Icon’s Low-Flying Guidelines: A Good Start

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In May of this year, two Icon company employees flying an A5 made the error that has been the final mistake for too many seaplane, bush, backcountry and mountain pilots. They entered a canyon from the downhill end, starting below the surrounding ridges. By the time they discovered they were in the wrong canyon they didn’t have room to either climb over the ridges or make a 180-degree turn. They tried to reverse course, hit a canyon wall and were killed.

Icon’s response to the accident was a breath of fresh air. In an open letter from company CEO Kirk Hawkins last week, Icon reiterated that its A5 is built for fun flying and pilots like the thrill of flying low. The letter provided a link to Icon’s new Low Altitude Flying Guidelines. Those guidelines speak frankly about the risks of low-altitude flight, give guidance for flights in the “low-altitude” environment—which it defines as below 300 feet AGL—and recommends a “soft deck” of 300 feet AGL as the minimum altitude at which Icon pilots should operate their amphibians. Icon ground and flight training will include instruction in operations down to that altitude. For those pilots who wish to whistle around below 300 feet AGL, Icon is now requiring completion of its advanced “lowalt” training and a check ride. Because the purchase agreement for an Icon A5 requires that each owner and pilot who flies one agree, in writing, to comply with Icon’s operational guidelines for the A5 and each airplane has a flight data recorder installed, Icon is in a position to enforce its low-altitude operational guidelines and requirements.

When it comes to low flying, pilot flight training has almost exclusively consisted of telling pilots not to do it. Historically, that approach has been about as effective as telling teenagers not to have sex. Each month I research and write up the accident history of a specific model airplane for the Used Aircraft Guide in our sister publication, Aviation Consumer. Each month I average reading between four and 10 accident reports involving pilots who tied the record for low flying—few survive. I think that yanking the subject out into the open for discussion and formally teaching pilots how to fly low without killing themselves should have been done long ago.

As a side note, I think Icon’s low-altitude guidelines need more information on avoiding power lines because they are only visible to a pilot if the light is just right—most of the time it’s not—and they are often routed where least expected. They can be just above the trees right along lakeshores (in the glide path for landing on the lake) and over the water between the shore and an island. As a seaplane instructor, I teach my students to be suspicious of the airspace between an island and the shore of a lake. Often, the only way to spot power lines is to find the supporting poles, but even with that aid, the lines themselves may be invisible until you’re within 100 feet of them.

Power lines get strung across river valleys—with no supporting poles in the valleys themselves. When I was in Civil Air Patrol in high school our Wing Commander decided to take the Wing’s T-34 out to do vertical banks along the cliffs of the local river. He hit power lines and removed one wing.

Every summer in high school I worked ground crew for a crop duster. More than once I watched those professional pilots hit power lines they didn’t see when going into or coming out of a pass across a field. I kept track of the aerial application pilots I worked with. Every single one crashed. Most of the accidents were due to hitting an obstruction.

When I look at seaplane or amphibian accidents, there are always some due to hitting the water unexpectedly—usually in conditions of flat light (overcast skies and lack of color contrast over the ground or water) or glassy water. Often those accidents involve a pilot who was intentionally flying low over a lake and hit the water in level flight (usually just a lot of damage to the aircraft, but sometimes fatal) or stuck a wing into the water (almost always resulting in a fatal cartwheel). In my experience, until a pilot actually experiences flat light and glassy water conditions she or he simply cannot believe that it is absolutely impossible to tell how high the airplane is above the water within several feet. The first glassy water landing for a seaplane student is almost always a revelation—the airplane never touches the water when the pilot expects it. In my opinion, a pilot who has been trained in low flying and the nature of glassy water and flat light conditions is going to tack on some extra altitude because he or she is aware of the powerful visual illusions involved.

Bush and backcountry pilots know never to enter a canyon or fjord from the bottom because the differences between the entrances of the safe one and a box canyon are often too subtle to distinguish. They know that if they desire to fly between the walls of a canyon to first fly to the uphill end, staying above the ridges, and only descend into the canyon going downhill.

I’m also glad to see that Icon is addressing the FARs applicable to low flying as they have a serious gotcha for pilots. The FAA does not publish its definition of a “congested area” in the FARs. You have to read the cases where the FAA has gone after pilots for illegal low flying over a congested area to get a feel for its definition. For example, it’s been defined as four houses within a quarter of a mile, a small group of people standing on the ramp in front of an FBO and a busy interstate highway—much smaller assemblages of people than most pilots would expect. The rule of thumb for seaplane pilots is that if you see four or five boats in proximity to each other, consider them to constitute a “congested area” and stay 1000 feet above them and/or 2000 feet away horizontally. Icon encourages pilots to be courteous to people they are flying near. That’s wise. After all, not everyone on the ground or in a boat likes little airplanes and those folks have cellphone cameras that can be used to take photos for evidence against low-flying pilots. Plus, the FAA can subpoena the flight data recorder from the A5 to help make its case against a low-flying pilot.

