FAA Still Failing on Small Unmanned Aircraft Systems (UAS)

“What are they smoking at the FAA???
“When is the FAA (and their indifferent parent, the DOT) going to fire their current crop of idiot regs-makers, and replace them with sober, competent, responsible adults?”

Valid questions, raised by a commenter in an online article at AW&ST’s AviationDaily, FAA Urged To Act Fast On Final Small-UAS Rule. The article and the comments are well worth reading.

The agency is well behind schedule, and they are failing to address the real issues. In fact, for the smaller and wildly popular hobby drones, the key issue is less about safety (since even small manned aircraft should not be flying so low to the ground), but more about the invasion of personal privacy. Here is a portion of a citizen comment that focuses on personal privacy and concerns about use of drones to monitor and arrest people, as submitted to the NPRM (by Christopher Booth, in Concord, NH):

“Addressing the issue of privacy is paramount. You can operate a UAV for private use, but can not obtain imagery which would violate any person’s expectation of privacy, and no imagery or information may be obtained for public use without regard for the requirement that a warrant must be obtained before such collection if it is going to be admissible in any court proceeding or may be used for the purpose of obtaining the arrest of any person. In other words you can not randomly fly a UAV over a city looking for someone to arrest, or to observe whether anyone is obeying or disobeying any law. You have to get a warrant for that, and it has to have probable cause that the person should be arrested, and must specify where you can look for them and who you are looking for to obtain that warrant – from a judge in open court, in the presence of a public defender arguing why the warrant should not be issued.”

Everyone would be better served if FAA simply punted. Perhaps FAA should relinquish regulatory authority for low altitude (?below 500-feet AGL and clear of all actual airport traffic patterns?) and light-weight (?under ten pounds?) drone uses?

Also, FAA could reduce noise impacts by helicopters AND increase safety margins, if they would simultaneously tighten the FAR 91.119 ‘Minimum Safe Altitude’ flight restrictions. It would be a ‘win-win’ if FAA would require that all manned aircraft (fixed wing and helicopters) cruise at altitudes at least 2,000-feet AGL, and transition to/from these cruise altitudes within reasonable short distances of takeoff/landing locations. Skies would be quieter AND safer.

See also:

ANALYSIS: Three Serious Accidents in Texas, all Related to the Same Frontal Passage

On the evening of February 4th, three separate small aircraft crashed and were destroyed in Texas. Two accidents killed the sole pilots; the third accident had four adults aboard and nobody died.

At all three locations (Lubbock, Argyle, and Andrews) a frontal passage occurred hours before the accident. The frontal passage brought strong, gusting winds, overcast ceilings below 1,000-feet, falling temperatures, and combinations of light rain, freezing drizzle, and mist.

The cold front passed through at around the following times:

  • Hobbs, NM: 12noon
  • Lubbock, TX: 3PM
  • Andrews, TX: 5PM
  • Denton, TX: 8PM
20150204scp.. PA46 flight route to KLBB (flightaware)

(click on image to view flight at Flightaware.com)

The first accident was in Lubbock [KLBB] and involved a doctor flying a Piper Malibu (high-performance single-prop). He was flying home from near Hobbs, NM. The flight impacted an 814-foot tall TV station antenna, and crashed more than six miles from the runway. The KLBB METAR 12-minutes after the accident, at 7:47PM, included: temp/dew 28/25, wind northeast 21kts gusting to 31kts, visibility 7 miles, ceiling 700′ overcast. Conditions were prime for icing, and light freezing drizzle did begin on the surface at KLBB at around the time of the crash. It seems inconceivable that the pilot would attempt to ‘scud-run’ so low, nor that ATC would allow it. The ATC communications should be revealing.

20150204scp.. N441TG, Final approach map, Flightaware

(click on image to view flight at Flightaware.com)

The second accident was also fatal, and involved a businessman flying alone,, home to the Denton airport [KDTO] in a 10-passenger Cessna Conquest (twin-prop). His flight profile included an intercept of the KDTO RNAV Runway 36 final approach at WOBOS, just west of Grapevine Lake. The KDTO METAR seven minutes prior to the accident, at 9:03PM, included: temp/dew 38/37, wind north 20kts gusting to 29kts, visibility 2 miles light rain and mist, ceiling 900-feet overcast. The crash debris distribution, with the wings and empennage separated but whole, suggests an aircraft that hit the ground hard but with a relatively normal ‘flat and straight ahead’ attitude. As with the Lubbock crash, ATC should have considerable information to explain the circumstances of this crash, so long as FAA does not conceal the information within the ATSAP safety data black hole.

