A LAMP to Illuminate the Weather

At irregular intervals, the National Weather Service (NWS) publishes The Front, a newsletter intended to "enhance aviation safety by increasing the pilot's knowledge of weather systems and processes, and NWS products and services." The newsletter invariably contains Good Stuff.

I've just gotten around to reading the latest issue (dated March 2010) and was not disappointed. One article describes the new, uniform look of the NWS Eastern Region's Center Weather Service Units' (CWSU) web sites. The revamped sites offer a number of outstanding flight planning products.

Since I need to access information from airspace covered by Boston Center (ZBW), New York Center (ZNY) and Washington Center (ZDC) for my weekly travels, I've bookmarked an NWS Southern Region site that offers a clickable map that links conveniently to any CWSU site.

For the Eastern Region (ZBW, ZNY, ZDC & ZOB), when you click on the Center of your choice you are brought to a top level page that offers an overview map showing current conditions in the Center's airspace. (Some CWSU sites outside the Eastern Region appear to have older formats, but the same information is usually available. Presumably in coming months they'll be upgraded as well.)

The map offers click-to-zoom for a more focused look at a local area of interest. If you mouse over any terminal you get a pop-up block showing present conditions, and if you click on a terminal you get a really complete display of recent, current and forecast weather for that location. One portion of the display that will prove really helpful is the LAMP forecast. LAMP stands for Localized Aviation MOS Product (and MOS stands for Model Output Statistics). This is a 24 hour forecast, updated hourly, that gives guidance on what weather to expect for a planned flight.

The March 2010 issue of The Front, mentioned above, has a great article called "Using LAMP Guidance in Flight Planning" that makes it all simple.

In case the CWSU site you're interested in doesn't yet offer the LAMP forecast, you can get to it through the LAMP program home page.

And, while you're at the CWSU site, be certain to explore the links listed in the left sidebar. These connect to a number of very valuable weather products, some of which may be new to you.

I expect to be a regular visitor to the CWSU sites and to make use of the LAMP forecasts as I plan my weekly trips between Connecticut and the DC area.

One last thing. You need to send an e-mail to Melody Magnus asking her to put you on the e-mail notification list for future issues of The Front. That way, you'll get to the Good Stuff right away.

Clearance Roulette (cont'd)

The ATC computer seems to have trouble getting N631S and me a workable clearance for our Monday morning trips from DC to Connecticut. As usual, there's a back-story to the tale.

Early on, I would file something like:
POLLA V312 GOLDA V268 ENO V16 JFK V229 PUGGS at 7,000 feet.

I learned very quickly that I'd be required to descend to 5,000 feet approaching ENO if I wanted that routing. Period. And that was annoying because I'd just used all the AvGas needed to get up to 7,000 where the air was clear and the tailwind stronger.

But a helpful Dover Approach controller told me that if I would accept direct LEEAH V1 JFK etc. I could stay at 7,000. So I started to file for this route:
POLLA V312 GOLDA V268 LEEAH V1 JFK V229 PUGGS

That's the red line on the graphic above. The V16 route includes the segment shown in green from ENO past VCN and up to CYN.

The route from ENO via LEEAH and V1 works well for me, but the ATC computer seems to have a bit of trouble spitting it out. When I file, and then check the FlightAware.com site to see what routing I should expect, it shows this odd version:
POLLA V312 GOLDA V268 ENO V268 LEEAH V1 JFK V229 PUGGS.

What is the point of inserting ENO into the middle of V268? (ENO is the Smyrna VOR near Dover AFB.) I got a hint this morning when I telephoned Mount Vernon Flight Data to pick up the clearance. The controller said, "Can you hold on for a minute? You have a "pref" route out of my airspace and a "pref" route into New York and I have to get them to mesh." A few minutes later he came back with this:
POLLA V312 GOLDA V268 ENO V16 JFK thence As Filed.

Well, that's not what I want! That's going to make Dover Approach issue me a descent to 5,000. But I accepted the clearance with the intent to try and work something out en route.

As soon as Potomac Approach told me to contact Dover I switched frequencies and said, "Good morning Dover Approach, Skylane 631 Sierra level at 7,000 with a request."

This got me, "Skylane 631 Sierra, Dover Approach. Dover altimeter 29.64, say request."

Me: "Skylane 31 Sierra is cleared after Smyrna, Victor 16 to JFK. Requesting after Smyrna, Victor 268 to LEEAH then Victor 1 to JFK and maintain 7,000."

Dover: "I have your request."

