The Problem with Checklists

Having finished reading The Checklist Manifesto, which deals with how checklist procedures can and have improved the delivery of medical care, I found some thoughts on aviation checklist procedures bubbled to the surface. The author, Atul Gawande, credits aviation as the inspiration for implementing checklist procedures in medicine. While there's no doubt that checklists help pilots complete complex procedures, the mere existence of a checklist doesn't immunize us from disaster. Pilot and aircrew performance is tightly linked to the quality and appropriateness of the checklist as well as checklist discipline. And let's not sidestep the whole issue of having to face a situation for which no checklist exists.

Appropriate and Useful

A fellow freight pilot once observed that there are just two kinds of mistakes that pilots can make: Those that embarrass us and those that can damage the airplane and/or kill us. An airline pilot friend once confided that he realized he could make errors in the cockpit at any time. His goal was to uncover any errors and correct them before they became a safety issue. For checklists to be an effective first line of defense against fatal mistakes, they must contain the crucial tasks and actions that apply to the situation at hand. Once a good checklist has been made available, pilots have to follow it. Here's a video a horrific accident during the test flight of a turbine conversion for the Caribou. The crew apparately neglected to remove the control lock, with deadly results.

One of Gawande's central themes is that the development of useful and appropriate checklists is aided by organizations that exhibit teamwork, continuous enhancement, and decentralized control. Gawande cites a study where a checklist was developed for the medical procedure of inserting central line. The steps were simple but it turns out that some of the crucial ones were often skipped, resulting in a high rate of infection, complications, and even patient death. When a checklist was developed for central lines and adhered to, the rate of infection dropped dramatically, survival rates improved and (here's what got a lot of attention) hospitals saved a ton of money. Interestingly, it was nurses who often reminded doctors when they were about to make a mistake, like forgetting to don a surgical mask or use a sterile drape.

The sort of cooperation being suggested by Gawande, where decision making, process improvement and double-checks are performed by people on the front lines, is not always what happens in aviation. Top-down organizational structure is often the rule in aviation, with the FAA being at the top of the heap. When I flew freight, I was astonished to learn that the checklists for our aircrafts' optional equipment weren't included in the regular manufacturer's checklist. Checks that needed to be done every day were strewn throughout the Supplements section of the Approved Aircraft Flight Manual. Creating a company checklist seemed like the answer, but that would have required a lot of time, effort and money since the checklist would need to be ... wait for it ... approved by the FAA. So there were procedures in the manufacturer's checklist that were incorrect or missing and the FAA's regulations (the ones supposed to ensure safety) condoned an environment where required equipment checks were easily forgotten or skipped altogether. At least this gave us something to talk about during recurrent training.

Gawande's glowing view of aviation checklists aside, I'd be remiss if I didn't point out that many aircraft manufacturer checklists are woefully inadequate, incomplete, and in some cases they even contain incorrect information. One manufacturer's After Landing checklist for a late-model aircraft in which I instruct contains just one task: FLAPS UP. Don't mistake this simplicity for elegance, because in point of fact it is inadequate. Checklist procedures continue to be spread throughout Approved Aircraft Flight Manuals, due to the manner in which aircraft and their components are certificated, and this may lead a pilot to incorrectly conclude that all of the manufacturer's checklist content is irrelevant. 

The good news here is that student pilots (and certificated pilots, too) flying under 14 CFR parts 61 and 91 can develop their own checklists. Just ensure that whatever checklists you develop contain, at their core, the manufacturer's checklist items. Creating your own checklist can be a great learning experience, but borrow an idea from Gawande's book and have some other pilots and instructors check your work for accuracy and completeness.

Familiarity Breeds ... Complacency

Assuming you have correct and complete checklists, there is another issue to address. Do the same routine countless times and you'll find you tend to skip using the checklist, do the tasks from memory, or use a flow check or mnemonic. Variety is the spice of life and I think it might even be the key to safety. There's emerging research that indicates what we have always suspected; endless routine is booooring and it can actually keep our brains from performing well.

On the ground, I still recommend using the checklist as a do-list, but that doesn't mean you can't have a passenger participate by reading the checklist to you. In the air you can mix things up by alternating between the checklist and a flow check or a mnemonic backed up with the checklist. Mix up your procedural routine and you may find checklist procedures to be less onerous, just be sure you don't skip any steps in the process.

I'm a big fan of Foreflight's Checklist app for the iPhone (it works on the iPad, too). What's nice about this app is that it's hard to lose your place as you check off items. Should you miss something, the app takes you right back to the first thing you skipped. If you discover a missing task or want to change the order of tasks, you can edit a checklist on the spot; no need to print out a new version, laminate it, etc. I fly a lot of different aircraft types and the checklist app really helps me keep it all straight without carrying a gazillion paper checklists.

Infrequently Used = Easily Forgotten

With abnormal or emergency checklists, we're faced with the opposite problem of routine checklists. Under stress and time pressure, these seldom-used checklists can make us feel confused and clumsy. The answer is to review these checklists by doing some arm chair flying from time to time, imagine an abnormal or emergency situation, then work you way through the checklist. You can also practice this in a simulator, just like the airlines do. Review emergency and abnormal checklists once a month and you'll be less likely to be flummoxed should a real emergency occur in flight or on the ground.

Designers and engineers can't anticipate every possible situation that a pilot or flight crew might face, so there isn't a checklist for all possible abnormal or emergency situations. Several years ago, flying in the wee hours of the morning of course, I heard a single, loud chirp every few seconds combined with annunciator lights flashing on and off. After a few confusing minutes (it didn't help that I'd barely gotten 6 hours of sleep in my 8 hour rest period), I determined the generator was being tripped off-line and then coming back on-line, all on its own, over and over. A quick review of the checklists showed there was no defined procedure for this problem. I followed the "generator offline" checklist as best I could and thankfully there was a standby electrical system. When I got on the ground and described the problem to maintenance, their first reaction was "That can't be!" Eventually the root cause was found and it did turn out to be an oddball failure.

I've witnessed numerous landing gear system problems for which there was no checklist. Most aircraft have emergency landing gear extension procedures, but many do not have checklist for situations like the landing gear failing to retract or only two out of three landing gear being extended. One of the most potentially dangerous situations you can face in single-pilot operations is an abnormality or emergency for which there is no checklist. This is where pilots try to use their knowledge of the aircraft systems to decide the correct course of action, in effect creating their own checklist in the moment.

The key in these situations is don't be in a hurry. Think very carefully and avoid impulsively jumping to any conclusions or simple explanations. If you have another pilot or a passenger on board, involve them in the process even if that only means you talking out loud and them listening to your thought process. You can learn a lot by listening to yourself talk.

Pessimistic or Realistic

It's been said that a good pilot is a pessimist, but I think being a realist may be better. Avoid an overly optimistic or inflated view of your skills, your knowledge, or your currency. Remember that there are mistakes that can embarrass you and mistakes that can kill you. The only thing standing between you and a fatal error just might be an open mind and a good checklist.

Our Menu Has Changed

Looking back at this year and the last ten years, many important things happened in aviation in general and general aviation in particular. If that sounds confusing, it's fitting because the last decade has been a bit confusing. Here's my round-up/rant on some of the major aviation events of the last ten years.

The Cirrus SR22 received certification in 2000 and quickly became the best selling GA aircraft. Ten years later, with the economy slowly trying to crawl out of what can only be described as a slippery commode, the company is behind on their rent and co-founder Alan Klapmeier is no longer employed by Cirrus.

Very Light Jets were going to transform air transportation by utilizing smaller airports, avoiding airline delays at large airports, and essentially bypassing the airline-style security screening. The subtext here was "Those able to afford to travel by private aircraft should not be asked to remove their shoes and belts." Arguments over whether swarms of VLJs would improve air traffic delays for passengers or simply clog up our allegedly antiquated air traffic control system became moot when the market for these aircraft never really materialized and Eclipse Aviation, one of the pioneers of the VLJ, went into Chapter 11 (bankruptcy) and then ultimately into Chapter 7 (liquidation).

The use of Unmanned Aerial Vehicles has grown tremendously, though mostly for military uses. In my neck of the woods, a Temporary Flight Restriction was created around Beale Air Force Base, but it's anything but temporary: It is, in fact, in effect most of the time. There has also been a push to allow UAVs to be used for police surveillance and other security tasks. How and when UAVs will mix with civilian, manned aircraft has got to be the most under-reported story of the decade.

The best, feel-good aviation story of the decade would have to be the ditching of an Airbus A320 in the Hudson River after multiple bird strikes crippled both engines. The successful outcome of this ditching involved a skilled flight crew and a lot of luck. The most disappointing story of the year is a toss up. It may be the mid-air collision between a Piper and a sightseeing helicopter over that same river where a contributing factor, and I'm going to be really blunt, was a tower controller who appeared more interested in talking on the phone about a dead cat than controlling aircraft. Or it could be the crash of a Colgan Air Dash 8 by a relatively inexperienced flight crew, both of whom were sick and tired and where a contributing factor was (and continues to be) a culture of denial about crew duty hours, rest requirements and miserably low pay.