20150204scp.. BE36 flight route to E11 (flightaware)

(click on image to view flight at Flightaware.com)

The third accident was miraculously nonfatal for the four adults aboard. Weather at the arrival airport near Andrews [E11] was already down to a 900-foot overcast ceiling, even before the single-prop Beechcraft Bonanza departed. Weather deteriorated further during the 80-minute flight, and the E11 METAR ten minutes prior to the accident, at 12:35AM, included: temp/dew 29/29, wind north-northeast 13kts gusting to 18kts, visibility 5 miles mist, ceiling 700-feet overcast. These flight conditions, to an uncontrolled airport in flat treeless countryside, have been known to result in scud-running. In this case, the pilot reportedly radioed ATC with an icing problem.

Here is a satellite view of the terrain near the Andrews County Airport. In a controlled arrival, given he winds, you would line up for Runway 34 or Runway 02. If iced up, you might not make it that far. Imagine dropping through the clouds at 700-feet above the surface, and having maybe one minute to try and control the aircraft and pick a spot to cause the least damage. A lot easier here than in other parts of Texas.

20150204scp.. Satellite image for approach area of E11

(click on image to view the satellite image at Google maps)

ANALYSIS: The ‘Mogas’ Study at KHIO, by KB Environmental Sciences

This Post offers an analysis of a 59-page study funded by the Port of Portland, to investigate the potential and feasibility to sell unleaded aviation fuel at the Hillsboro Airport [KHIO]. It includes some background on the leaded fuel issue, followed by a look at (and critique of) the KB ‘Mogas’ Study.


The Clean Air Act was passed in 1970, and included guidance for the removal of toxic lead from transportation fuels. It took more than two decades for EPA to completely phase out lead in automotive fuel, as was accomplished in 1996. But, although there are far fewer aircraft and fueling locations (and thus the change for aviation should have been faster and easier to accomplish), it has now been 45-years, yet lead remains in the most commonly used General Aviation (GA) fuel: 100LL, commonly called Avgas.

Many aircraft have been modified to safely use unleaded fuel, commonly called Mogas. The problem, though, is that while mogas is widely available from wholesalers, very few airports have invested in the above-ground storage tanks and/or fuel trucks needed to offer this less hazardous fuel choice. Thus, even busy GA airports do not offer mogas. Such is the case today at the Hillsboro Airport [KHIO], west of Portland, OR.

20150204scp.. PoP Aternatives to Lead in Aviation Fuel [KHIO]For the past few years, lead has been a focused issue at the Hillsboro Airport. The airport is owned/operated by the Port of Portland (PoP). It is common throughout the U.S. for airport authorities to appoint citizen groups, which ostensibly assures the community is involved in airport impact decisions. In reality, though, PoP and other airport authorities tend to stack the membership of these groups so as to assure they vote favorably for the airport uses (and against the airport neighbors). At Hillsboro, PoP created the Hillsboro Airport Roundtable Exchange (HARE). Many airport neighbors feel that HARE is strongly aligned with the aviation interests at KHIO, particularly Hillsboro Aviation.

The KB ‘Mogas’ Study’s Summary:

At some point in the recent past, the Port of Portland hired a consultant to prepare a study related to the KHIO avgas/mogas issue. They hired KB Environmental Sciences, based in Tampa Bay, FL (and with offices in Washington, DC and Seattle) to do a study. KB is one of a handful of companies who make lots of money doing studies that are use by the aviation status quo to sustain practices and delay change. KB’s 59-page report was completed last December, and just recently made public. Here is the bullet list from the Executive Summary page:

…to read the study summary and the aiREFORM analysis,
please see page two of this Post…

Growth of Jet Operations at KSMO, 1983-2014

20150202cpy.. KSMO Annual Jet Ops chart, 1983-2014The number of jet operations per year, in and out of the airport at Santa Monica [KSMO], was barely 1,000 in 1983, and peaked at around 18,000 from 2004-2007. There was a substantial decline coincident with the financial collapse of 2008, and jet operations bottomed out below 13,000 during 2010-2012, before climbing back to 15,000 in 2014.

