe there will be one issue both airplane and car autopilots share–many people just won’t trust them. I have seen that for decades in aviation where human pilots, especially when the workload is high and when they need the autopilot most, just can’t trust it and turn it off. I bet we will see the same in cars. Most of us have been driving since we were teenagers and when that darn thing does something we don’t like, or don’t expect, we’ll be looking for the off button.

However soon it happens the self-driving car can only be good news for teaching us how to make an autopilot we humans understand, and trust, at least most of the time. Let the great experiment begin.

Posted in Mac Clellan's Left Seat Blog | 8 Comments

The Affordable Aircraft Expo

The U.S. Sport Aviation Expo at Sebring this week has rebranded itself The Affordable Aircraft Expo. And I think that is a terrific idea.

The driving force behind the show has been creation of the Light Sport Aircraft category a little more than 10 years ago. LSA arrived with great promise and dozens and dozens of companies, mostly new to airplane manufacturing, built airplanes to the new standards.

The fundamental concept of LSA, and the Sport Pilot license that goes with it, is simplification. We all wanted a quicker and easier path for companies to gain approval to manufacture light and basic airplanes. And the Sport Pilot rule streamlines the requirements to qualify to fly very light airplanes under daylight VFR.

But words like simplified, streamlined, less burdensome, less complicated and on and on are really synonyms for lower cost. No matter what you call it the LSA rule was intended to make newly manufactured airplanes available for a fraction of the cost of standard airplanes from traditional manufacturers.

And the LSA rule did work. But not exactly as those of us who supported the rule hoped. A new quality LSA is less costly than a new Cessna, or Piper, but is still a lot more than many expected. Most LSA are priced north of 100 grand, and that’s still not “cheap” by anybody’s standard.

What the Sebring show people are doing now, and what I applaud, is move their focus off of LSA and target any and all affordable airplanes. LSA are the most affordable airplane if you want brand new, but existing basic standard category airplanes can be as affordable, or even more so. And then there are also homebuilts which trade sweat equity for lower price, and a range of ultralights that can get you off the ground for the fewest bucks and least required training and regulation.

Among the shiny new LSA and kit airplanes at Sebring will be at least a few equally shiny standard airplanes. Shiny because they have brand new paint and interiors, but affordable because they were built years ago and are fully depreciated.

Sporty’s is showing what can only be called a stripped down Skyhawk. The Sporty’s training concept is that for pre-solo and the big part of the whole private pilot curriculum you don’t need anything more than the most basic instruments and avionics. Sporty’s calls the airplane the 172LITE and they believe it can be rented for $99 per hour all-up.

AOPA has its own training airplane refurb project in the Reimagined Cessna 152. Again, by sprucing up an older but still sound airplane entry cost are lower than any new airplane, including LSA, and operating cost are manageable.

You can, of course, buy one of thousands of older piston singles for well under $50,000 without doing a total overhaul and get lots of flying capability for the money.

What Sebring is doing is trying to highlight the options available. For example, a new LSA will cost more to buy than nearly all older basic standard category singles, but the LSA will probably cost less to fly because of lower maintenance costs and fuel burns. There are also differing maintenance standards to consider which will impact costs.

You can fly an LSA to Sport Pilot standards using a driver’s license to certify medical qualification. That’s a plus for many pilots. But you can also fly some of the most basic standard two-seaters such as Cubs and Champs as a Sport Pilot. Those airplanes remain in their original certification category with all the requirements that go with that, but the pilot can be a Sport Pilot, or any other level of pilot who chooses not to have a current medical.

Bottom line is that Sebring is about recreational airplanes. These are not machines meant to travel on a schedule, or fly in any but benign weather. Because they offer little utility in a traditional sense pilots judge them by their recreational return on investment. And that gets us back to affordable.

Sebring is about getting off the ground on nice days just to enjoy the ride. And there are so many ways to do that I’m really glad to see a show devoted to explaining and exploring the options. Early interest in the show seems to be up so I believe The Affordable Aircraft Expo is on the right track.

Posted in Mac Clellan's Left Seat Blog | 28 Comments

The FAA Likes My ADS-B Out Performance

The ADS-B out certification in my airplane had been done by Mayday Avionics in Grand Rapids. Mayday is a very capable avionics shop. It filed all the Form 337s for the major alterations that are required under the installation STC. When the software updates, flight manuals and other paperwork and inspections were done, Mayday tested the signal using advanced ground test equipment. The ADS-B out equipment and installation in my airplane met all of the rules and is ready for the 2020 mandate.