About three minutes later, the Dover Approach controller was back with a routing change. He cleared me present position to ENO, thence V268 LEEAH V1 JFK, rest of route unchanged. Perfect.
But it seems like a lot of effort to do something that ought to be simple.

Well, that's IFR flying in the Northeast.

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Since I make these trips every week, I guess some of the controllers are getting used to me. I had the following exchange upon checking in with Atlantic City Approach:

Me: "Good morning, Atlantic City Approach, Skylane 631 Sierra, level, 7,000."

AC Approach: "Skylane 631 Sierra, it must be Monday. Good morning, Atlantic City altimeter 29.62."

Me: "29.62 for 631 Sierra and yes, it is indeed Monday."

Some Fuelish Thoughts

The fuel situation is attracting lots of attention again and generating ample discussion around the aviation blogs and boards. It looks like there is a consensus forming that the EPA and FAA are serious about establishing a definite sunset for 100LL aviation gasoline. And so, the hand-wringing and finger-pointing over how we got here, and what will be the impact of 100LL's demise and what will happen next?

Reportedly, EPA officials are saying that a notice of proposed rulemaking (NPRM) could be seen as early as October 2010, with a targeted phase-out date of 2017. If that's accurate, an additional seven years grace doesn't seem too bad, especially considering the length of time that we've enjoyed the protected status of AvGas as the only lead containing motor fuel available in the US. But we really do have to get serious about figuring out what's next.

The piston-powered segment of general aviation is at a fork in the road. One path involves developing one or more alternate lead-free 100 octane fuels. The other path requires development of power-plant modifications to allow all of the fleet to function with fuel providing significantly less than 100 octane performance.

This is somewhat like the chicken and the pig discussing the ham-and-eggs breakfast, where the chicken is interested and the pig is involved. Some engines will run just fine on lower octane fuels. Like the chicken, their owners get to watch all this with mild interest. But N631S and I find ourselves in the role of the pig, since our O-470-U engine has an 8.5:1 compression ratio and an aggressive timing specification. It's unlikely to be happy with much less than 100 octane.

This point was made pretty emphatically by TCM's chief engineer, Bill Brogdan, in an AvWeb podcast wherein he describes Continental's testing of legacy engines on reduced octane fuels. They've been surprised to find that the worst performers are not the fire-breathing turbocharged engines but rather, the high-compression normally-aspirated powerplants. Like my O-470-U. Hmmm...

TCM seems to feel that the only thing close to a "sure bet", if 100LL is indeed going away, is a 94 octane lead-free fuel (94UL) that is essentially 100LL with the lead taken out. They are working on ways to keep the legacy fleet flying on that fuel. Unfortunately, their answer for the normally-aspirated engines seems to be to reduce the compression ratio. This is major surgery (essentially a "top overhaul" with add-ons and lots of $$$$) and would entail a significant reduction in horsepower. It's not a pleasant prospect.

The folks over at Textron-Lycoming are of the opinion that it's really important to develop a 100 octane solution and they are much taken with the G100UL fuel being proffered by the clever folks at GAMI (George Braly and friends). In February, General Aviation News offered a good summary article describing the G100UL project. By all reports, the fuel performs nicely as a substitute for 100LL and, very importantly, can be mixed with 100LL in any proportion without unpleasant consequences. This is a vital consideration for any transition between fuels.

Another alternative, which I blogged about last September, is SwiftFuel from Swift Enterprises (Dr. John Rusek's venture) in Indiana. Like G100UL, SwiftFuel seems to perform nicely as a 100LL replacement and seems fully compatible with the current leaded fuel.

Both of these lead-free alternatives are undergoing continued testing. Both are beginning the lengthy and difficult ASTM certification process. In addition, George Braly is trying to convince the FAA to allow certification of G100UL for certain airframe and engine combinations under the STC process. The FAA is reported to be unenthusiastic with respect to this option.

Either or both of these alternative fuels may represent viable options for life after 100LL. The economics of both are still subject to investigation. One or the other may fall by the wayside; one or the other may prove to be just what the doctor ordered.

If both fuels turn out to be technically and economically viable, it's worth remembering that SwiftFuel is not a petroleum product. As a bio-fuel, it may help general aviation to move in a "greener" direction, a benefit that G100UL would not offer.

But what if neither fuel works out - whether for technical or economic reasons? What do I do with N631S in 2017 (or whenever)? Should I panic now, or wait a few years?