Numerous cockpit devices were created and released in the last 10 years, some of them good, some not-so-good. The only unanswered question is "How did pilots and aircraft ever manage to fly without at least one iPhone on board loaded with a bevy of aviation apps?"

The most over-reported and over-hyped story would have to be NextGen, the FAA's answer to everything from airport delays to restless leg syndrome. There are a lot of problems that NextGen could address: Improved ATC services in remote areas, greater emphasis on satellite-based navigation, better handling of flight plans and direct routings, and enhanced collision avoidance. The hype surrounding NextGen include claims that it will solve airport delays at major hubs. It won't and if you want a really cogent explanation of why it won't, go read this series from the WWVB blog. And no, NextGen will not replace "antiquated" radar and from a national security perspective, there's no way we'd want to get rid of radar, thank you very much. As to why NextGen receives so much ink, look no further than the former head of the FAA, Marion Blakey, who has moved to greener pastures ... representing the very industry that is trying to get contracts to implement NextGen.

The terrorist attacks of September 11, 2001 were related to aviation, but only in that they exploited passenger airline security flaws. There were certainly ramifications for GA and there continue to be, but issues surrounding national security ... er ... I mean Homeland Security are more far-reaching than just a private pilot's $100 hamburger privileges. What followed those attacks was intensified airport security procedures, some of which actually added some security value. A lot of the screening procedures came to be known as "Security Theater: A DHS/TSA production."

Flight instruction, particularly for foreign nationals, became more tightly regulated with flight instructors being conscripted as unpaid border guards. Airline passengers began disrobing to varying degrees and checked bags were randomly searched. I didn't travel by airline much in the last decade, but when I did I often opened my checked bag only to find a little calling card left by the TSA explaining why they'd searched my belongings. But no chocolate mint!

Returning from San Juan, Puerto Rico, after completing a ferry flight to the Caribbean, I had my first experience passing through one of the new bomb-sniffing detectors. Before entering the machine, which looks like a futuristic telephone booth, I was admonished to keep my shoes on. After exiting the machine, still somewhat dazed by being blasted by a fast sequence of air "puffs," I was admonished to remove my shoes. Reminds me of a line from the old Woody Allen movie Bananas:

... all citizens will be required to change their underwear every half-hour. Underwear will be worn on the outside so we can check.

There has yet to be another successful attack using airliners but there have been two notable attempts. Richard Reed tried to light off an explosive device concealed in the sole of one of the athletic shoes he was wearing and the talking heads just couldn't seem to believe it. They all continued to repeat one phrase with head-shaking, wide-eyed astonishment; " ... in his shoe!" until he became known as the Shoe Bomber.

The packaging of news is crucial because it distracts us from important details, like those behind latest airline bombing attempt. Maybe it's just me, but this reads like something out of a Keystone Kops script: 1) The alleged perpetrator's father notified the US that he believed his son was a threat, 2) The US Department of State didn't revoke guy's visa but put him on a list that wouldn't have allowed him to renew his visa, 3) The guy shows up at Schiphol with a one-way ticket and no baggage. And that's just what we know of that went wrong. Instead of talking about those issues, let's discuss the really important stuff: Should he be called the Underpants Bomber or the Nut Cracker?

The biggest story of the last 10 years, the one with the farthest reaching implications has to be the modernization of Flight Service. It's hard to remember what Flight Service was like before Lockheed-Martin took over. Many new pilots don't know that just a few years ago there used to be 58 Flight Service Stations throughout the US. Once LM took over, those functions were privatized and modernized. In the first year and a half, LM closed 20 of those stations which resulted in hundreds of FFS specialists being "relocated" or just plain fired. If that weren't bad enough, what ensued can only be described as a $#!+ storm:

Pilots waiting on hold, calls not answered or dropped, briefers not familiar with the local area and the subtleties of the local weather patterns where the callers were based. I would be remiss if I didn't point out that AOPA came out in favor of LM's modernization efforts, presumably as a way to forestall user fees, and had to eat a significant amount of crow when their membership realized they'd been sold up the river.

With 38 of the original 58 stations remaining, LM did eventually clean up their act. Things gradually got better, calls got through, hold times were reduced, but the actual level of service never returned to what it had been: Pilots learned they had to spell out VORs, intersections and even airport identifiers to briefers, but the march toward modernization didn't stop. In the months that ensued, LM closed even more flight service stations, reducing the number to 18, then 13. Now LM has announced plans to close seven more stations leaving six stations out of the original 58 and the loss of another 160 or so jobs.

With a 90% reduction in flight service stations and probably a similar number of staff cuts (I don't know the exact numbers), pilots found other ways to get briefings and file flight plans. For a while, LM's FSS site gave the distinct impression that they were going to implement an online service where pilots could get briefings, file flight plans, and close flight plans. Then, just as mysteriously, those plans fell by the wayside and now the website simply provides information on selected topics, provides some PR-generated rah-rah phrases, and gives pilots a way to provide feedback on LMs level of service.

During the first year of LM running FSS I recall several times I sat on a remote freight ramp, with FSS as my only official link for getting weather information. The problem was I frequently couldn't get through to file a flight plan or get a briefing. Some say that those days are behind us and to an extent they are right: Pilots can generally get through by phone to get a briefing and file, open, or close a flight plan. Trying to raise FSS by radio while on the ground or in the air is still proving problematic in some areas. Should the weather be worse than expected at your destination, Flight Watch can tell you while you are still en route, but they don't accept new flight plans - you have to call a Flight Service Station to do that. And if pilots can't contact FSS by radio, they have no choice but to throw themselves on the mercy of the ARTCC or TRACON controllers and ask for a pop-up IFR clearance. Understandably, many controllers are not thrilled with the prospect of having to provide a function that FSS used to provide. Another alternative would be to always file an IFR flight plan and always pick up a clearance, but that's seldom the most fuel-efficient way to fly.

LM just announced that even more closures are needed because of a 13% reduction in call volume. Hello? When you decimate a service, give it a black eye by firing a talented and trained work force, and take away most of the value-added features, pilots will find other ways to get the information they need. In my personal experience, the majority of pilots are getting their weather briefings online using a desktop computer, laptop, or smart phone. I still teach student pilots how to contact FSS by phone and by radio, but I tend to emphasize online briefings because it saves time and provides more value-added features than talking to FSS. There are several ways to to get online briefings and some sources provide complete, QCIP-approved briefings that meet the requirements of 14 CFR 91.103. Others online sources, while not official briefings because they do not provide NOTAMs or TFR information, are nevertheless quite useful.

The shift to on-line briefing might sound like progress, but much has been lost. The idea of having someone read you a description of the weather never seemed that efficient, but there were advantages to talking to a real person who had local expertise. Student pilots and less experienced pilots no longer have a local briefer who can give them the official weather, then use their years of experience with local weather patterns to help the pilot read between the lines. More responsibility is being placed on the individual pilot and without much weather experience, some pilots will make mistakes. They may interpret the online briefing incorrectly, their knowledge of weather may be incomplete, they may get an incomplete briefing, or the forecast may be turn out to just be plain wrong. With weather being one of the primary causes of GA accidents, the result could be more weather-related crashes and incidents. But rest assured that LMs balance sheet is safe and they continue to meet their performance goals ... rah, rah, rah!

So there you have my round-up of some of the important events of the last ten years. You may have your own list of high and low points, so let me just add that if you'd like to hear my holiday greeting, please press 1 ... All joking aside, I'd like to express my appreciation to all my loyal readers out there and wish everyone a Happy, Prosperous, Safe, and Fun-filled New Year.

The Big Sky

On August 8, 2009, at 11:53 a.m. EDT, a Eurocopter AS 350 BA (N401LH) operated by Liberty Helicopters and a Piper PA-32R- 300 (N71MC) operated by a private pilot, collided in midair over the Hudson River near Hoboken, New Jersey. The certificated commercial pilot and five passengers onboard the helicopter were killed. The certificated private pilot and two passengers onboard the airplane were also killed. Visual meteorological conditions prevailed and no flight plans were filed for either flight. The local sightseeing helicopter flight was conducted under the provisions of 14 Code of Federal Regulations Part 136. The personal airplane flight was conducted under the provisions of 14 Code of Federal Regulations Part 91.

Following this very prominent midair collision, the media have been talking about procedures, policies, and regulations with which most reporters have little experience or expertise. This is nothing new. Every time I read a news story on a topic about which I'm not familiar, I wonder how accurate that story really is. But I digress ...