But the FAA has been finding that not all ADS-B installations are done correctly. Or maybe there are some undiscovered equipment problems in the airplane. Or maybe not every shop has the experience and advanced equipment of Mayday. But for whatever reason a significant number of airplanes are flying with ADS-B equipment that does not meet all of the minimum requirements for actual use in flight.

So the FAA is offering to “test” your ADS-B out and send you a report. All you need to do is send an email to the address on this FAA web page: http://www.faa.gov/nextgen/programs/adsb/. You must tell the FAA what the specific model names of your ADS-B transmitting equipment and position source.

In my case the transmission is sent by the Garmin GTX330ES transponder with extended squitter. The 330 is a Mode S transponder so it, like all transponders, broadcasts on 1090 MHz. The position source is a Garmin GNS530W navigator. The 530W and the STC it is installed under meets all of the accuracy requirements for advanced GPS navigation, including LPV approaches. That means the 530W also qualifies as a position source for ADS-B out.

I’m not sure that you need to tell the FAA when you will be flying because if you have an approved ADS-B installed it broadcasts all of the time, including on the ground. But I knew I was flying from Muskegon to Battle Creek the next day so I included that in the email, and also that I would be flying IFR.

In a couple days I received an email from the FAA along with a status report of how my ADS-B performed, and also a guide explaining how to read the report. The FAA person sending the email also included a very helpful note saying that “everything looks ok.”

Neither Muskegon or Battle Creek have the ground equipment to track ADS-B movements. So far only the larger airline airports have ADS-B ground coverage so only the flight performance of my equipment could be checked.

The FAA report shows that ADS-B signals send such complete information so everything can be known about my airplane. For example, the report includes my assigned ICAO number that is matched to my N-number. It knows my mailing address, the make and model of my airplane, and even its serial number.

The flight to Battle Creek with an ILS approach to Runway 23R took 28 minutes and 11 seconds. During that time the ADS-B out made 8,827 reports. The rules require a report at least once each second. The FAA ground network processed 2,329 reports so you can see lots more than the minimum required data were reported by my system.

The good news is that the ADS-B ground system found zero missing elements in the reports and there were no failures of any kind in any of the reports.

The horizontal accuracy was better than 10 meters at all times, and the velocity error was better than 0.3 meters per second 100 percent of the time. The source integrity level was better than 1 in 10 million. The ground system could validate 99.2 percent of all reports from my ADS-B equipment.

Even though I have been writing about ADS-B and talking with the people who designed the equipment for at least 20 years I still find the amount of data being automatically reported and its accuracy to be amazing. Even the short range approach control radars often have errors of a mile or two, or even more, but a GA level ADS-B out system is reporting the 3-D location of an airplane within a few meters.

There is absolutely no question ADS-B will allow a far superior IFR traffic system and I’m very happy to see that in real world flying with real world equipment the system is working. If you have ADS-B out installed I certainly recommend you ask the FAA to produce a report on how it’s performing. It’s free and quick and confirms the in flight operation matches ground testing.

Of course, the vast detail of the ADS-B report doesn’t answer the question of why VFR pilots flying in regulated airspeed need to broadcast so much data of such extreme precision, but that’s a different discussion.

Also, I’m happy to report that Sean Elliott, the EAA VP who handles advocacy and government affairs, was at FAA headquarters shortly before Christmas when my blog about a complete lack of guidance on how to certify ADS-B out in experimentals appeared. The FAA told Sean they were aware of the problem and were working to establish a clear path to ADS-B out certificationi for airplanes that do not have a type certificate. Nobody knows how long that will take, but at least we know the FAA is aware of the issue and knows that it must be solved so homebuilts and other experimentals can be equipped before the 2020 deadline.

Posted in Mac Clellan's Left Seat Blog | 42 Comments

Cirrus Is Making Me A Single Engine Jet Believer

I lost count long ago of how many single engine jet projects have been announced, usually with great hullabaloo, impossibly fantastic performance and even more unbelievably low price.