John Frank, who heads up the Cessna Pilots Association (CPA), is one of the "wise old heads" in General Aviation. He's been looking bemusedly at the stir about the 100LL issue and suggests that we all calm down. John points out that a workable solution to this issue has been around for about 70 years. In a message to CPA members, John tells us that:

It is called Anti-Detonation Injection (ADI). It was developed before World War II and was used on some fighter and cargo aircraft well into the 1950s. Basically at high power settings a water/methanol solution is injected into the induction system. The injection of this fluid cools the fuel charge, and increases the density thus permitting more fuel to enter the cylinder. As the water/methanol solution vaporizes it absorbs heat which further reduces the combustion temperature and the amount of heat transferred to the cylinder head. The alcohol in the fuel charge burns but is more resistant to detonation than even 100LL avgas.

Is ADI the perfect solution to the problem of lower octane unleaded fuels in our aircraft engines? No, of course not. There is an expense and an added system to the aircraft that must be operated and maintained. A fuel that is a direct replacement for 100LL would probably be the perfect solution, but so far that has not appeared.

Is ADI the best solution available? Maybe yes, maybe no. Probably depends on what fuel the industry can develop between now and when 100LL is no longer available.

The point is that ADI is a workable solution of proven technology that can be made to function on just about any aircraft/engine combination. So to those in the industry who are running around shouting "The sky is falling, woe is us." I say "Get a Grip." There is a workable solution and it has been there all the time.

That sounds like a good Plan B to me (Plan A being development of a viable 100 octane lead-free fuel). I'm going to calm down and go flying!

(Further) Thoughts on the ELT

A long, long time ago (March of last year, to be exact) I posted some thoughts on the issues surrounding Emergency Locator Transmitter (ELT) technology - specifically the options available after the deprecation of the old 121.5 MHz standard and its supersession by the 406 MHz standard. I took note that just keeping the 121.5 MHz "brick" in the airplane met all regulatory obligations under the FAR's. Given my typical mission and operating area, I've been fine with that.

It now appears possible that we have been outflanked. My attention has been drawn, by this posting (courtesy of the estimable Comrade E.B. Misfit) to a recently adopted order of the Federal Communications Commission (FCC). Therein (see page 10) the order states:

We therefore amend the Commission’s rules to prohibit further certification, manufacture, importation, sale or use of 121.5 MHz ELTs.

In a footnote to that statement, apparently as an attempted justification of the action, the order explains thusly:

Although this may force some aircraft owners and operators to terminate their use of 121.5 MHz ELTs sooner than they may have anticipated when they acquired the device, and impel them to incur the cost of purchasing a 406.0-406.1 MHz ELT as a replacement, the safety benefits of imposing an immediate prohibition on continued use of 121.5 MHz ELTs outweigh the costs. We note, moreover, that the users of 121.5 MHz ELTs have been on notice of the need to transition to 406.0-406.1 MHz ELTs for a long time.

Let us pause for a moment to consider the situation of an aircraft owner who has a 121.5 MHz ELT sitting dormant in the tailcone of the airplane. So far as this device is concerned, what is the meaning of the FCC's prohibition on "use"? As a practical matter, it would seem that the device may not legally be allowed to transmit any signal on the frequency 121.5 MHz. There is no prohibition on possession of the device, and I choose to store mine in the aircraft. Of course, I promise not to "use" it.

Now, of course, the operations of our aircraft are not governed by Part 87 of the FCC's Rules Concerning the Aviation Radio Service. They are, rather, governed by the FAR's and in this particular, by 14CFR91 Subpart C Section 91.207. This section requires that we have an approved ELT attached to the aircraft, describes the preferred manner of attachment and specifies the protocol for replacement of the battery. So far, so good. Then, it states in sub-section (d):

Each emergency locator transmitter required by paragraph (a) of this section must be inspected within 12 calendar months after the last inspection for—

• (1) Proper installation;
  
• (2) Battery corrosion;
  
• (3) Operation of the controls and crash sensor; and
  
• (4) The presence of a sufficient signal radiated from its antenna.

Item (4) would seem problematic. I can store my approved 121.5 MHz ELT aboard my aircraft without violating the FCC's rules, and I can stay in compliance with FAR section 91.207 until 12 calendar months have elapsed since it was last inspected. At that time, it must be inspected again and that inspection requires that a signal be radiated; thus it will be used in violation of the FCC rule. Rats!