One news report seemed to imply that the pilot of the Piper (being a private plane) was at fault because it had run into the Eurocopter. The author of another story focused on the shocking fact that aircraft operating in the thin sliver of airspace over the Hudson River do so without talking to air traffic control and without a flight plan. Other reports tried to compare and contrast the water ditching of a US Airways Airbus with this accident. This compels me to comment on what is known about this accident, provide a pilot's perspective on operating in airspace that has little or no ATC intervention, and talk about just how well the see-and-avoid approach to preventing midair collisions really works. I'll attempt to address these issues so that non-pilots can develop a better understanding of just what pilots of smaller aircraft who fly at lower altitudes have to deal with on a regular basis.

Apples and Oranges
First off, the only thing this midair accident has in common with the ditching of US Airways Flight 1549 is that in both cases, the aircraft ended up in the Hudson River. The US Airways accident involved a bird strike (which I guess is kind of like a midair collision) that resulted in a loss of power to both engines: The Airbus was still be flyable, it just didn't have any thrust to keep it from losing altitude. The fact that the plane was still flyable, combined with the skilled flight crew and a lot of luck, resulted in an amazingly successful water ditching. In contrast, the midair collision between the Piper and the Eurocopter caused catastrophic damage, both aircraft departed controlled flight, and the impact with the water was not survivable. The only thing these two accidents had in common was their location.

ATC's Role
The Piper departed Teterboro Airport and was, in fact, communicating with the tower controller until he was over the Hudson, when he was handed off to the Newark control tower. Talking to an airport's tower controller is mandatory when an aircraft is within that airport's airspace. In these situations, ATC will point out other potentially conflicting air traffic, but this is done on a workload permitting basis. Here's just a bit of what the Aeronautical Information Manual has to say on the subject:

4-1-15. Radar Traffic Information Service

This is a service provided by radar ATC facilities. Pilots receiving this service are advised of any radar target observed on the radar display which may be in such proximity to the position of their aircraft or its intended route of flight that it warrants their attention. This service is not intended to relieve the pilot of the responsibility for continual vigilance to see and avoid other aircraft ...

Many factors, such as limitations of the radar, volume of traffic, controller workload and communications frequency congestion, could prevent the controller from providing this service. Controllers possess complete discretion for determining whether they are able to provide or continue to provide this service in a specific case. The controller's reason against providing or continuing to provide the service in a particular case is not subject to question nor need it be communicated to the pilot. In other words, the provision of this service is entirely dependent upon whether controllers believe they are in a position to provide it.

Some questions have arisen about the Teterboro Tower's handling of the flight. Reportedly the controller was making a "non-business" phone call to the Newark tower which may have contributed to coordination problems with the handoff of the Piper from Tereboro to Newark. A conflict alert indication was shown on the radar displays at both towers as the Piper and the Eurocopter began to converge. Though these alerts usually produce both a visual and audio warning, neither controller recalled seeing or hearing the alert.

Several initial news reports made a big deal of the fact that the Piper's pilot never contacted the Newark tower after being handed off by the Teterboro tower. It's hard to know why that was, but it's also important to point out that a delay checking in after a handoff is quite common. Radio communication in aircraft is somewhat primitive - only one person can talk at a time. Perhaps the Piper's pilot was busy tuning his radio to the new frequency so he could check in, but we don't really know. It does appear that the frequency change came at a very inopportune time and the collision occurred shortly afterward. Remember all those studies that show distractions (like cell phone use while driving) reduce reaction time and situational awareness? The same thing can happen in aircraft and, apparently, in control towers.

Different Frequencies
Aircraft operating over the Hudson usually communicate using a CTAF - common traffic advisory frequency - which is like a party line where only one person can talk at a time. The CTAF is different from the frequencies used by Teterboro and Newark towers. The idea with the CTAF is that each aircraft announces their position, altitude, and intentions so that other pilots can put together a mental picture of where other traffic might be and avoid them. If this sounds primitive, it is! Yet in areas where there is no ATC service (usually at rural airports) and when there's not too much traffic, the CTAF set-up is pretty workable. The thing is that CTAF areas are usually not swarming with the volume of traffic that is seen on a daily basis over the Hudson River corridor. The important point here is that the Eurocopter was probably monitoring and transmitting on the CTAF while the Piper was monitoring and transmitting on the Teterboro Tower frequency.

Big Sky, Little Planes
This brings up the big sky theory of preventing midair collisions: The sky is big when compared to the size of aircraft, so the probability of a collision is reduced by the simple fact that the sky is so much bigger than the aircraft. This is a good theory if you assume that aircraft are randomly or evenly distributed throughout the big sky. Unfortunately, aircraft tend to congregate around certain locations (like around airports, helipads, and land-based navigation transmitters) like bees around a hive and that dramatically increases the probability of a collision.

The situation over the Hudson River adds another wrinkle since the area of airspace used by the sightseeing helicopters and other light aircraft is underneath and physically constrained by an overlying area of controlled airspace called Class Bravo. Entering Class Bravo requires a clearance from ATC precisely because this airspace was created primarily to keep small, slower aircraft away from larger, faster aircraft. When aircraft are cleared to enter Class B, ATC will guarantee separation between aircraft: This separation is not done on a workload permitting basis, it is guaranteed. This dramatically enhances the safety of aircraft operating in Class B, but ironically creates a thin layer of airspace for the smaller aircraft to share, which makes the Big Sky quite a bit smaller, and increases the probability that these smaller aircraft who are not in Class B will come close to one another.

Invisible Hands
So how about separating aircraft with a controller using radar? Air traffic control (ATC) can and does provide many valuable services to pilots by providing traffic advisories when aircraft get close or appear to be converging, but they are not an invisible hand that holds the aircraft and keeps them completely safe. Just because the pilot or flight crew of an aircraft is talking to a controller does not mean they are immune to mechanical problems, bird strikes, or midair collisions. The idea that ATC keeps aircraft safe, while not entirely a fantasy, is a belief that non-pilots may find comforting. Non-pilots need to remember that it's the pilot that is flying the aircraft and there is no invisible shield provided to aircraft that just happen to be talking to ATC.

Another misconception held by non-pilots has to do with flight plans. The idea that an aircraft is operating with an open flight plan is somehow safer than one operating without a flight plan may or may not be true. There basically are two types of flight plans: Instrument Flight Rules and Visual Flight Rules. Non-pilots need to know that the primary purpose of VFR flight plans is so that the appropriate authorities will be notified if you don't call in and close your flight plan when you arrive. In short, filing VFR flight plan helps ensure that if you crash and no one sees the crash, someone will eventually come looking for you.

Rules, Rules, Rules
Some reporters have claimed that aircraft which are not under ATC control are completely unregulated and not following any rules, but nothing could be further from the truth.

The aircraft that fly in any airspace must meet FAA airworthiness requirements including regular maintenance inspections with specific criteria.

The pilots that fly these aircraft must be certificated (we don't call them licenses in the US, but the media can't get that right either), they must hold a medical certificate, and they must meet recency experience to be able to act as pilot-in-command and to carry passengers.

The airspace in which these aircraft are operated have specific flight visibility and cloud clearance requirements. And there are specific right-of-way rules that pilots follow when they see they are getting too close to one another.

To equate these areas of airspace not under air traffic control to the Wild West is uninformed and stupid.

Technology to the Rescue, sort of

Without radar, isn't there someway that technology can keep two aircraft from trying to occupy the same airspace? It's not as if no one has tried to create technology to do this, but the success has been mixed.

Large aircraft are required to have traffic collision and avoidance systems (TCAS), but even with TCAS these planes can run into one another.

Several similar systems are available for smaller aircraft, but they can be expensive and not every aircraft has them. One system is the FAA's Traffic Information System (TIS) where appropriately configured ground radar facilities upload traffic information to appropriately equipped aircraft. This is a common system in many newer general aviation aircraft, but many ATC radar facilities do not support TIS. Oh, and the FAA is planning to phase out TIS. Yes, you read that correctly. The reason is that another system is supposed to replace TIS, even though virtually no small aircraft out there are currently equipped to support the new system. Call me a curmudgeon, but that sounds about right for the FAA ...

Another system for smaller aircraft (that is also expensive) is an Traffic Advisory System (TAS) that actively interrogates other aircrafts' transponders, just like ATC's radar. These systems can be quite helpful, but with some aircraft (like the Cirrus) there is no way to mute the aural warnings and keep them from barking "Traffic! Traffic!" when you're trying to talk to or listen to ATC.

The last system for small aircraft that I'll mention is a class of portable devices that warn of nearby aircraft and are sometimes referred to as Portable Collision Avoidance Systems (PCAS). These devices are not perfect, but they help pilots have an idea when other aircraft are nearby, even if they don't tell you exactly where those aircraft are. As a side note, I always fly with a PCAS unit.

What's a Pilot to Do?

First, scroll back to the top and watch the YouTube video of the Hudson midair. I know it's scary, heartbreaking, and painful, but watch it nevertheless.