Many of the personal jets were the dream of startup companies that had never built an airplane of any type. Those were easy to dismiss as the longest of long shots. But established airplane builders such as Diamond and Piper invested heavily in single engine jet programs with both reaching at least the proof of concept flying airplane stage.

Even mighty Gulfstream dabbled with a single engine jet design in the early 1980s with the Hustler, later renamed the Peregrine. That project morphed from a single engine turboprop, to a turboprop with a jet engine in the tail, and finally to a single powerful turbofan before the plug was pulled.

Just over eight years ago Cirrus entered the personal jet race, if we can call it that, by announcing what was dubbed “The Jet”. Rumors of work on a jet single were so pervasive that people in the company didn’t really need a unique name because the entire GA world was simply calling it the Cirrus jet.

When it was announced The Jet was on such a long list of projects it was hard to see why it had a better chance of success than the others. But there were a few reasons I thought Cirrus maybe could pull it off.

First, Cirrus had come from nowhere to design and manufacture piston singles, something that is incredibly rare. The road was rocky, virtually none of the original predictions in terms of schedule, performance and price came true. But, still, Cirrus had become a real airplane manufacturer from scratch and that was worth a lot of points when making the betting line.

Another reason I thought The Jet might have a chance is that the initial speed, range, payload and altitude goals were the most modest, and therefore I believed most realistic. The cruise speed goal was around 300 knots, maximum range around 1,000 nm, and a ceiling below 30,000 feet.

Finally, I am impressed with the Cirrus jet engine location. Imbedding the engine in the fuselage has been done many times, particularly in fighters, but there are significant issues in designing inlet ducts that don’t rob too much power and function at the extremes of attitude and angle of attack. And that’s not to mention how to handle ice buildup inside the duct.

Locating the engine on the vertical fin as Piper proposed gives the engine a good clean air inlet but can create pitching moments when power is added or reduced. The loads on the fin are considerable so structural weight goes up. And locating such a concentration of weight at the extreme aft end of the airplane presents considerable CG issues.

The Cirrus decision to mount the engine atop the aft fuselage and send the exhaust between the stabilizers of a V-tail is a solution with, as far as I can tell, the fewest compromises and complications. There is no need for an inlet duct. The engine exhaust is not far above the water line so pitch change is small. And the engine is clear of likely FOD sources. A small ramp on the fuselage top redirects the engine exhaust upward to closely parallel the line of flight.

The big problem with the Cirrus jet was clearly lack of initial funding when the program was publically announced in 2006. A proof of concept airplane that resembled what might be actually certified was built and flew, but progress stalled. The global economic recession that began in 2008 didn’t help at all.

But that’s all old news. Cirrus new parent company appears to be committed to the jet program. Dozens of engineers have been hired, people with experience in creating certifiable and producible airplanes. New facilities dedicated to jet development have been built. And most importantly Cirrus has built three prototypes that conform to the anticipated final design.

It’s next to impossible to fully test and develop a complex airplane with only a single prototype so all significant companies build several test airplanes to assign to various segments of flight testing and certification. Cirrus has done that with first flight of its third conforming prototype jet a few weeks ago.

Cirrus has lots of work ahead to push the SF50 through to production. The Cirrus Airframe Parachute System (CAPS) is a huge project  because the jet will probably weigh at least 2,000 pounds more than the SR22 piston single, and will fly faster. But the company has taken one big potential show stopper off the table by opting for a stall barrier system as most jets use.

Last spring when it was clear Cirrus was ramping up for real to develop the jet I asked company co-founder Dale Kalpmeier why they pressed ahead when others haven’t. His response was that Cirrus has hundreds of pilots who want to buy The Jet. And that is more important than any of the difficult structural, system and aerodynamic issues Cirrus faces. Pilots want a single engine jet, and for the first time, I really am convinced they will be able to buy one before too much longer.

Posted in Mac Clellan's Left Seat Blog | 13 Comments

What a Pilot Wants for Christmas

There has been loads of reporting on psychological and behavioral studies that show we humans gain more happiness and better memories from an experience than by acquiring a new possession. In other words the lasting effects of a wonderful vacation are greater than the happiness of buying a new car or piece of jewelry.

I can believe that. Most stories we tell when among friends and relatives begin with something like “do you remember the time . . . .” And the story doesn’t often include sitting in a car salesman’s office closing the deal on a new BMW. The story is about something really wonderful–or unbelievably stupid–that we lived through.

