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Lots of Campers

I got a bit of a surprise Sunday afternoon when driving by the North 40 camping area at Wittman Field in Oshkosh. The field wasn't quite full to the fence line off the approach end of runway 9 but it was getting there. That's as full as I've seen the campground on a pre-show Sunday in several years and certainly an improvement over last year, when heavy rains rendered the place a sodden wasteland. Using the North 40 as a leading indicator of economic conditions is a great AirVenture sport, but it's probably not a reliable indicator of show attendance.

Still, I'd rather see it full than not. The campers had their usual Vulture's Row of gawkers grading the landings of arriving airplanes. Not to be too harsh, but you can sure see that some pilots don't seem to be to…ummm…very proficient. Some of those landings were quite cringe worthy. I always figured if you're going to fly into OSH with an audience, you'd better bring your A game.

Real People, Real Pain

As that convention of idiots in Washington otherwise known as the 112th Congress continues to play chicken with the world economy, some of those chickens came home to roost here at AirVenture. With the FAA's budget in limbo, some of the more than 4000 agency employees furloughed were involved in the unleaded avgas transition team group. They were scheduled to give a briefing here on Wednesday, but it appears they've called the whole thing off in the absence of FAA staff to oversee it.

And that's only scratching the surface. Probably dozens if not hundreds of certification projects large and small are also stalled, thus costing companies real dollars in delays and probably some of the real jobs the political class flaps its lips about but does nothing to improve. The aviation industry continues to be fragile and this is just another few knots of headwind.

Flight Designs CT4

I've never seen convincing evidence that a low-ball price on airplanes expands the market at the lower end in a sustainable way. The most compelling evidence to the contrary is Eclipse. Its proposed sum-million dollar jet proved to be a headlong slide into bankruptcy.

But here comes Flight Designs with a certified, four-place cruiser it proposes to sell for around $250,000. Why does it think it can do this with Diamond's DA40—a comparable proven and competent airplane—sells for around $350,000? One reason is that it builds airplanes in the Ukraine, where labor rates are lower. But another may be that it hasn't certified a four-place airplane in the current market and is doing what most airplane companies do: underestimating the cost of bringing a new airplane into production.

I wish them the best, but I'd rather see a realistic price that builds in the most important thing any new airplane should have: Good value for the customer and profitability for the company building the airplane. It's never in the customer's interest to have the company losing money on every sale.

Airlines: Sinking to New Lows

Speaking of customers and sticking it to same, how about a nice loud razz for the ever incompetent Congress and at least some airlines. Since Congress can't figure out a way to re-authorize the FAA to operate, it can't, among other things, collect passenger ticket taxes.

Sensing yet another opportunity to abuse customers, some airlines skipped right past giving ticket buyers a break on the tax holiday and just raised their basic fares to the same level, keeping the money for themselves. According to the Associated Press, American and Jet Blue followed this course, reaffirming my faith that American business remains in the grip of money grubbing MBAs.

Run! Run for Your Lives!

Well, okay, maybe just file in an orderly fashion to the exits. That's the idea behind a new emergency notification by text message that EAA has put together. Following the surprise tornado at Sun 'n Fun last spring, the AirVenture staff figured it needed at least a basic framework for emergency notification.

They're doing this through a text message setup. To use it, text OSHALERT to 84444 and you'll get on the list for emergency notifications. For alerts on other activities, text OSHFUN to the same number.

Comments (52)

"some...agency employees furloughed were involved in the unleaded avgas transition team group"

Obviously, those particular individuals should have been let go years ago. An entire industry is waiting and they have had no results to show for 10 years on the job. Results oriented people say that it's no loss to Aviation that they're gone...

Posted by: Mark Fraser | July 26, 2011 7:28 AM    Report this comment

"...as the 112th Congress continues to play chicken with the world economy." "...incompetent Congress..."

Contrary to your skewed worldview, the Senate and White House are in it deep , way over their heads IMHO, as well.

"..reaffirming my faith that American business remains in the grip of money grubbing MBAs."

Your faith? Wow, how about all those foreign owned businesses are they in those MBAs grip too?

Posted by: daniel schultz | July 26, 2011 3:33 PM    Report this comment

The unfunding of FAA due to inattention in congress is a good example of what we will see if (when?) the feds fail to raise the debt ceiling next week.

It is a bit inconvenient, but somehow I think we will all survive without the expected bureaucratic report on the remote possibility that 100 octane unleaded fuel will some day be in the pump at our airports.