FAA’s records indicate there are only 6 or 7 jets actually hangared at KSMO. In fact, much of the jet traffic at KSMO is on-demand charter jets, often flying relatively short distances to Arizona, Nevada, the Rockies, or the Bay Area. The on-demand charter jets also frequently fly repositioning hops between KSMO and the three closest airports: KLAX, KVNY, or KBUR. Thus, a 6-mile or 8-mile direct trip becomes 50-60 miles of flying, mostly at altitudes no higher than 5,000 feet. The noise, soot, and other pollution impacts are substantial. And, as close as the houses are to the runway at KSMO, these jet operations are certainly not good for the health of local residents.

Below are aerial views showing the approaches to the two runway ends: Runway 21 (the primary runway) facing towards the ocean, and Runway 03 (used far less frequently) facing away from the ocean. These images are copied from a November 2011 presentation by Martin Rubin, Santa Monica Airport & Public Health.20111130.. aerial view RY21 looking SW [KSMO]20111130.. aerial view RY03 looking NE [KSMO]
Given the dense residential development close-in to the runway, air charter service to the Santa Monica area would be more safely and efficiently handled out of KLAX, KVNY, or KBUR. All three of these other airports offer much longer runways as well as multiple runways, so they can safely segregate faster jets from slower recreational aircraft. Plus, at all three airports, the controllers regularly work steady jet flows.

See also:

Seven Months above 400ppm

We’re already back above 400 parts per million of CO2 in our atmosphere.

Last year, we hit this mark in early April. This year, we are two months earlier. Given the clear trends since Keeling first started measuring atmosphere CO2 in the late 1950’s, we can expect to briefly pass below 400ppm next Fall, then pass above 400ppm late in 2015, never to fall below again.

The text below was posted a year ago, and it still applies…

Geologists are confident that, going back to at least 800,000 years ago, the CO2 in our Earth atmosphere has never exceeded 300ppm … or at least not until AFTER mankind started creating CO2 by burning coal, oil and natural gas. When measurements were started in Mauno Loa, in 1958, the annual peak for CO2 was 315ppm. As shown by the graph below, for the past week, the daily average has remained above 400ppm.

20150130scp.. KeelingCurve holding at 400+
So, the pressing question is:

…when (and how) will we get control
of our addiction to fossil fuels?

See also:
  • The Scripps Institution of Oceanography updates this online graph everyday.

2015-01-25.. Near Collision, JetBlue Arrival to White Plains, NY

An Airbus A320, flown as JetBlue Flight 94 from Orlando, FL [KMCO] to White Plains, NY [KHPN], reportedly took evasive actions during the arrival, to avoid a collision with a small plane. The news story was widely reported four days later.

(click on image to view source/original article at cnbc.com)

(click on image to view source/original article at cnbc.com)

Below is arrival portion of the route of flight, from FlightAware. Note the flight-planned crossing of the midsection of Long Island and the box-shaped route over the Sound, apparently to transition through the flows in/out of KLGA and/or KJFK.
20150125scp.. JBU94 Arrival to KHPN, FlightAware route plotIf reports are accurate and the JetBlue crew did in fact take last-second evasive actions, this was most likely a controller error. And this does happen; controllers get bored or distracted. Or, they may be coming to work with deprived sleep, due to bad workshift planning, with compressed work schedules (though, many controllers ‘benefit’ from this type of schedule, by having what feels like a 3-day weekend every week).

In any event, if there is any possible ATC involvement, NATCA and FAA will both encourage the controller to file an ATSAP report. Doing so grants that controller immunity for his/her error, meaning less re-training  and less discipline. More importantly (to FAA and NATCA), filing the ATSAP report means the Public will likely learn nothing more about what happened here.

Why not? Because in May 2014, FAA Administrator Huerta signed off on a new administrative rule that declared all ATSAP report data ‘fully exempt’ from release under FOIA laws. Now, not even the courts will compel release of ATSAP data. This change makes ATSAP effectively a ‘black hole’ for U.S. aviation safety data. Thus, no matter how diligently the media investigates this incident, FAA will refuse to release the real details, as reported by the controller.