The issuance of the FCC rule has lead to a considerable dust-up on the aviation boards and blogs, with some folks worrying that 60 days after the rule is published in the Federal Register all aircraft carrying 121.5 MHz ELT's will be grounded. By the above logic, I think not. However, it does appear that the rules as presently written (FCC and FAA) will mandate replacement by the end of the inspection interval with a new 406 MHz device. I've got better places to spend those aviation dollars, but if that's the way it is so be it.

It's also possible that we haven't heard the last word. A flurry of activity can be expected from a somewhat embarrassed AOPA (which seems to have been asleep at the switch) and political strings will be pulled. A delay of a year, or so, in implementation would be unsurprising. But it appears that sooner or later we will all be installing 406 MHz ELT's.

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It occurs to me that there hasn't been much written here the last few weeks about the flying! That isn't because N631S has been resting on the ground, but rather because the flying - which continues at the usual pace - has been remarkably uneventful. It's been rather pleasant, but not very productive of blog-worthy events. I'm certain that this is temporary.

Send in the Drones?

There can be no doubt that we are being prepared for the day, not very far off, when we will be sharing the skies with Unmanned Aircraft Systems (UAS), also known as drones or remotely piloted vehicles (RPV's). According to a recent Associated Press article, the FAA is coming under heavy political pressure to admit UAS's to the national airspace:

Texas officials, including Gov. Rick Perry, Sens. Kay Bailey Hutchison and John Cornyn, and Rep. Henry Cuellar, have been leaning on the FAA to approve requests to use unmanned aircraft along the Texas-Mexico border. ...

Homeland Security Secretary Janet Napolitano has told lawmakers that safety concerns are behind the delays. Cornyn is blocking a Senate confirmation vote on President Barack Obama's nominee for the No. 2 FAA job, Michael Huerta, to keep the pressure on.

Other lawmakers want an overall plan to speed up use of the planes beyond the border.

There are, to put it mildly, safety concerns. In the same article, the FAA's head of air traffic operations, Hank Krakowski, is quoted as saying:

I think industry and some of the operators are frustrated that we're not moving fast enough, but safety is first. This isn't Afghanistan. This isn't Iraq. This is a part of the world that has a lot of light airplanes flying around, a lot of business jets."

In April 2008 the National Transportation Safety Board held a 2-day Unmanned Aircraft Systems Safety Forum discussing the safety issues surrounding integration of UAS's into the national airspace. The forum was organized in the aftermath of a mishap two years earlier when an RPV operating in civil airspace suffered the loss of both power and communication due to operator mis-management and subsequently crashed. The NTSB Final Report reads like one of those "nothing can go wrong...go wrong...go wrong..." scenarios.

Of course, the FAA is reacting to the pressure. Now comes the May/June 2010 issue of the publication FAA Safety Briefing, offering on page 20 an article titled "Eye in the Sky." The subtitle is "Assuring the Safe Operation of Unmanned Aircraft Systems." The article observes that:

[D]espite the numerous environmental, economic, and safety benefits of UAS, there remains an underlying, and understandable, apprehension of how these “flying robots” will perform alongside manned aircraft, especially during an unexpected event or emergency.

In discussing this apprehension, the article reviews ongoing FAA research regarding the characteristics and behaviors of UAS's, and acknowledges the need to address the "sense-and-avoid" (sic) issue.

Of course, the "sense-and-avoid" issue (which used to be called "see-and-avoid") is the elephant in the room. Here's what an executive of Insitu, Inc. (a Boeing subsidiary in the UAS business) has to say:

While we don’t have a pair of eyeballs on the aircraft, there are several feasible alternatives that need to be tested and evaluated.” Existing test data show current ground-based radar and TCAS systems are able to pick up nearly any vehicle within 12 to 15 miles of a UAS. “By working with the FAA, we’re seeking to obtain the safety ‘street’ credit for these systems, along with rules that permit reasonable access.”

Isn't that nice. We will supplement the UAS's on-board sensor suite with radar data (and, no doubt, ADS-B Out product - another reason to press on with NextGen) so that the robot can "sense-and-avoid" threat platforms. It is unclear how that is going to help the VFR pilot in the Cessna 172 who is squawking 1200 and not talking to ATC to understand that he is potentially in conflict with an aircraft that has only a limited ability to react to his presence. And that doesn't begin to account for the NORDO J-3 Cub or the sailplane or the hot air balloon, any of which may or may not be "sense-able" by the UAS's "sense-and-avoid" systems.

As if "see-and-avoid" were not already sufficiently problematic as a collision avoidance strategy (see, for example, the circumstances surrounding the mid-air over the Hudson in the summer of 2009) we would now shift most of the burden of "seeing-and-avoiding" to the general aviation pilot with the degree of difficulty increased by the typically small size of the UAS.