Posted by: Paul Mulwitz | July 27, 2011 5:41 AM    Report this comment

Well done Paul. Nice to have someone tell it the way it is!

Posted by: Jeremy Clark | July 27, 2011 6:53 AM    Report this comment

Easy fix to the certification problem. Get the FAA out of the business of certifying aircraft below 12,500lbs. The bureaucracy is just expensive and in the way, and there's no more mystery about how to build a small airplane, than there is about how to build a small boat. Nothing kills an airplane design faster than a few crashes, so both the customer base and the producers are pretty conservative anyway.

On airplane prices, of course lower prices expand the market. That's why airplane companies keep trying to get to lower price points. What you mean to say, Paul, is that you've never seen evidence that anyone knows how to build airplanes at the prices the market keeps asking for. Sad, but true.

Posted by: Thomas Boyle | July 27, 2011 8:02 AM    Report this comment

Just an FYI, the United States Congress consists of both the House and Senate, so maybe Paul was referring to both collectively; however, I agree the WH deserves a big chunk of the blame as well for its total lack of leadership.

Posted by: A Richie | July 27, 2011 9:17 AM    Report this comment

What if the FAA never came back? Could we survive without non-essential FAA employees and rules lighting the way and cluttering the path? Could we survive without unmonitored ELTs or ADS-B that benefits no-one or knowledge tests designed to stump the dummy or class 3 medicals or ramp checks? Gosh, is anarchy in the cockpit far away or could we think for ourselves?

Perhaps sadly they'll be back, and with that in mind, the airlines are covering their bases by collecting fees that the feds will demand when they come back to work. Congress routinely violates the constitutional ban against ex post facto laws by passing retroactive legislation. From the MBA's point of view, better safe than sorry.

Posted by: tom connor | July 27, 2011 12:01 PM    Report this comment

Tom,

Perhaps it's time we sport aviators started to raise this issue: do we really need the FAA, and if so, for what? Maybe the FAA should try to focus on airlines and other passenger-carrying operations, and minimize the resources it expends on helping/interfering with private operations. Obviously, there is some need to coordinate the two, but beyond some basic rules of the road, is there really any public interest served by having a Federal bureaucracy worry about private vehicles like this? Mostly, I think not.

Posted by: Thomas Boyle | July 27, 2011 1:20 PM    Report this comment

Tom/Thomas, Obviously we need the FAA. It may just be a good time to see how much FAA we really need for GA.

Posted by: Mark Fraser | July 27, 2011 2:17 PM    Report this comment

Paul, you hit a lot of good points in one posting!

On the subject of "need" for FAA, there are certainly many aspects of the FAA conglomerate that GA could do without. Traffic control is probably not one of them since the public demands (and almost gets) absolute, total safety in air carrier flight.

On the other hand, we could obviously exist just fine without the 3rd class medical. And the one thing that would re-invigorate GA would be to follow Tom Boyle's suggestion & completely "sunset" the hardware certification system for sub-12,500 lb. aircraft. Start over with no certification requirements at all, see what you really and truly can't do without.

Would people die as a result? Yep. A lot? Nope. Can't deal with that? Don't buy the products.

Posted by: John Wilson | July 27, 2011 5:04 PM    Report this comment

Evidently I'm late to the party on certification. See a story right here on Avweb:

http://www.avweb.com/news/airventure/lsa_lama_gama_part23_standards_205062-1.html

Assuming that doesn't get blocked. If it does, look for "How LSAs Could Influence Part 23."

Sounds like a fine start to me, although I worry about ASTM becoming the new FAA (for example, ASTM blocked LSA-in-IMC even though the manufacturers - and the FAA! - were okay with it, and the risk is no worse than it would be for Experimentals, where IMC has never been a particular problem as far as I'm aware).

Posted by: Thomas Boyle | July 27, 2011 6:04 PM    Report this comment

Thomas,

I think you are mistaken about ASTM blocking LSA in IMC (and I am a voting member on the F37 committee that controls LSA standards). There has been a lot of discussion on that subject but I don't think there has been any conclusion to the discussion.

About ASTM taking over Part 23 certifications as it has with LSA -- I just can't imagine how that could happen. It took a lot of hard work by a lot of very dedicated industry leaders to create the consensus standard paradigm for LSA and ASTM provides the clockworks for that process. There is no movement at all toward a consensus standard process for light planes destined for commercial operations.

Posted by: Paul Mulwitz | July 27, 2011 11:11 PM    Report this comment

Hi Paul,

On whether ASTM has prohibited LSA-into-IMC, you'd know better than I would! And I'm glad to hear it didn't: it seemed an uncharacteristically conservative step for an organization that had previously been much more forward-thinking. My apologies to all concerned!