I suspect Icon is going to be tweaking its low-altitude guidelines and training. It appears a bit weak on power lines and tower guy wires. However, I think it’s great that Icon has stepped up to squarely face the issue of protecting pilots who want to have fun flying low. I think the other manufacturers should consider doing the same thing because pilots are using their airplanes for that purpose. Flying low is a blast. The way to stay alive doing it is to receive formal training in how to do it right; not rely on information whispered in the back alleys.

Rick Durden is the Features editor of AVweb. He is a CFII, holds an ATP with type ratings in the Douglas DC-3 and Cessna Citation and is the author of The Thinking Pilot’s Flight Manual or, How to Survive Flying Little Airplanes and Have a Ball Doing It, Vols. 1 & 2. 

Comments (22)

I hope this low flying training does not encourage newbies to think they can safely scud run.

Posted by: April Talmadge | October 23, 2017 8:17 AM    Report this comment

"I think it's great that Icon has stepped up to squarely face the issue "

Seriously?
Icon's entire business model was to make an airplane to be flown at low altitude by 20 hour sport pilots. NOW, after first delivery, they worry about people flying at low altitude with little experience?

Posted by: Mark Fraser | October 23, 2017 8:47 AM    Report this comment

"However, I think it's great that Icon has stepped up to squarely face the issue of protecting pilots who want to have fun flying low."

Next topic:

"Drones and low flying aircraft and Protecting people who want to have fun on the surface and then Calling your FAA FSDO"

Posted by: Rafael Sierra | October 23, 2017 10:55 AM    Report this comment

Mark nailed it. Icon purports to be in the paintball business, but they're selling real guns and live ammo. How can anyone be surprised by the almost-certain outcome? Those rocks, lakes, and rivers are real - as an experienced factory pilot demonstrated in the most costly way. Newbies + low-altitude manuevering = disaster, no matter how "safe" the vehicle is.

Posted by: Tom Yarsley | October 23, 2017 10:56 AM    Report this comment

As commendable as it is, it does seem a little odd that they are just now addressing the issue. After all, every sales brochure and promotional video they have released shows pilots zipping around close to the water like the plane is a jet ski with wings. I can't imagine that it took the tragic loss of two employees to make them realize the potential for such behavior.

I wonder if their training will include the likelihood for encountering drones. At those low altitudes they are encroaching in airspace where drones can legally fly. You can see a lot of YouTube videos of lakes, rivers and ocean scenes taken by drones.

Posted by: John McNamee | October 23, 2017 11:10 AM    Report this comment

As others have mentioned, there are some problems with Icon's approach. But as much as this can be a "they should have seen this coming" situation, at least they are realizing it's a problem and doing something about it. And there is very little said about low-altitude flying/scud running, other than "don't do it", which as Rick says, isn't very productive or helpful.

I recall one article posted on this site that was something like "how to scud-run safely", which went into detail on how to do it...ending with "and that's why it's not something you should do" or something to that effect. THOSE are the types of articles and safety tips we need, not just blanket "do/don't do X" without an explanation of why.

I don't know the details of what Icon has in mind, but as long as it is approached from a direction that gives low-alt flying the proper respect it deserves, at least if a pilot attempts it, they'll have some sort of idea about what to do to not become a statistic. And regardless of what gets pilots into trouble, I think we can all agree that keeping GA out of the news (which in 99% of cases is "look, something bad happened") is a good thing.

Posted by: Gary Baluha | October 23, 2017 11:55 AM    Report this comment

Icon re-labels "Mountain Flying", "Back Country Flying" and just basic weather flying in Alaska and it stirs folks up. Those of us who learned to fly in Alaska were introduced to low-level operations the first lesson. It's very common for the weather to turn within an hour and force a pilot to fly at altitudes less than 500 feet.

So, is this whole topic really about labeling?

Posted by: Klaus Marx | October 23, 2017 12:15 PM    Report this comment

Klaus,
Icon marketed to young males who wanted excitement without the whole bother of getting a full private pilot certificate, learning about retractable undercarriage, or even the added bother of finding a seaplane for an additional rating. As said by John, Icon marketed it as a jet ski with wings. Icon obviously worked overtime to gain an exception from the FAA to make sure that owners did not require traditional seaplane ratings.