But this reality leaves pilots in a conundrum. We want to accumulate new flying memories, but unless you’re some kind of a 60s leftover, nobody can fly without an airplane. So to build happiness we must acquire the possession–an airplane–and then we must have the experience of flying it.

Thousands of pilots have succeeded in the first step. Airports and hangars are filled with airplanes of all sorts. But increasingly we are failing at the second step to flying happiness and memory building. We just aren’t flying the airplanes we already have very much.

There is no reliable measure of flying hours in personal airplanes, but we all know it’s down, and decreasing every year. The most precise indicator is avgas sales and it has done nothing but decline for decades.

We can all rail against the cost of airplanes, but somebody already owns them. The acquisition cost is already covered. We can blame high maintenance cost, but unless we simply allow the airplane to lapse into an unairworthy condition, we are paying those, too. And, of course, the cost of fuel shoulders most of the blame. But when adjusted for inflation avgas prices have been pretty stable, and high for a long time.

I think what’s in short supply is a reason for airplane owners to fly. And that’s where we need to change. We need to accumulate the experience that research knows will stay with us and contribute to our happiness long after the thrill of acquiring the airplane is gone.

For me the reason to fly has always been to go someplace. Traveling on my own schedule is the reason I learned to fly and it has been rewarding. And thinking back, it’s the challenging flights I remember most. The beautiful blue sky smooth air trips were pleasant, but getting their safely and sanely when the weather or traffic was at its worst was most gratifying and memorable.

Other pilots I know love to shoehorn their airplane into some wilderness spot far from civilization. And I’m sure the more desolate and challenging the strip the more powerful and lasting the memories.

It’s the same for pilots who want to fly aerobatics. The perfect maneuver is a memory, but so are all the attempts to get there.

And there is a core of dedicated teachers who are so essential to create a new generation of pilots. Of course, some pilots are just building time in the right seat, and that’s necessary too, but the true teachers are logging rewarding memories along with the hours.

Something we can all do when searching for a new aviation experience and lasting memory is add a new license or rating. I don’t know any pilot who calls a check ride fun, but I also don’ t know any who forgets them.

The longest term memory builders must be the pilots who build their own airplanes. I’m not sure which memory stands out most, the years of building or the flying, but the whole process is an investment in time that surely must last a lifetime.

So the Christmas present I hope all of us pilots will give to ourselves is to fly more, challenge ourselves more, and build a bigger library of memories to carry us on. After all, if you don’ t go flying you can’t say “did I tell you about the time. . . . ”

Merry Christmas.

Posted in Mac Clellan's Left Seat Blog | 5 Comments

Can You Install ADS-B Now? Maybe Not

So you’re ready to take the plunge and install equipment that meets FAR 91.225 and 91.227 requiring ADS-B “out” for flight in regulated airspace after the end of 2019. Can you do that? Is there a certified option available for your airplane? Maybe. But maybe not.

If you built your own airplane, or bought an E-AB that someone else built, the answer is no. If you own an LSA the answer is also almost certainly no. And if you own a pretty new standard production airplane with a factory installed flat glass avionics system the answer is also probably no.

Sounds crazy, doesn’t it? The FAA and the avionics industry are urging all airplane owners to act now and get certified ADS-B equipment installed and approved because there won’t be enough radio shop capacity to handle the crush of installs at the last moment.

But the FAA has tied itself into such regulator knots that many airplane owners simply don’t have a certified path to ADS-B compliance.

When the FAA was finalizing the ADS-B rules more than six years ago it was, and remains, extremely concerned that all approved equipment meet a very high standard for precision and reliability. After all, when we make it to an all-ADS-B world an airplane will be invisible if its system doesn’t function. Worse yet, if an ADS-B broadcasts inaccurate position, altitude, velocity and so on it could create a collision threat rather than resolve it.

So the FAA made the ADS-B certification rules extremely strict. For example, initially every specific piece of equipment must be approved in each type of airplane. There would be no multi-model (AML) STCs granted. That idea lasted for a couple years until it became unworkable so now there are AMLs covering installation of specific ADS-B equipment in hundreds of standard category airplanes. But so far the FAA is clinging to its individual model approval for helicopters.