Hopefully that video has you in a mood to listen.

Remember that accident statistics indicate that midair collisions tend to occur on clear, sunny days and usually in the vicinity of airports of navigational transmitting stations.

Keep your head on a swivel when operating in crowded airspace.

Fly at an appropriate VFR altitude for your direction of flight. I see at least one pilot violating this simple safety rule every time I fly.

Avoid distractions, like unnecessary conversations or fiddling with your GPS or MP3 player.

Listen up! Poor radio phraseology and technique not only wastes everyone's time, it can actually threaten your life, the lives of your passengers, the lives of other pilots, and the lives of people on the ground.

If you have a traffic detection device, use it.

If you think this sort of collision can't happen to you, watch the video a few more times.

Bermuda Triangle

Pilots often think the real work surrounding flying begins once they are airborne, probably because taxiing for takeoff or after landing usually doesn't seem very demanding, interesting, or dangerous. Some of my more harrowing moments in airplanes have occurred during ground operations and the years have taught me that planning, organization, and situational awareness on the ground during single pilot operations can be just as critical as when you're airborne.

The FAA, recognizing the importance of safe ground operations, has published AC 91-73A: Part 91 and Part 135 Single-Pilot Procedures During Taxi Operations, which divides single-pilot ground operations into planning, situational awareness, written taxi instructions, radio communication, and finally taxiing itself. It's a pretty good read, especially for seasoned pilots who may have become a little complacent, and it got me thinking of some of the more memorable experiences I've had while I was just taxiing.

Standardization

The AC suggests that pilots use SOPs (standard operating procedures) which should be introduced during initial training, applied during each flight, and evaluated during recurrent training. The problem is that GA pilots whose initial training was accomplished under part 61 often have little exposure to SOPs, other than their instructor's biases and what they see other pilots do. My wife says that dogs mostly learn bad habits from other dogs and the same could be said for pilots, so here are some recommended practices for single pilot ground operations.

• Get a briefing and check for NOTAMs
• Write down taxi instructions
• Have the airport diagram out and refer to it
• Avoid distractions during taxi, like programming the GPS
• If reading a checklist, hold it up so your peripheral vision is outside
• If confused about your taxi clearance, get clarification
• Don't be bashful about asking for progressive taxi instructions
• Expect the unexpected at non-towered airports, even on the ground

Have a Plan

Before calling for taxi, especially at an unfamiliar airport, it's good to review the airport diagram and mark any NOTAMs for taxiway or runway closures or other changes. Listen to the surface weather (ATIS, ASOS, or AWOS) to determine which runways are in use and look at the airport diagram and estimate the best route to the departure runway. That way when you get your taxi clearance, you'll more likely actually understand it. Jeppesen, for their part, marks hot spots on their airport diagrams and even includes some description of why the areas require special attention.

At larger towered airports, the airport diagram will list all the various clearance delivery, ground, and tower frequencies that you'll need to use. If I had a dollar for every time a pilot asked me what a particular frequency was, I might be sitting on a warm beach, sipping a cool beverage.

Becoming a Literate Pilot

As pilots gain experience I've noticed that many tend to skip the step of writing down the taxi instructions they receive, mistakenly thinking that this is what experienced pilots do. Writing down taxi clearances is easy, especially if you always do it as part of your own personal SOPs.

One morning I called for taxi and got a much more complicated clearance than I had expected. I was used to hearing "taxi runway 28 left via Alpha" but instead was given "taxi 28 left via Delta, Zulu, and Zulu One, hold short 28 right."

A recent change to ATC procedures requires ground controllers to specify the taxiways leading to your departure runway. I heard a pilot recently ask a controller if they had to read back the route, as if it were really that much trouble to do so. I often marvel at how some pilots expend considerable energy in seeing how much they can get away without doing rather than just doing what they know they should.

Be careful that you don't mistakenly hear, write, and read-back the taxi clearance you expect to get. If you read back the incorrect clearance, the controller may not catch your error, hearing what they expected you to say (sometimes called a hear-back error).

Mental Picture

Referring to your airport diagram during taxi can help keep you from making a wrong turn, but it's not foolproof. And don't rely on the ground controller to keep you out of trouble, as witnessed by this takeoff accident where a combination of factors led to the crew taking off on the wrong runway with disastrous results.

I've learned to be especially alert when I hear one controller working both the tower and ground frequencies, which is routinely done at my home airport later in the evening. While I understand that staffing considerations may drive these practices, it carries additional risks for pilots operating on the ground.

One night I called for taxi from the fuel island to parking. I received and read back my clearance. As I began taxiing, I noticed a Lear rolling out on the runway adjacent to my taxiway, both of us approaching a particularly confusing intersection of taxiways locally known as "The Bermuda Triangle." As the Lear taxied off the runway, I heard only the tower's side of the conversation as he was working both tower and ground while the Lear crew was still on the tower frequency. Keep in mind that the Lear and I were the only two aircraft on the field.

I heard the tower say "Lear 123, taxi to parking." After a pause, I heard the tower say "You can take either route" and I knew it wasn't good. Sure enough, the Lear crew chose the route that brought them straight at me - at a high rate of speed I might add. The controller had not said a word to either of us about the other. Sensing a collision was imminent, I turned on my strobes, added power, and sped past just as the Lear's wingtip missed the end of my plane by what I estimate was less than 10 feet. There wasn't any time to say anything on frequency and since the Lear was still on tower and I was on ground, it wouldn't have helped anyway. I have no idea if the Lear crew even saw me.

Eyes Peeled

Several years ago another pilot and I narrowly avoided being hit by another aircraft while doing our engine run-up. The preflight and taxi had been uneventful, but during the engine runup we noticed an anomaly in one of the cylinder head temperature indications. This led us to stay in the runup area longer than usual as we tried to figure out what was causing the high reading. The longer the engine ran, the more the cylinder head temperatures normalized. To fly or not to fly?

We had just resolved to stay in the pattern and watch the engine closely when I caught a glimpse of the aircraft that was headed straight for us. It was a home-built, tailwheel aircraft and I found myself asking aloud "Why is he taxiing so damn fast?" followed by "Jesus, he's not going to stop!" I was certain he would hit us, but at the last moment he jammed on his brakes. This raised the tail of his plane into the air, buried his prop in the pavement, and his craft slid to a stop on it's nose just short of our propeller. We told the ground controller we'd had a near collision in the runup area, that we'd be exiting our aircraft, and that we'd remain clear of the taxiway. The other pilot apologized and confessed he was headed into the sun and hadn't see us.

Speak Up

If you see a conflict unfolding that the ground controller is not aware of, it's critical to say something on the frequency. I frequently see pilots seem to just freeze in these circumstances and wonder why this is so. Perhaps it's because pilots feel intimidated by controllers or mistakenly believe they must always follow their instructions, even if those instructions are going to put their aircraft in harm's way.

Taxiing out for takeoff a few weeks ago, I heard a Gulfstream call for taxi, too. We got our clearance, joined the taxiway and headed to the run-up area. The Gulfstream got their clearance to the South Field and ended up behind us, taxiing in the same direction. That's when we heard a 727 taxiing from the South Field switch to the North Ground frequency. The 727 was ultimately going to be headed in the opposite direction. I knew there was time for us to get into the run-up area and get out of the way, but the ground controller now had a conflict between the Gulfstream and the 727. The controller ended up having the Gulfstream do a 180 degree turn on the taxiway, then taxi onto an adjacent runway so the 727 could pass. And I was glad that we had gotten our little plane well downwind of all the jet blast!

On another occasion, I was taxiing with a student to a local FBO's ramp as a Global Express on the same ramp called for taxi. Ground told him to wait and pass behind us, but I didn't like how that was going to unfold: We'd end up parked right where his jet blast was going to be as he powered up to taxi out. So I suggested to ground that we hold our position on the taxiway a hundred or so yards away and let the bigger guy taxi out, which worked out to be a much better solution for everyone.

Approach Briefing

When you brief your approach to an airport, don't forget to think about where you're going to head once you're clear of the runway. This is a good time to get your airport diagram ready and review what your desired taxi route will be. Don't forget to consider any NOTAMs included on the ATIS you recorded. You did listen to the entire ATIS, right?

Post-Flight & Good Night

You can make your ground operations safer by developing your own SOPs, writing down your taxi clearances, having the appropriate charts available, and thinking ahead. And if something doesn't look right, speak up. You just might prevent some bent metal, cracked composite, or worse.