If Icon was really serious about training a pilot to safely fly an amphibious seaplane, they should surrender their LSA exemption. End of story.

Posted by: Mark Fraser | October 23, 2017 2:55 PM    Report this comment

"If Icon was really serious about training a pilot to safely fly an amphibious seaplane, they should surrender their LSA exemption."

But Icon didn't come up with the concept of a light-sport seaplane rating; that already existed. Icon's exemption only applies to it being heavier than otherwise allowed for an LSA seaplane. And their own webpage suggests 27 hours as the absolute minimum to earn a sport-pilot seaplane rating (7 hours on top of the 20 required for SP). To me, they seem to be going about the training aspect properly, though their marketing of the A5 is a bit disconnected from the training, and they should probably work on that.

Posted by: Gary Baluha | October 23, 2017 3:19 PM    Report this comment

Subtly endorsing this low altitude flying guidelines, errr fright training for the unskilled, appears to be ludicrously ludicrous. Maybe I'm out of touch with the scheme.

Posted by: Rafael Sierra | October 23, 2017 4:28 PM    Report this comment

Mark Fraser. I thought your first comment was rough but your second compelled me to write a response. Let's start with your first comment on 20 hour sport pilots. I don't know any and I'd be interested to know if you do. Please compare the training requirement for a sport pilot with that of the private pilot. Pull out the operations that sport pilots can't legally do and tell me what VFR day training the private pilot has that a sport pilot doesn't. I suspect many pilots going into the Icon are former or current private pilots or higher. Regardless, all require type specific training so the level or cert they show up with should not matter.

Your second comment seems to me to suggest one must have a private license to have the "right stuff" to fly a seaplane. I would think a J3 or Aeronca on floats would be more difficult to fly than an Icon. I may be wrong but sport pilots have been flying those for years.

Finally, at what point in experience flying aircraft does a sport pilot meet muster in your opinion? Do they ever or are they always something less than a real pilot?

I'm just curious because you seem to imply pilots who fly under sport pilot rules are somehow, well.......

Perhaps I just misunderstood

Best.

Posted by: jay Manor | October 23, 2017 4:44 PM    Report this comment

1) Private pilots are taught night and instrument work; seaplane ratings teach further regulations and operations on water. None of that is part of the LSA/Sport rating (nor legally required to fly the Icon) but come in handy in real world operations and events.
2) We have seaplane ratings because operation on water (floats OR hulls) takes some training and experience and a sign off.
3) Icon itself is saying that there is a lack of "muster" by publishing these guidelines. Obviously, seasoned private pilots with seaplane ratings already know about the dangers down low, slow, and off-airport because they are still alive.

I don't imply, I insist that LSA airplanes are just as deadly as any typical small GA aircraft (even more so if you add retractable landing gear and river landings to the mix).

Posted by: Mark Fraser | October 23, 2017 8:07 PM    Report this comment

Rick,
"Because the purchase agreement for an Icon A5 requires that each owner and pilot who flies one agree, in writing, to comply with Icon's operational guidelines for the A5 and each airplane has a flight data recorder installed, Icon is in a position to enforce its low-altitude operational guidelines and requirements."

You are an experienced attorney ... with the caveat that details matter and we don't have the actual agreement here for reference, but as a conceptual matter: are those agreements likely to be enforceable in any meaningful way? What would the company do: Summarily cut an owner off from parts and maintenance for non-compliance? That is not a great way to build a customer base, let alone a loyal one.

Seems like the business drivers (sell airplanes & cultivate happy customers) cuts against any theoretical "technically enforceable" agreement on how use a product. I can't see them wanting to litigate access to parts or whatever their action against a non-compliant owner may be in Delaware Chancery court ... of course they probably opted for a mandatory arbitration of any dispute ... but that is another kettle of fish.

Curious where you think the practical bottom line is on the manner of use conditions for a vehicle.

Thanks,
Don

Posted by: DON HUDDLER | October 23, 2017 8:14 PM    Report this comment

Here in New Zealand low-flying is a mandatory part of the PPL curriculum (Terrain and Weather Awareness). Perhaps if you taught it in the states you'd have fewer stall/spin accidents.

Posted by: Gareth Allen | October 24, 2017 2:40 AM    Report this comment

Jay:

As I've read the string of comments, I've detected no assertion that private pilots are superior to sport pilots. OTOH, there's widespread sentiment that LOW-TIME pilots of ANY stripe would live longer if they eschewed low-level manuevering in their newly-acquired toys.