Under its number one priority to keep ADS-B rules strict the FAA apparently forgot about homebuilts and other experimental airplanes. The rules require an STC (supplemental TYPE certificate) or TC (TYPE certificate). I capitalized type because that’s what is missing in an experimental. By its very existence an experimental aircraft has no type certificate. It’s a one-off, no matter if homebuilt, prototype, exhibition or developmental.

Maybe ADS-B in a homebuilt could be certified by an FAA field approval where an FAA office approves modification of a specific airplane. But that doesn’t seem to work for homebuilts. It is the builder who is the “approved” modifier and equipment installer. A field approval normally is granted to an individual based on work performed on other airplanes of the same type. There’s that word again.

Some builders are installing ADS-B equipment that is potentially certifiable and believe they have met the rule. But they haven’t. The rule requires flight manual supplements, operating restrictions, a performance test and other approved paperwork and there is no way for a builder to get there.

Under the ASTM rules that govern factory built LSA only the manufacturer can approve any change in the airplane, including installation of avionics. So there can be no STC for an LSA because there is no FAA type certificate for the airplane. No radio shop can ask for a field approval because only the manufacturer, not the FAA, can approve any change. How will this be resolved for LSA owners who want and need ADS-B capability? The situation is particularly worrisome for owners of LSA whose manufacture has exited the business. Who will spend the money to get an ASTM approval for those airplanes and how would the process work?

And the airplane left out of a path to ADS-B so far that is most surprising is a newer airplane with glass cockpit. When a complete avionics system is installed by the airframe manufacturer it is usually part of the type certificate, just like the ailerons or wing structure. The only way to add ADS-B capability to such systems is for the manufacturer to amend the TC, which can be cumbersome, and expensive and so far none have complied that I know of.

In some other airplanes a manufacturer delivers a new airplane with a complete integrated avionics system under an STC. But the complication there is that the airframe manufacturer may own the STC, or almost certainly controls the STC. That means that even though the maker of the avionics has ADS-B equipment designed and ready for certification it can’t get approval on its own because it doesn’t control the STC.

I’m sure there are other situations that I’m not thinking of where an airplane owner ready to invest in ADS-B out equipment simply has no path to certification. And changing FAA regulations never happens quickly so I don’t know how these conundrums will be resolved.

If you have a homebuilt or LSA what can you do? The only sensible answer is to wait on the FAA. If you buy and install equipment that you think can be approved in the future you may guess wrong. If you have an airplane delivered from the factory with a fully integrated avionics system you’re stuck waiting, too. So the mixed message from the FAA is the standard hurry up and wait.

Posted in Mac Clellan's Left Seat Blog | 124 Comments

A Year Is Too Short

I’m not exactly sure when or why the year–12 months–became enshrined in so many aviation regulations. But it did. And it’s not nearly long enough, particularly when it comes to annual inspection of our airplanes.

There is no question that calendar time, not just operating time, exacts a toll on any machine. So inspection intervals based on the passage of time make sense. And maybe at some point the passing of a full year was reasonable cause for an inspection. After all, wood left out in the elements can degrade a lot in a year. And so could the cotton fabric that covered the airfames. And the steel tube that was often used for primary structure could rust very quickly.

But those days are long gone. Of course, tube and fabric airplanes still exist and are still being built, but the fabric is synthetic that lasts for decades and corrosion control and wood preservation has vastly improved.  And the big majority of airplanes are made from aluminum, and there is a growing number of composite construction airplanes, all of which age much more slowly than the fleet did when the annual inspection requirement was established.

What we’re left with is the wear and tear of significant disassembly necessary to complete an annual inspection. Simply because 12 months have passed, an airplane that is working just fine has to be torn apart just to be sure it’s working, and that is guaranteed to cause at least some wear, and also create at least a few issues when things are reassembled.

Even worse is that we are all flying fewer and fewer hours. Meaningful annual flight hour averages for typical personal airplanes are impossible to come by, but I’m convinced the annual average of flying is somewhere around 50 hours. The flight times are so low there is simply no way we are wearing our airplanes out from actual use.

The people who do fly a lot–the airlines and business jets–have made great progress in moving beyond arbitrary calendar time limits. The Maintenance Steering Group (MSG) is an industry committee that works with the FAA and manufacturers to design in maintainability. The goal is to increase the time between maintenance events and make line replacement of failed units quick and inexpensive. Many newly designed jets have a basic maintenance interval of 600 flight hours or more. That means you only check the oil and tire pressure and stuff like that for the entire 600 flying hour interval.