The Wrong Stuff

Tuesday's NTSB hearing on the crash of Colgan Air flight 3407 is getting a lot of coverage and for a balanced technical assessment, I recommend you read a post by Sam. Sam is currently an RJ captain for a regional airline and a former Dash 8 first officer. I've never flown for a regional passenger airline and I have no flight time in the Dash 8, but I did a stint flying cargo under part 135. I have some experience with the duty time regulations, the economic stress that regional pilots face, and the effect this has on a pilot's performance. My conclusion is that pilots, the airlines, the government, and the flying public are all complicit in the current state of affairs at the regional airlines. I'll warn you in advance that I'm going to say things that you might find controversial, so suck it up! This is the blogosphere and we don't always have to walk lockstep or hold hands and sing Kumbaya.

Pilots who attempt to earn a living flying are addicts, myself included. Okay, maybe our obsession with flying is more a psychological dependency than addiction, but consider the parallels. No matter how bad the working conditions, how low the pay, how miserable the management, how poorly maintained the aircraft, how isolated the lifestyle, pilots will do almost anything for the opportunity to fly. For some of us, the rush starts once the cabin door is closed. For others, it's when the engines start. Even if you are a jaded veteran with thousands of hours, you're not immune to the feeling of the wheels leaving the runway. Once airborne, the troubles fade away and for those many minutes or hours, you're flying again.

Perhaps flying hooks up our brains with a supply of dopamine, but whatever the mechanism it sure drives pilots to make some kooky choices. These talented, intelligent, and highly-skilled professionals seem to blithely accept low pay, early mornings, late nights, long duty days, bad weather, working on holidays, isolation from family and friends, and even AIDS - Aviation-Induced Divorce Syndrome. It's obvious that denial (or at least compartmentalization) is a crucial skill for professional pilots. It's no secret that many pilots will practically fly for free and, in the process, subsidize their airline's operation. And their employers know it.

Management at regional airlines are trying make a profit in a business with lot of variable costs (like fuel) and uncertainties (like weather delays). Where better to start than by keeping wages low? Low wages were the primary reason I quit flying freight. Sure there were the stresses and risks with single-pilot operations, having to fly through bad weather rather than fly on top of it, and the long hours. Then I came to realize that I could earn at least twice as much as a freelance flight instructor than I could as a part 135 pilot, even if I hung on and racked up several years of seniority. And yet I still miss it! You see, pilots love what they do so much that they have a really hard time being objective about what might be wrong in their work environment.

The pilots who fly for regional airlines, especially the low-seniority first officers, are under some serious stress. Stress is a huge risk factor in aviation safety because it narrows the perceptual field and reduces a pilot's ability to perform. Fatigue, which often goes hand-in-hand with stress, increases reaction time and impairs decision making. I've read how the young woman first officer on Colgan Flight 3407 earned so little that she lived with her parents, sometimes held a second job, and commuted across the country to her flying job. She often slept on the crew lounge sofa, I'm assuming because she couldn't afford or didn't want a hotel room. Part of the legendary mystique of being a professional pilot is paying your dues, though once you've slept on a crew couch a few times the allure wears off pretty quickly.

Pilot's are generally goal-oriented and have a predisposition to a perform no matter what. If you call in sick or fatigued, it seems there's always another motivated pilot (addict) just waiting to take your place, maybe even your job. Yet the replacement pilot might be just as fatigued and stressed as you. How much stress and fatigue you're willing to endure depends on your age, your goals in life, and how badly you need your flying fix. Airline management knows all of this and they use it to their advantage.

As convenient as it would be to lay all of the responsibility at the feet of the regional airline management, let's not forget the role of the flying public. People want, no they expect to be able to fly to most any part of the country as cheaply as possible. They don't want to be troubled with knowledge of how the aviation sausage is made, they just want a low price. People will pay $35 to get a package shipped overnight all the while complaining mightily about the airfare involved in shipping their own carcass across the country in air conditioned, pressurized comfort. And many passengers seem to still believe that pilots work just a few days a week, earn upwards of $100,000 a year, and live a country club lifestyle. The fact is that most regional pilots are living hand-to-mouth and don't even get a cost-of-living adjustment for expensive pilot bases like Boston or San Francisco. Low airfares certainly don't help their cause. Greater public awareness of the poor wages earned by regional pilots and cabin crews could be one of the few good things to come from this accident.

The federal government's role is their continued failure to adequately address the twin safety issues of stress and fatigue. Well not all of the government: The NTSB has been pushing for years for an overhaul of the federal duty time regulations for flight and cabin crew members while the FAA and the airline industry have fiercely resisted change. As it stands, flight crews can be on duty for 16 hours or more each day and the 8 hours of rest they must get every 24 hours often does not take into account the time it takes to get to the hotel, eat, and take care of personal affairs. Consider the research conducted at Boston's Harvard Medical School which showed that being awake for 24 hours was equivalent to a blood alcohol level of 0.10% . Getting 5 hours of sleep per night for a week had the same effect. The press has a field day when crew members are found to be drunk on the job, as well they should. By and large, fatigue seems to be tacitly ignored.

Given their work environment, it's hard to expect pilots to be objective about the stress and fatigue they face. Airlines are trying to make a profit in a very difficult business with strong price pressure, so when it comes to fatigue they probably don't ask and pilots probably won't tell. The government has dropped the ball with regard to ensuring reasonable duty limits and reasonable rest time. The press may have found a convenient scapegoat in the form of the flight's low-time captain and the allegedly incomplete simulator training he received. Sure it's difficult to identify all the causal factors that led to a fiery crash on that snowy night, but low wages, stress and fatigue must be examined as contributing factors to this accident and the crew's ineffective performance. Or we could just continue to deny there's a problem ...

Broken Circle

On January 3, 2009 at 1710 mountain standard time (MST) a Learjet 45, N279AJ, sustained substantial damage when attempting to land during a snowstorm at Telluride Regional Airport (KTEX), Telluride, CO. The airplane was owned by LJ279, LLC, Missoula, MT and operated by Aero Jet Services, Scottsdale, AZ. The CFR 49 Part 91 positioning flight was conducted using instrument flight rules and had departed Scottsdale Airport (KSDL), Scottsdale, AZ at 1503 MST. The pilot occupying the left seat was not injured and the pilot occupying the right seat received minor injuries. Both pilots were able to exit the airplane unassisted.

The circle-to-land maneuver is one of the more risky activities that you may do under instrument flight rules, second only to the contact approach. Many freight operators manage these risks by prohibiting their pilots from executing circle-to-land maneuvers at night and most part 121 operators prohibit circling approaches altogether. To understand why a circling approach is potentially more dangerous than a straight-in approach, you need to understand why these minima exist and the challenges that pilots face when executing the circle-to-land maneuver.

Examine the Circular File
One of several situations that require a circle-to-land maneuver is when an approach procedure's final approach course is more than 30˚ out of alignment with any runway at the airport (15˚ for GPS approaches). In these cases, no straight-in approach minima will be published, the approach name will use a letter (starting from the beginning of the alphabet) instead of a specific runway, and the pilot must adhere to the circling minima. This approach into Hanford, California has a final approach segment that is at a right angle to both runways, so you may have no choice but to enter a modified traffic pattern and circle to land on either runway 32 or 14. If you acquire the necessary visual references early enough, nothing in the regulations prevents you from maneuvering early for a straight-in landing.



The NDB or GPS-A approach to Lakeport terminates at the NDB (which has been out of service for almost as long as I can remember) and the pilot must fly visually to the airport, provided they have the necessary visibility and high enough cloud ceiling. It is important to realize that if you begin flying a visual segment like this, then lose visual references and decide to execute the missed approach, it's likely you won't have the normal 40:1 obstruction clearance that you would if you began the missed approach at the missed approach point. Anytime you elect to fly the missed approach, you best climb like a striped monkey (i.e. at your aircraft's best rate of climb) until you reach a safe altitude.



Many pilots don't know or never learned that circling minima will also be provided when the descent gradient from the final approach fix to the runway threshold exceeds 400 feet per nautical mile, even when the final approach course is aligned with the runway. The reason is simple: You may arrive at the missed approach point, visually acquire the runway, yet be too hight to execute a landing using normal maneuvers. This is exactly what happened to the accident flight crew.

One of my favorite examples is the Gillespie LOC-D approach. The localizer is aligned with the runway, but no straight-in minima are published due to terrain and obstructions.


Finally, circling minima are often published in addition to straight-in minima. The circling minima, which are usually higher, allow the pilot to descend on the approach and, once they have the necessary visual references and are at or above the circling minima, maneuver to land on a different runway. This can be advantageous if the surface winds are favoring a different runway for which there is no instrument approach.

The Telluride LOC/DME RWY 9 approach has both straight-in and circling minima, but unlike most approaches, the straight-in minima and the circling minima are the same. I don't know if this is the approach that the accident flight crew was flying, but it likely was because the localizer offers the lowest minima of any of the approaches into that airport.



Manage the Risks
NACO instrument approach charts provide an inset map that shows the airport runway layout, relevant obstructions, and the final approach course relative to the runways. If you are using Jepp charts, you'll need to have the airport diagram out and at the ready, but that diagram won't show the approach course relative to the runways.