I was going from stories published on Avweb and AOPA Online. I can't post links here but check for an Avweb story dated Sept 1, 2010 titled "LSA, IFR and IMC: An Update" and a September 3, 2010 AOPA Online story titled "LSA Flight Into IMC To Be Prohibited". At the time I was told that FAA had no objection to operating LSA in IMC, and clearly some of the manufacturers didn't (there were some aircraft being sold as "IFR ready" or something similar).

I understand that it took a lot of hard work to create a consensus standard paradigm, and very impressed that it was done (and I didn't mean to imply otherwise). I hadn't thought anyone was working to expand it until I saw that story on Avweb yesterday. Even if someone isn't, there's no real need for FAA to continue to get in the way. And a comparison of new LSA introductions, versus new Part 23 introductions, over the last few decades, pretty clearly establishes that FAA is in the way.

Posted by: Thomas Boyle | July 28, 2011 1:11 AM    Report this comment

I could sure due with a lot less FAA. A part for my Mooney that is also sold for experimental planes cost a lot more when it has the blessing of the FAA.

My doctor gave me the green light to get my 3rd class medical back. Now I'll see how long it takes the FAA to do it's part. Wouldn't it be nice not to have to deal with that 3rd class medical.

Posted by: Ray Wyant | July 28, 2011 6:53 AM    Report this comment

"I've never seen convincing evidence that a low-ball price on airplanes expands the market at the lower end in a sustainable way."

Right. The projected low-ball prices of some (most?)newcomers in an aviation market fail to factor in the huge costs of inevitable hiccups in the certification and the production start-up for new models. Just as important, they also fail to cover the high costs, especially warranty costs, of supporting a new and very thin customer base distributed all over the world.

When start-ups like Eclipse also waste time and money on impossible engines, pointless new structural details, etc, failure always seems to follow.

It's too bad about Eclipse. They had plenty enough capital to make a go of it -- if they had more disciplined management and a smarter initial design.

Posted by: S. Lanchester | July 28, 2011 11:04 AM    Report this comment

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Posted by: dukang John | July 28, 2011 5:06 PM    Report this comment

Hi Thomas,

There is a need for confidentiality in the discussions that take place in the ASTM, so I can't really explain what is being discussed. However, in the interest of clearing up wrong information that is circulating I will make a few small "Personal opinion" comments. I am not intending to speak for anyone but myself.

I agree that the FAA is comfortable with LSA that have the proper equipment installed operating in the "System". That is not what is at issue with the manufacturers or the ASTM committee either. What is at issue is whether LSA can be operated in IMC. This may sound like the same issue but it is not. Many training flights are operated in VMC but using IFR flight plans and some kind of vision blocking for the student pilot. I think everyone agrees this is a fine thing to do in LSA.

Operation in actual IMC is a different matter. It includes icing, potentially severe turbulence and other problems not encountered in VMC. It is not clear that the LSA standards are appropriate for this environment. Most likely is the fact that some LSA can handle it and others cannot. The standards really were not built with this environment in mind, but manufacturers may have considered it in their own design process for a given model. It is this complex combination of issues that is not and perhaps cannot be resolved.

Posted by: Paul Mulwitz | July 28, 2011 7:01 PM    Report this comment

Hi Paul,

Thanks for the insight. That does correspond with what I was hearing, which (to perhaps oversimplify a bit) was that ASTM had lost its nerve and started worrying about improbable scenarios involving LSA in IMC, specifically LSA operating in conditions conducive to ice and lightning.

Now, here I'm once again going on hearsay rather than personal knowledge. However, several things strike me about these concerns.

First, let's separate ice and lightning: the FAA gave up on certificating light airplanes for ice decades ago, which is why most IMC-approved light planes have a placard prohibiting flight into known icing. I can't imagine why an LSA would need any type of icing certification.

Now, let's consider lightning and extreme turbulence. Extreme turbulence associated with IMC means cumulonimbus, because the other type of extreme turbulence - wave turbulence - can occur in clear air. So these are the same problem: operating an LSA into a thunderstorm. The thing is, no-one in their sane senses is going to operate an LSA anywhere near a thunderstorm, IMC or VMC. While it's always possible to imagine the hordes of dumb pilots who might do it anyway, there are already numerous Experimentals out there being operated in IMC, many of them composite aircraft that would explode in a lightning strike - and I can't recall many (or any) instances of that happening.