We can’t redesign our airplanes to an MSG standard, but as Mike Busch has repeatedly pointed out, we could employ evidence based inspection and maintenance in place of the arbitrary annual. And the evidence is not on the side of an every 12 month disassembly to find critical problems.

When you think about what calendar time does to an airplane versus the wear of flight everything bad that can go wrong when an airplane is not flying happens very slowly. I guess it’s possible a crack could develop in a motionless airplane, but not very likely. Wear of moving parts doesn’t happen without flight. Yes, lubricant does dry out, hoses and rubber seals do decay, but that happens over many years, especially to airplanes stored indoors.

Internal engine corrosion is a threat to an airplane that flies little, but only to your wallet. If a corroded cam lobe rounds out, or a rusty cylinder wall wears, the engine won’t stop suddenly. Oil consumption and rough operation will tell you it’s time for maintenance if corrosion has attacked your engine.

What we need is to focus inspections on flight hours and stretch out the calendar intervals to a point that makes sense. Certainly a full inspection every other year would not compromise safety for an airplane that flies 100 hours or less a year. And that would cut routine maintenance costs by half. And for many of us maintenance is the largest component of airplane ownership cost, so half would be big, and a safe place to start. For example, if the requirement were 200 flying hours or two years between what is now an annual inspection, whichever came first, most of us would save a bundle.

Just as we are all demanding that the FAA overhaul the third class medical because there is no evidence it adds to safety, it’s time to do the same for the annual inspection. A year is just too soon to take a personal airplane apart.

Posted in Mac Clellan's Left Seat Blog | 28 Comments

Want A High Performance Two-Seater? Build It Yourself

The most popular category of homebuilt airplane is a two-seater. And there are even a bunch of single seaters flying. And most of these airplanes offer high performance either in speed or aerobatic capability, or both.

But if you look at standard category two-seat airplanes you find only the most modest performance. Even though Cubs, and Champs, and Cessna 140s/150s and many other types were built in enormous numbers they are also among the slowest and least powerful production airplanes.

It’s hard to think of a high performance one or two-seat standard production airplane because there have been so few. There may be an airplane I’m forgetting, but the Mooney M18 Mite is the only production single-seat airplane that comes to mind. Even the Pitts, when it was put into production, was the larger two-seat version.

The only fast production two-seater that comes to mind is the Wing Derringer, a very small piston twin that was very briefly built in the late 1970s. The Derringer evolved from the Thorp homebuilt. I don’t believe more than a dozen of the tiny twins were manufactured before the company failed.

The reasons high performance single and two-seat airplanes haven’t succeeded in standard category production are complicated, but can be distilled to one overall factor–cost.

The reality in airplane production is that building an airplane a little larger to accommodate four, even six, instead of two people costs comparatively little. The costly components such as engines, landing gear, systems, avionics and so on cost the same for a high performance two-seater or installed in a four-seater. And the demand for at least four seats is simply larger so that tips the scales for an airplane manufacturer.

You can see this phenomenon at work in several production airplane families. The Bonanza line is probably the best example. When Beech introduced the Model 33 Debonair it had lower power and thus less performance than the Bonanza. But as the Model 33 evolved Beech installed the same 285 hp engine as the six-seat Model A36 so performance was about the same. Then Beech dropped the name Debonair and called all of the models Bonanzas.

But it soon became apparent that is cost Beech only a little more to build the six-seat A36 compared to the four-seat F33A Bonanza, but the six-seater commanded a significantly larger price and demand in the market. The F33A went out of production years ago but the A36 continues on.

Cessna and Piper reached similar conclusions with their two-seat lines. Cessna found it no longer economical to build the two-seat 152, but the four-seat Skyhawk is in production. The same thing happened at Piper where the two-seat Tomahawk has been long gone while the four-seat Warrior/Archer is still a success.

In kit airplanes we have seen the opposite trend. High performance two-seat designs dominate while four or six-seat kit airplanes are not that common.

I guess it’s the mythical “invisible hand of the market” at work. Companies that manufacture standard airplanes have to appeal to the largest possible audience. Companies that make kits must appeal to pilots who want something they can’t get anywhere else.