On reason the circle-to-land maneuver is more risky is that the pilot must transition from flying on instruments to flying by visual references and then begin maneuvering in a modified traffic pattern fashion. Throw in poor visibility, high surface winds, or night conditions and you've got yourself a real handful. Often the circling MDA is lower than the normal VFR traffic pattern and the obstruction clearance while circling in the protected area is a mere 300 feet, which means it can be really easy to run into something. The size of protected area for circling depends on the aircraft's approach speed, and generally speaking, the larger the aircraft, the faster the approach speed.

• Category A is for aircraft flying at 90 knots or less
• B: 91 - 120 knots
• C: 121 to-140 knots
• D: 141 - 166 knots
• E: 167 knots and above

The diagram shows an idealized runway environment. Many instrument approaches contain a notice that the circling is not allowed in certain areas around the airport, due to obstructions. And some approaches specify that circling is not authorized at night. The Telluride approach is a good example of both. But of greater interest is that the approach speed of a Lear 45 may have required category C minima, which are not authorized on this approach.

In a statement provided by the Pilot-In-Command (PIC), upon arrival to KTEX the weather was reported to be below minimums; the crew elected to hold over the Cones VOR and wait to see if weather conditions would improve. The crew was given instructions, by air traffic control, to hold as published and to expect further clearance (EFC) at 1630. When the weather improved to a visibility of 4 miles and a ceiling of 2300 feet, the PIC requested a descent and approach to KTEX. At approximately 4 miles from the airport, the pilot acquired the airport environment but was not in position to land, so he called for a missed approach back to Cones VOR.

If your destination airport is reporting conditions below minima, you are not prohibited under part 91 from attempting the approach. The accident aircraft was reportedly being repositioned under part 91, but the crew elected to adhere to part 135 and 121 requirements of not beginning the approach unless landing minima were being reported at the surface. They even waited until the weather improved to considerably better than the circling minima and they had a plan B, too. But things went South from there.

The pilot then requested a second attempt to land stating that "if we did not land, we would like to be sequenced to into KMTJ" Montrose Regional Airport Montrose, CO, their alternate airport. On the second approach, both crew members stated that they had acquired the runway environment; however, they were still too high for a visual approach. The crew elected to do a 360-degree, right, descending turn, in order to get in a better position for landing. On completion of the turn, they again affirmed the runway environment and that they were aligned with the extended centerline of the runway. The airplane touched down and after full thrust reversers were deployed, the nose gear collapsed. The airplane began to slide in snow and came to a stop about mid-field, in an upright position.

Let the Circle Be Unbroken

The preliminary accident reports stated that the accident aircraft actually failed to touch down on the runway, which is curious given that the localizer appears fairly well aligned with the runway centerline. Did the crew become distracted or disoriented by the poor visibility and blowing snow?

An on-scene investigation was conducted by a Federal Aviation Administration (FAA) inspector. The initial examination of the area indicated that the airplane had touched down about 20-feet to the right, of the runway. Additionally, the airplane's wings were torn from the fuselage and the tail section had separated just aft of the engines, during the contact with the ground.

...

Weather reported at KTEX 10 minutes prior to the accident was winds 260 degrees at 8 knots, visibility of 3 miles, scattered clouds at 400 feet, broken clouds at 2300 feet, temperature of 6 degrees Celsius, dew point of 6 degrees Celsius, and altimeter setting 29.85 inches of mercury.

Should you need to fly a circling approach, turn up the sensitivity on your spidey senses and consider some techniques that may prevent you from becoming an accident statistic.

If the surface winds are not aligned with the straight-in runway, you probably have a tailwind on the approach. Monitor your groundspeed carefully and consider configuring gear and flaps as necessary to control your groundspeed. Be prepared for a faster than normal speed when you break out and acquire visual references.

Slowing down will also aid you in the circling maneuver since a slower speed will give you a higher rate of turn and a smaller radius of turn with a shallower bank angle.

If the surface winds are high and you'll need to circle, you may want to go to your alternate. Even if the ceiling and visibility are above circling minima, high winds may just ruin your day.

Should you lose visual references while circling, don't kid yourself; it's time to get out of Dodge. Begin climbing, remaining in the protected circling area if necessary, and execute the missed approach ASAP.

Use the VASI and PAPI. If you stay on or above the glide path and within 10˚ of the centerline, you'll be guaranteed obstruction clearance within 4 miles of the threshold.

If ATC gives you advance notice of a need to circle, it will sound something like this:

Barnburner 123 is two miles from Mooselips, fly heading 230, maintain 3000 until established, cleared for the ILS 25, circle runway 7.

When landing at a towered airport, expect the controller to give you a cardinal direction to turn, such as:

Barnburner 123, at minimums, circle south, enter left traffic, runway 9.

Here is an illustration of various ways that a circling maneuver might be conducted, but keep in mind any circling restrictions at your particular destination.

If you have to fly the missed approach once, you may well be better off going to your alternate rather than risking a second approach. The risks of attempting multiple approaches to the same airport are subtle, but very real.

Circle-to-land maneuvers must be demonstrated on an instrument rating practical test and on an instrument proficiency check, so instrument-rated GA pilots should be familiar and proficient with the maneuver. But if the need arises for you to circle-to-land on a real-world instrument approach, be aware that you're doing something that entails more risk than a straight-in approach and landing. Like the accident flight crew, you may be better off executing Plan B and going to your alternate.

Caution: Bird Activity

Bird strikes became newsworthy recently with the dramatic ditching of US Airways Flight 1549 in January of this year after multiple bird strikes caused both engines to fail. Now the FAA wants to keep the raw data on bird strikes "confidential" (read "secret"). The justification being offered seems tenuous, at best. Here are some quotes from the Notice of Proposed Rulemaking, which the public may comment on until April 20, 2009.

The Agency is concerned that there is a serious potential that information related to bird strikes will not be submitted because of fear that the disclosure of raw data could unfairly cast unfounded aspersions on the submitter.

When it comes to safety issues, knowledge is power, except apparently when that knowledge might scare airline passengers away from particular airports or airlines.

The complexity of the information warrants care with its interpretation; releasing this information without benefit of proper analysis would not only produce an inaccurate perception of the individual airports and airlines but also inaccurate and inappropriate comparisons between airports/airlines.

Apparently our public servants think it's okay to make public some scary data, but other sorts of sorts of scary data must be kept secret; the sort of scary data that might adversely affect commerce. If third parties, including the news media, want to access the raw data to provide their own analysis, I think that's a good thing. The FAA seems to be saying that they, and they alone, know how to interpret raw data which I find unbelievably arrogant. Considering the agency's past performance on a variety of issues (aircraft safety inspections, management of air traffic control, etc.), two things are clear: They think they know best and they have the ability to screw up an anvil.

Whatever you think, you have until April 20 to comment by fax (202–493–2251), or by mail at:

U.S. Department of Transportation
Docket Operations M–30
West Building Ground Floor
Room W12–140
1200 New Jersey Avenue, SE.
Washington, DC 20590

You can also comment on-line, though I found it to be a bit complicated. Go to this link and search for docket number FAA-2009-0245.



On the next screen, locate and click on the rules link.



On the next screen, click on the comments link and post your feelings about this proposed rule.



Here's some interpreted data on strikes that has been published to date. According to Wildlife Strikes to Civil Aircraft in the United States 1990–2007, the threat of wildlife strikes to aircraft are on the rise due to three factors. First, many wildlife populations have increased and/or have adapted to living in urban areas. Next, there are more aircraft flying - passenger aircraft operations have increased dramatically since 1980. Lastly, more airlines are flying two-engine aircraft as opposed to three or four engine aircraft and fewer engines means less redundancy and less safety.

If you think your odds of hitting a bird or other animal are low, think again. In the 18-year period between 1990 and 2007, over 82,000 animal strikes were reported. Birds accounted for over 97 percent of the encounters, terrestrial mammals for about 2 percent, bats for 0.3 percent, and reptiles for 0.1 percent. Just over half of reported bird strikes occurred between July and October and if you think birds don't fly in the dark, 38 percent of strikes occurred at night. 60 percent of bird strikes occurred at 100 feet above ground or less, 73 percent occurred at 500 feet or less, and 92 percent occurred at or below 3,000 feet. The record altitude for a bird strike? 32,500 feet. 60 percent of the strikes occurred during landing or approach to landing. 37 percent occurred during takeoff and climb-out.

58 percent of terrestrial mammal strikes occurred between July and November. 33 percent of deer strikes occurred between October and November. 64 percent of the terrestrial mammal strikes occurred at night and 89 percent occurred during the takeoff or landing phase.

Now that didn't hurt, did it?