If it helps to sweeten your bitter, just give it a fuzzy new name and catch-phrase:

ATSAP – FAA’s new ‘Flying Blind’ program

‘We keep you safely in the dark!’

EPA on Leaded Avgas: Delay-Delay-Delay

EPA recently issued a response to a petition filed by a coalition seeking action to address the problem of aviation lead air pollution, particularly at the nation’s busiest GA-training airports. Lead was banned decades ago in automotive fuel, paints, and other products, yet lead is still being added to the fuel used by small propeller-driven aircraft, even newly-built aircraft with brand-new aircraft engines.

(click on image to view original article)

(click on image to view original article)

A quick look at the timeline on this matter reveals just how ineffective EPA is at pressuring FAA to protect air quality near airports. The timeline on this issue is as follows:

  • October 3, 2006: petition by Friends of the Earth, seeking rules to regulate GA lead emissions
  • late 2008: EPA strengthened the NAAQS for lead, reducing the allowable level from 1.5 micrograms per cubic meter, to 0.15 micrograms per cubic meter
  • 2010: EPA improved lead monitoring by requiring readings at selected airports
  • July 18, 2012: EPA responded to the 2006 petition
  • April 21, 2014: petition by a coalition, asking EPA to reconsider the 2012 response
  • January 23, 2015: EPA’s final response letter, responding to the 2014 petition

Note that the timeline includes two formal response letters by EPA. In the first one, in mid-2012, EPA estimated they would produce a final determination in mid- to late-2015, with regard to Avgas lead emissions endangerment. In their latest formal response letter, EPA is now estimating they will produce a final determination in 2018, with regard to Avgas lead emissions endangerment.

That’s twelve years, 2006 to 2008, just to produce a ‘final determination’, which does not even get to the actual change needed. An entire generation will be born and grow up breathing in this lead, at and near hundreds of lead-impacted airports in the U.S. — not just the ‘seventeen’ airports posted in EPA’s latest questionable summary, but scores of other ‘unlisted’ airports, too (like Hillsboro, near Portland, OR).

The beat goes on. And, so does the AvGas lead pollution….

See also:

‘Just Say No to Jets’ — In Santa Monica

Joe Marrapodi was interviewed for a column in the Santa Monica Daily Press. As a final question, he was asked: Is there anything you’d like to share with the Santa Monica community? Here is what he said:

“The Santa Monica Airport has a rich history with the city, but with the relatively recent explosion of jet traffic, the airport is no longer in balance with the community. Jet fumes cause cancer, birth defects, and are a serious health issue for growing children.

Please, Santa Monica, the jets were never welcome and now they need to go.”

There are many in and around Santa Monica Airport who agree with this, and if the FAA will cooperate, this could happen this year. The few jets using KSMO can easily and more efficiently use the bigger and better-suited airports (KBUR, KVNY and KLAX are closest).

See also:

Trends in Aviation Transparency: Passenger Documents In-Flight Engine Failure

The trend in aviation has been toward careful micromanagement of information, by both the airlines and the regulatory officials. So, when an airplane issue happens (an accident, an in-flight failure, or even a disappearing flight), or when ATC makes a mistake, it is nearly impossible for the press to produce a solid, informative news article. Often, in fact, the stories do not get into the news. It seems that, if the Av-Gov Complex had it their way, there would be no transparency in aviation. Increasingly, what transparency we have is driven by personal electronic devices, social media, and independent blogs.

So, it is a pleasure to see the occasional news story that DOES happen, when a passenger snaps a picture from her airplane seat. In this case, a Dash-8 feeder flight from Kansas City [KMCI] to Denver [KDEN], operated as Republic Airlines Flight 4936, was flight-planned to cruise at FL240 but levelled at FL200 (20,000 feet) when the crew had to shut down the number one engine due to low oil pressure. Here’s the photo which helped ensure the world would learn about this incident:20150123.. Republic 4936 DH-8 engine out, passenger photo
The flight then turned around and landed back at KMCI. Total flight time: one hour.

(click on image to view flight data at FlightAware.com)

(click on image to view flight data at FlightAware.com)