So if you want to fly fast in a very maneuverable airplane there is a solution that manufacturers can’t provide–a kit airplane. And the numbers show more and more pilots don’t want to haul around extra seats just to fly fast and far.

Posted in Mac Clellan's Left Seat Blog | 9 Comments

Do the FARs Still Matter?

I was looking out the window of the diner on the main street in our little Lake Michigan beach town and saw a big white SUV drive out the wrong way from the one-way entrance for the parking lot across the street. There are signs forbidding this, and arrows and words painted on the pavement. There’s no way the driver could have been unaware he was breaking a rule.

There was no conflict with other cars so the rule defiance caused no threat. I can only assume the driver simply believed the rules didn’t apply to him, at least not at that moment.

The incident made me think about an increase in fundamental FAR breaking that I have been seeing in NTSB accident reports over the past few years. I read every fatal accident report when it becomes final. I haven’t tried to tally how many reports find FAR violations, but I am certain the number is growing.

Of course, most serious accidents involve some sort of rule breaking because, in general, it’s against the law to crash. Operational rules infractions have been an accident cause forever. For example, the VFR pilot who flies into weather below VFR minimums obviously chose to break an FAR. So did the pilot who knowingly–or at least should have known–about conditions that were beyond his capability or that of his airplane. That violates rule 91.13, the careless and reckless clause. And so does buzzing and many other inordinately risky things some pilots do in airplanes.

But what I have been noticing is an increase in violation of fundamental FARs, rule breaking that requires not just one wrong decision in the cockpit, but many, even hundreds of decisions to ignore the rule while safely on the ground.

For example, it’s not uncommon now to read in accident reports that the airplane has not had an annual, or in the case of experimentals a condition inspection, for years before the accident. ADs are frequently ignored and increasingly airplane owners have not properly re-registered their airplanes as required.

NTSB reports show that pilots frequently blow off currency requirements for the basics such as making the three landings and takeoffs in the past 90 days before carrying passengers. Often the biennial flight review is years in arrears. It’s not rare to read about pilots who lacked a category or class rating to fly an airplane, or even to have any valid certificate of any level at all.

The most common rules infractions reported by the NTSB involve medical certification. Autopsies of pilots killed in accidents commonly show the pilot had known medical conditions not reported to the AME. And the NTSB finds that a huge number of pilots, maybe even a majority, involved in fatal accidents are taking medications not reported or approved by their AME.

But just like the driver I watched break the one-way traffic rule, pilots breaking non-operational rules are seldom the cause of an accident. For example, the NTSB goes to great length to examine the maintenance records of a crashed airplane, often finds huge rule violations, and then notes that everything in the airplane appears to have been working normally before impact. And that makes sense. Is an airplane going to break just because it’s been 14 months, or two years, or five years since its last annual inspection?

The same goes for rules like pilot currency. Do you forget how to land if you haven’t done it in 100 days instead of 90? Has the biennial flight review prevented an accident? Does even having a pilot certificate prove that you know how to fly?

And the situation is really murky in the medical area. The NTSB will often list several drugs found in a pilot’s system, including alcohol and illicit drugs, and then note that there isn’t direct evidence the drugs contributed to the accident. A total pilot incapacitation in flight is quite rare, and more often than not, the pilot who becomes incapacitated was not breaking any rules.

Private flying is very much a self-regulated activity. In more than 45 years of flying nobody has ever asked to see any paperwork on me or my airplane except when I voluntarily go for training, a new rating, or take my airplane to the shop for maintenance. Unless you are involved in an accident or serious incident you can almost certainly fly on ignoring nearly all of the FARs without much fear of being caught.

But historically we haven’t done that. The pilots I know and grew up with wouldn’t think of flying their airplane to the shop for an annual without a ferry permit even if it was only one day beyond the limit. And we all pay attention to the 90 day currency rule, even though it, like nearly all rules, is totally arbitrary. And on and on.

Is that attitude changing? The findings in NTSB accident reports appear to say yes. Maybe, like that SUV driver, we in aviation are becoming libertarians. Rules are for somebody else, and if we don’t cause conflict or add risk to others why should arbitrary rules apply to us?

I hope I’m wrong because aviation safety comes from creating and following procedures and norms, arbitrary though they may be.

What do you think?

Posted in Mac Clellan's Left Seat Blog | 41 Comments