I've had three bird strikes and countless near misses. The first, and most dramatic bird strike happened during a daytime instructional flight at about 400 feet above ground, right after takeoff. The bird was a turkey vulture that I estimate weighed 15 to 18 pounds. The bird hit the leading edge of the right wing, just outboard of the wing strut. The sound of impact was quite loud. I took control of the aircraft, verified all the primary flight controls were functioning, and we returned for landing. After landing we found a three foot portion of the leading edge was significantly deformed, though I didn't notice any change in flight handling or performance after the strike. Our encounter was fairly lucky, for us anyway. Had the turkey vulture struck the windshield, the results would have been much worse. Here's an eagle that collided with a Schweizer helicopter, hitting a passenger in the chest and causing a fractured shoulder.



On several occasions I ferried Caravans to maintenance under a ferry permit after they had been damaged by bird strikes. The Caravan driver's old joke is that if you're going to hit a bird, try to hit a duck or a goose such that you skewer it on one of the two massive pitot masts. That way you can turn the pitot heat on and cook the bird on your way in and have something to eat after you land. Of course, this is just a joke.

If my bird encounters have taught me anything it is to take immediate evasive action anytime I see birds that pose a threat. There is a lot of folklore about how birds can or may get out of your way, when they may dive and when they may climb. Some of this may or may not be true, so the best advice I can offer is don't just sit there and passively expect the birds to get out of your way. If you see birds before or during takeoff, wait or abort the takeoff until the area clears. At a towered airport, tell the tower or ground controller if birds are an issue. Many airports have bird hazing protocols and ground crews may be dispatched to scare the birds away. If you see birds during approach to landing, remember you can always go around. Again, tell the tower about what you've seen since that information can help other pilots who may be following you. Sometimes, like at night, you may not see the birds until it is too late to take any action and you have to hope for the best.

As for terrestrial mammals, I've had my share of near misses with deer, coyotes, foxes, skunks, and stray dogs. Just like birds, you need to take action if you see an animal on or near the runway where you are departing or landing. If you can see the animal, don't assume it will get out of or stay out of your way. When in doubt, aborting a takeoff or executing a go-around is the prudent thing to do.

If you do collide with a bird, remember to report the event after you have safely landed. You can now report these encounters using this on-line form. It's actually a heck of a lot easier to report a bird strike than it is to comment on Notices of Proposed Rulemaking. If you hit a bird and the remains are accessible to you, follow the instructions on the site for sending the remains to the Smithsonian for identification. I've never submitted bird remains. In the case of the turkey vulture collision, the bird fell somewhere into a slough and was "unavailable for comment."

'Chute First ...

I've read with great interest some assertions about Cirrus aircraft, the pilots who fly them, and whether or not the airframe parachute makes the Cirrus pilot safer or just emboldens them to take risks. By now most of you know that on Sunday, March 15, 2009, a 64-year old instrument-rated private pilot flying a new Cirrus SR22 elected to deploy his aircraft's airframe parachute shortly after takeoff from Montgomery County Airport in Gaithersburg, Maryland. He departed runway 34 and his plane came to the ground about a half mile from the airport, no injuries were reported on the ground, the pilot walked away, and the aircraft was substantially damaged. It's dangerous to generalize, but I feel compelled to make some observations about this particular accident, the pilot's decision to launch into the weather, the efficacy of Cirrus door latches, and under what conditions a Cirrus pilot should consider deploying the 'chute.

The pilot involved in this particular accident was reported to have had 320 hours total time and I'm assuming, given his age, that he came to flying later in life. None of the reports I've read give any specific numbers, but given his total time and the fact that his last certificate was issued in June of 2007, it seems reasonable to assume that he didn't have much experience with solo flying in IMC. A low time pilot with a powerful and capable aircraft can be a dangerous, sometimes even deadly combination, and this accident would seem to reinforce that belief. And let's be clear that while this accident happened to involve a Cirrus, most any brand of high-performance aircraft will do.

An important part of instrument training involves making a competent go/no-go decision. Heck, it's explicitly called out in the Instrument Rating PTS as something the candidate must demonstrate. I sat on the ground a few years back with a Cirrus owner while we waited for the weather to clear. The radiation fog was thick and the surface winds were gradually starting to increase and mix out the fog, which made waiting all the more uncomfortable. But wait we did because, parachute or not, the conditions did not meet my minima for departure.

Turn in your hymnals to 14 CFR 91.175 and you'll find specific departure weather restrictions for aircraft operating under 14 CFR 135 and 121. Taking off under conditions with zero visibility and zero ceiling is not expressly forbidden when operating under part 91, but that doesn't mean it's a good idea nor does it mean that if you do so and you run into problems that you won't be scrutinized for violating 14 CFR 91.11 (Careless or reckless operation) - endangering the life or property of another. In our Me First society, it is easy to forget that our actions may indeed have adverse effects on others. This is where an instrument instructor's job of teaching risk management begins.

The accident pilot elected to launch with a reported ceiling of 400 feet and 2 miles visibility. Shown above are the takeoff minima published for Gaithersburg, which don't specify any ceiling or visibility. That means the 14 CFR 91.175 standards of 1 mile visibility for aircraft with two engines or less apply to part 135 and 121 operators. Technically the accident pilot was not prohibited from departing since he was operating under part 91.

The absolute lowest personal departure minima for a single-engine aircraft that I recommend to pilots I train for the instrument rating are pretty simple: The surface weather observation must be equal to or better than the highest circling minima (ceiling and visibility) for the airport, just in case an emergency return is required. In a twin-engine aircraft, I'm still pretty conservative and recommend the conditions be no lower than the highest straight-in minima of all non-precision approaches available at the departure airport.

When I flew freight in the Caravan, my company's procedures allowed us to depart in some really crummy conditions. On several occasions, I departed when the greater Bay Area was blanketed fog and with low IFR conditions at all nearby major airports. And you know what? It gave me the creeps every time I did it.

I've never flown into Gaithersburg, but a quick review of the available approaches show the following circling minima.

GAI NDB RWY 14 - 1 SM vis & 1380 feet MSL, 841 feet Height Above Threshold
GAI VOR RWY 14 - 1 SM & 1200 feet MSL, 677 feet HAT
GAI RNAV (GPS) RWY 14 - 1.5 SM & 1020 feet MSL, 481 feet HAT

In case you're wondering what I'm getting at, the low-time instrument-rated accident pilot took a pretty big risk when he chose to depart with 2 miles visibility and an overcast ceiling of 400 feet at an unfamiliar airport.

I've written before about my experiences with the door latches on a Cirrus SR22 that I used to fly. Quite frankly, I found the performances of these door latches stinks. Cirrus, in an apparent quest to make the aircraft seem as much like an automobile as possible, tried to implement a slam-and-shut-style automobile door. This just in: A high-performance single-engine aircraft is not a car. My experience showed me that the latches on an SR22 G2 must kept adjusted just right by a mechanic and the pilot had best ensure the doors are secured, top and bottom, before taking off. Interesting, the door latches on an older SR20 that I used to fly had a very positive door mechanism with a latching handle.

So a door popping open on a Cirrus is not uncommon and the AFM even has a procedure for handling it - abort the takeoff if you can, otherwise reduce your speed and land as soon as practical. A door popping open can be distracting as hell, especially to a low-time pilot, but the slipstream will keep the door mostly shut. You just need to reduce the airspeed and return to land. Of course, returning to land is going to be a lot easier if you at least have circling minima.

When I flew the Cirrus regularly, I followed all the recommended Cirrus Airframe Parachute System (CAPS) procedures. This included removing the safety pin from the activation handle before takeoff and installing the safety pin after landing. If you don't remove the pin, you simply can't be ready to deploy the parachute quickly in an emergency. I've read of several fatal accidents involving Cirrus where NTSB investigators, combing through the wreckage, found the CAPS safety pin firmly in place on the deployment handle.

Even though I followed the CAPS procedures and I regularly reviewed the deployment procedures, my mindset when flying the SR22 was that CAPS deployment was going to be an absolute last resort. The AFM gives some suggested situations where CAPS deployment is warranted:

• Mid-air Collision
• Structural Failure
• Loss of Control
• Landing in Inhospitable Terrain
• Pilot Incapacitation

After the door opened, the accident pilot reported that his intention was to turn back and land at Gaithersburg. The accident pilot says the plane entered an unusual attitude and he let the airspeed get low, the aircraft stalled and started to enter a spin. The accident pilot said he had pressed the magic button (the autopilot Level button) to get the plane stabilized, but decided he couldn't wait for the magic button to do its magic. He was also concerned about entering restricted airspace nearby and was unfamiliar with the Gaithersburg airport environment. So he pulled the 'chute.

I'm glad he's okay and that no one on the ground was hurt, but this all seems so preventable. Low time pilots in high-performance aircraft with airframe parachute systems can learn a lot from this accident. "'Chute first" is a potentially dangerous and definitely expensive procedure. The hard questions need to be asked and answered on the ground, before the clouds are approaching, the door has opened, or the engine has quit and you feel the urge to pull that T-shaped handle.