Remember, while Icon eagerly will sell one to a 10,000-hour seaplane-rated ATP, they're marketing their bird - and its "adventure experience" - to NON-pilots. Zero-timers. Does Icon even require a purchaser to demonstrate that s/he can swim? At least most JetSki operators wear personal flotation devices...

Gareth's comment is interesting, particularly in the context of response #2 to the accompanying Reader Poll. If something is in the curriculum, is it "okay to do?" Food for thought.

Posted by: Tom Yarsley | October 24, 2017 4:20 AM    Report this comment

"Icon's response to the accident was a breath of fresh air." I would not describe Icon's marketing strategy as "a breath of fresh air." It appears to me like it is an attempt to control undue tarnishing of the aircraft's developing reputation, a clever way of enticing the Zero-timers. YARS nailed it!

Posted by: Rafael Sierra | October 24, 2017 5:58 AM    Report this comment

"It appears to me like it is an attempt to control undue tarnishing of the aircraft's developing reputation..."

Though the same could have been (and I believe was said) of Cirrus when they started up their training program.

Posted by: Gary Baluha | October 25, 2017 8:12 AM    Report this comment

As far as I know, Cirrus' training program doesn't include "Recreational Buzzing and Swooping for Zero-time Pilots 101." A 300-foot soft deck? Seriously? Other than amphibious operations, how can one defend doing something in an Icon that you'd never endorse in a Cherokee?

The pre-solo written test that I administer includes this question: "Under what circumstance can you descend below traffic pattern altitude?" The correct answer is: "When it is necessary to do so, in order to land." Not coincidentally, that's also the correct answer to the question: "When conducting a circling approach with the runway in sight, under what circumstance can you descend below the published MDA?"

Low-altitude maneuvering is a perenial favorite among probable causes. Do we really want to endorse it? How much is an amateur thrill worth?

Posted by: Tom Yarsley | October 25, 2017 9:01 AM    Report this comment

We all know GA flying is not as safe as airline flying. We try to lower thee risks but we still freely accept them because we love flying ourselves instead of suffering the indignities of modern airline flying. Statistics also make it clear flying experimental aircraft is riskier than flying certified aircraft. Again, pilots of experimental aircraft freely accept that risk because they enjoy that brand of flying.

I have been a Cirrus Standardized Instructor Pilot since 2004 and the obvious difference between Icon and Cirrus is Icon is marketed as an adventure device and Cirrus is marketed as a safe and effective means of personal transportation.Since "risk" is a component of "adventure" flying an Icon will always tempt pilots to do stupid tricks regardless of how much experience and training they receive and no matter how well-built the aircraft is. In a rational world populated by responsible adults the rule would be full disclosure of the potential risks and let the purchaser (and his passengers) make their own decisions about how much risk they are willing to assume.

But we don't live in a rational world, we live in a country with a legal system that allows people to offload the consequences of their stupid decisions to other parties. That is the problem Icon faces, trying to make a product that is inherently risky seem safe to juries filled with people who understand little about aviation. I predict the legal system will eventually force Icon out of business as the surviving family members of stupid pilots sue Icon into bankruptcy despite their purchase agreement.

Posted by: ROBERT W LITTLEFIELD | October 25, 2017 11:44 AM    Report this comment

Hi Tom,

The low-flying and terrain and weather awareness PPL requirements were mandated after a spate of accidents on New Zealand. I suppose the dangerous pilots will always do stupid things without encouragement, and all pilots can use the training. From the CAA lesson briefing introducing Low Flying (if you google "caa nz low flying introduction" you'll find it and the rest of the briefings)

"It is important for the student to be exposed to operating close to the ground, not only when forced to fly low, but also when Mountain Flying. It improves the student's awareness of terrain and the effect of wind. Good aviation practice dictates that a pilot should never fly lower than they must, however, each takeoff and landing involves low flying operations, where the recognition of potential visual illusions is critical."

Posted by: Gareth Allen | October 25, 2017 12:20 PM    Report this comment

When Cirrus first came out with the BRS there was concern that having the option of the chute, pilots would take risks they would not have taken without the backup of the chute option. One Cirrus pilot told me that he felt" a lot more comfortable" flying IFR over the mountains. So maybe this Icon program will make low time pilots feel a lot more comfortable buzzing the boats and flying under bridges.

Posted by: Richard Montague | October 26, 2017 7:29 AM    Report this comment

Soooo, when's PB coming back?

Posted by: Rafael Sierra | October 27, 2017 1:57 PM    Report this comment

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