Posted by: Thomas Boyle | July 28, 2011 10:15 PM    Report this comment

To wrap up that thought...

The commonsense reality is that the kind of IMC conditions people would want to operate LSA in, are going to be non-convective stratus layers and "flat" cumulus: it's the "descend/climb through a layer" operation, not "hard cross country IFR" (which would be unpleasant at best). It seems to me, and some other people I've discussed this with, that the practical thing would be to placard LSAs "Not approved for operation in known icing conditions. Not approved for instrument flight where thunderstorms are forecast," or something similar. This is how everything from IFR-certified C-152s to IMC-operated Experimentals are already operated in practice anyway.

Is it all really much more complicated than that? (That's not rhetorical: I assume it must be, or smart people wouldn't be as stuck as they appear to be. After all, if ASTM is going to start worrying about every remote possibility, it will have bigger problems with LSA than flight into IMC.)

Posted by: Thomas Boyle | July 28, 2011 10:16 PM    Report this comment

"Is it all really much more complicated than that?"

No, it isn't any more complicated than that and that is how it should be. I flew in a perfectly IFR-competent Remos GX-NXT yesterday and I wouldn't hesitate to fly it in IMC. Too bad it's not technically legal to do so.

Posted by: Paul Bertorelli | July 29, 2011 6:08 AM    Report this comment

Regarding LSA and IMC (IFR), one issue is the fact several OEMs have different certification level(s) for their products based on how they will be used. Since LSA was originally intended to be Day VFR, that is the level the products are held to. However, if the product is going to be used for night and or other more 'demanding' flight proficiency levels, the higher certification (costs more) is required.

Posted by: Richard Norris | July 29, 2011 6:49 AM    Report this comment

Thomas and Paul B.

I agree with all of your comments and analysis. Indeed I bow to both of you regarding IFR operations since I am not a rated pilot. However, there are complications in the regulatory domain I don't think are clearly understood.

ASTM is not a regulatory body. It is a standards body. It does not and cannot prohibit or allow anything. ASTM creates international standards that can be used by national regulatory bodies (like FAA) to regulate (in this case) aviation in their country.

There is also a big difference in the S-LSA regulatory environment than the one for type certificated aircraft. For S-LSA the manufacturer has nearly infinite power to decide how their product is used. This means one manufacturer might restrict their planes to non-IMC operations while another may not. That is how it is today, and how it will remain. The notion that ASTM will prohibit LSA flight into IMC is flawed in its formulation.

I won't go any further than to say some manufacturers may think their competitive position in the market is damaged by their (perfectly proper technical) choice to prohibit flight into IMC for their own product. In their frustration they might try to use ASTM to improve their position by making all LSA equally inappropriate for this kind of operation. I don't think this ploy will ever work.

Posted by: Paul Mulwitz | July 29, 2011 7:19 AM    Report this comment

Hi Paul M,

What was it, then, that changed back in September? Before that, it appears that ASTM had issued standards for LSA to be - broadly speaking - "airworthy," with use limitations left up to the manufacturer, and with ASTM remaining silent on "IMC". By that logic, flight of a properly-equipped LSA into IMC by a properly rated pilot was left up to the manufacturer, who could prohibit it or not. (Rotax, in trying to extract even more value from its near-monopoly in LSA, was even selling an apparently identical but differently-priced engine with the "Day VFR" restriction removed.)

But, in September we heard that ASTM had taken a vote to positively require a prohibition on operations in IMC. As I understood it, the effect was that a manufacturer could not offer an aircraft as being "in compliance with ASTM standards" unless the operating limitations effectively specified "VMC Only". If an aircraft does not comply with ASTM standards, it is not eligible as an S-LSA, at which point the FAA steps in with its regulatory powers. Thus, although ASTM is not directly a regulator, it has had regulatory powers delegated to it.

Your notes suggest that whether to actively prohibit IMC, or to remain silent on it, or to create some "certification" requirement for removal of a prohibition within the ASTM standard, is the debate that's under way.

I do hope commonsense prevails!

Posted by: Thomas Boyle | July 29, 2011 7:53 AM    Report this comment

Nothing important changed in September.

Let me point out that "Taking a vote" in the ASTM consensus process is quite different from our concept of voting in democratic processes. A single negative vote kills an item. There are complicated procedures to try to eliminate the negative vote but those were not employed in the ballot you have heard about. I remember reading some message suggesting the ballot item was distributed in error. I'm quite sure there was at least one negative vote (mine) and I'm confident there were many more such votes.

Posted by: Paul Mulwitz | July 29, 2011 6:31 PM    Report this comment

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