Uncertain Conclusions

This post concerns serious business, so I'll start with some levity.

A salesman, a hardware engineer, and a computer programmer were in a company car traveling down a steep mountain road when the car's brakes gave out. Miraculously, the driver was able to bring the car to a stop by turning off the engine and using the emergency brake.

As they piled out of the vehicle to assess the damage the salesman declared, "We should call the company carpool and have them dispatch us a brand new company car."

The hardware engineer shook his head and said, "No, we should take this car apart, find out what went wrong, get new parts, and fix this car."

The programmer rolled his eyes and opined, "No, no, no. We should take this car back up the hill and see if it does it again."

There are limits to inductive reasoning, especially when one tries to draw conclusions based on a very small sample of events. It's easy to draw a conclusion from experience, but that conclusion could be invalid or incomplete, depending on your experience and, among other things, luck. Pilots often receive in-depth training in aircraft systems and that can lead them to believe they can troubleshoot or fix problems in flight, but don't forget an important part of aeronautical decision making: Have a solid respect for what you don't know and avoid making unnecessary and risky assumptions.

Consider the procedure for resetting a popped circuit breaker while flying an aircraft, a practice that is now virtually prohibited in commercial aviation but may still be widely practiced in general aviation aircraft. A related problem involves flying an aircraft with non-essential, inoperative equipment that hasn't been removed or deactivated. The NTSB has concluded that both of these issues likely led to the crash of the Cessna 310 I mentioned in my last post.

Like many things, the FAA's regulations don't make the process of dealing with inoperative equipment a simple matter. There are seven (count 'em!) steps you may need to follow to be legal.

1. Does the aircraft in question have a minimum equipment list (MEL) and, if so, is the thing that's inoperative required on the MEL? If yes, the aircraft is grounded and corrective action is required. If no, then skip to step 6. If your aircraft doesn't have an MEL, then ...
2. Does the thing that's inoperative appear in the aircraft's original equipment list as being required for certification? If yes, the aircraft is grounded and corrective action is required. Otherwise ...
3. Does the thing that's inoperative appear in the aircraft's Kinds Of Operation Equipment List (if the aircraft has one) found in the Limitations Section of the AFM for the planned type of operation? If yes, the aircraft is grounded and corrective action is required. Otherwise ...
4. Is the thing that's inoperative required by 14 CFR 91.205 for the planned type of operation? If yes, the aircraft is grounded and corrective action is required. Otherwise ...
5. Is the thing that's inoperative required by an Airworthiness Directive? If yes, the plane is grounded and corrective action is required. Otherwise ...
6. Do you, as PIC, believe that safety of flight will be adversely affected by the thing that is inoperative? If yes, the aircraft is grounded (see Sam's blog for a great description of a PIC's real life safety-of-flight decision). Otherwise ...
7. Deactivate or remove the thing that is inoperative, placard it as inoperative, make a maintenance log entry describing what you did, and you can now go flying.

An important thing to consider is "When did the thing that is inoperative actually quit working?" Often you'll discover something is broken during your preflight inspection, taxi check, or during the before takeoff checks. If you discover something is broken while in flight, you should tell someone and make a record of the discrepancy after you complete your flight. This discrepancy report (US pilots often call them squawks) should alert the pilot who is scheduled to fly the aircraft next, provided that information is recorded somewhere and communicated to maintenance personnel and the next pilot(s).

The FAA tries to incorporate these maintenance concepts in the various Practical Test Standards under the Emergency Operations and Postflight Procedures areas of operation. In my experience, few GA pilots actually complete a postflight inspection after flying. Heck, with some pilots you're lucy if they remember to tie the plane down, install the gust lock, and so on. Many designated pilot examiners will thoroughly quiz a candidate about required equipment and the handling inoperative equipment, but a lot of pilots seem to forget these procedures as soon as the ink is dry on their temporary airman's certificate. Even the very experienced airline transport pilot involved in the Cessna 310 crash seems to have overlooked the proper procedure for handling inoperative equipment.

A maintenance discrepancy log sheet recovered at the accident site, annotated during the previous day’s flight, described the weather radar display as going “blank” during cruise flight, accompanied by a “smell of electrical components burning. Turned off unit - pulled radar [circuit breaker] - smell went away.” No corrective action was annotated next to the discrepancy write-up, and no evidence was found to indicate that corrective action was taken prior to the mishap flight.

Post accident interviews with company personnel indicated that during a phone conversation the day prior to the accident, the ATP was made aware of the weather radar discrepancy item. A company aircraft mechanic confirmed that the ATP stated that he “didn’t care about the radar” during a telephone conversation on the morning of the accident.

None of the company personnel interviewed remembered seeing either member of the accident flight crew reviewing the airplane discrepancy log prior to departure, but one mechanic did recall that the ATP performed the preflight inspection of the airplane.

The pilots decided to take the plane without thoroughly investigating the squawk about the radar and it appears the circuit breaker that had been pulled was not "collared" by maintenance to prevent it being reset. Resetting the circuit breaker may have caused the Cessna 310's in-flight fire. Here's how.

Older style circuit breakers use a bimetallic, thermal design that responds to the heat generated when a specified electrical load is exceeded. A metal collar holds the circuit closed against the force of a spring contained inside the circuit breaker. Should the collar begin to heat up, it will expand, allowing the spring to open the circuit. This design generally works, but it has two problems.

Old circuit breakers may no longer perform as designed, especially if they have accumulated a coating of dirt, dust, or some sort of spilled contaminant like coffee or soft drinks.

Even if circuit breakers aren't contaminated, an arcing event between wires whose insulation has chaffed away may not generate enough heat at the breaker to cause it to open immediately. Significant arcing damage may occur and significant smoke can be generated before a conventional circuit breaker will trip. Arc-Fault Circuit Breakers are now available which can detect arcing events and immediately open the circuit before significant damage occurs, but you can bet that 70's, 80's or 90's vintage aircraft are probably not equipped with such devices.

According to AC 120-80, most hidden fires are the result of arcing between bundled wires. Uncontaminated wiring insulation is fire resistant, but an arc can easily provide a source of ignition for surrounding insulation materials or even wiring insulation if it has been contaminated with dust/dirt or stray corrosion inhibitors and lubricants. Once a circuit breaker trips, you may very well be confronted by an electrical system in an indeterminate state: The AFM's wiring diagram may no longer apply to your aircraft.

The problem is made worse by the fact that some aircraft designs put circuit breakers in very difficult-to-reach places. The Caravan has numerous rows of circuit breakers located on a panel adjacent to the pilot's left leg, leading some operators put color-coded plastic collars on important circuit breakers to help pilots figure out which circuit has opened. The Cirrus SR20 and SR22 have circuit breakers that are located near the pilots right foot in a location where parallax makes it virtually impossible to accurately read the labels while flying the aircraft. Piper Comanche and Twin Comanche aircraft have circuit breakers behind a trap door on the floor, another illustration of a fundamentally bad design decision.

Did the pilots of that Cessna 310 reset the circuit breaker for the radar equipment that had previously been pulled (but not collared) by the previous pilot? We may never know.

At 08:32:50, shortly after reaching a cruising altitude of 6,000 feet, the flight crew declared an emergency to the Orlando International approach air traffic controller (ATC). The crew advised that there was "smoke in the cockpit," and announced their intention to land at SFB. ATC cleared the airplane to fly directly to SFB and descend to 2,000 feet. Radar data indicated that the accident airplane turned toward SFB and commenced its descent. ATC then cleared the accident crewmembers to “to land any runway." The last radio transmission from the airplane occurred at 08:33:15. It was terminated in mid-sentence and appeared to include the phrase “shutoff all radios, elec.” The last radar return from the accident airplane was at 08:34:50, about 1/2-mile
east of the accident site.

GA pilots can learn a lot from this accident by following a procedure for fires and tripped circuit breakers that the airlines generally follow, as outlined in AC 120-80. First, be aware of the indications of hidden fires:

• Odors of smoke or of hot electrical equipment
• Un-commanded operation of an aircraft system may indicate a hidden fire
• Circuit breakers tripping
• Hot spots on the floor, or behind sidewalls and access panels
• Smoke or visual signs of flames

Should a fire develop, be prepared to follow these steps:

• Fight the fire immediately, be aggressive
• Try to find the base or source of the fire
• Do not reset circuit breakers unless the equipment is required for safe flight
• Plan for an immediate descent and landing at the nearest suitable airport
• Use personal breathing equipment (supplemental oxygen) if available

Be wary if a circuit breaker trips and try to apply all that systems knowledge you learned once you are safely on the ground. Knowing the signs of in-flight fires, how to properly handle inoperative equipment, leaving tripped circuit breakers alone, and being familiar with using fire extinguishers may save your life some day.