A few conclusions can be drawn. First, it is apparent that there are political and economic forces in place that are strong enough to ensure that This Will Happen. UAS's are coming to an airspace near you.

Second, it would seem that the only way to accommodate UAS's in the National Airspace System without unacceptable risk is to understand that any airspace in which they operate is de facto Restricted Airspace. As with the Restricted Areas that we're already familiar with, IFR traffic can be separated from UAS operations by ATC; VFR traffic will have to avoid the airspace. Check NOTAM's!

The alternative would be to require UAS's operating in unrestricted airspace to carry Visibility Enhancement Systems to give pilots a fighting chance to see them and avoid them.

• Light 'em up like a Christmas tree!
  
• A colored smoke trail would be nice.
  
• While we're at it, restrict them to 140 knots.
  

Of course, that would eliminate any thought about stealth. The border patrol probably won't like that.

The FAA is planning to publish a Special Federal Aviation Regulation (SFAR) that will govern operation of small (under 55 lb.) UAS's in commercial airspace, by mid-2011 with a final rule
expected in late 2012. That one will bear watching.

The Fallacy of Safety

Let me begin by affirming that I am a great admirer of Ms. Deborah A.P. Hersman, the Chairman of the National Transportation Safety Board (NTSB). It seems to me that she well understands the power of moral suasion at her agency's disposal, and she makes good use of the bully pulpit that her office provides.

Given my admiration of her, I was taken aback and disappointed when, in her opening remarks for the Board's recent forum on Professionalism in Aviation, Ms. Hersman said this:

"[T]he American people rightly demand not 99-plus percent safety, they demand 100% safety."

Of late, we are daily reminded that we engage as a society in high-risk endeavors. Whether we are speaking of an aviation mishap or a major casualty in some other technology-intensive field, we understand that some combination of carelessness, incapacity and neglect tipped the balance from "ops normal" to catastrophe. The systematic defenses that had been designed to save the day were overwhelmed. And people died.

Predictably, the cries for safety ring out across the land. Managements and regulators are faulted because they failed to ensure that the operations were safe. We must be able to assure the public that they will be safe! Tell me, please, what does "safe" mean?

The dictionary teaches that "safe" means "secure from liability to harm, injury, danger, or risk." So, to render an activity safe, must we reduce the "liability to harm, injury, danger, or risk" to essentially zero? Is that to be our goal?

"A ship in harbor is safe, but that is not what ships are built for."

-- John A. Shedd, educator, Salt from My Attic, 1928

If, in our economic activities, we are to venture out of the harbor and onto the stormy seas of real life, we have to realize that there will be risk, there will be danger, that we shall go in harm's way. We cannot be safe.

Let me repeat that: We cannot be safe! Ever! To live, is to live with risk. To "demand 100% safety" (in Chairman Hersman's words) is to be at best naive and at worst a fool.

"Insisting on perfect safety is for people who don't have the balls to live in the real world."

-- Mary Shafer, NASA Dryden Flight Research Center

If we will wrap our minds around this simple, somewhat discomforting truth, perhaps we can abandon the fallacy of safety and start to think seriously about risk mitigation. To live in the real world, we need to understand the sources and magnitudes of our risks. We need to think through ways to avoid or to counteract them. And we need to so order our lives that adequate countermeasures will be at hand whenever danger looms.

Risk mitigation is always purchased. We must decide how much of it we wish to pay for. The calculus, whether explicit or instinctive, involves evaluation of the likelihood of mishap and the cost of consequences.

When the potential cost of failure is very high (say, a nuclear plant core melt-down) there is almost no limit to the risk-reduction budget. When the cost of failure is less extreme (as with aviation systems, where at worst a few hundred people are at risk) then we will spend a lot to reduce risk, but not an unlimited amount. We just can't afford to reduce risk in aviation to the level where it must be in nuclear systems.

Once the calculus of risk mitigation is completed and appropriate safeguards are in place, it's essential to avoid deviations that introduce unmanaged risk factors. There are always pressures, economic and political, to allow a risk in "just this once". And then if no mishap occurs, well, it must be all right to accept that risk routinely. That's called "the normalization of deviance," and we lost two space shuttles that way in spite of supposedly nuclear-quality risk management systems.

When the public asks of us, "Is aviation safe?" we can't honestly say, "Absolutely!" We have to answer: "We understand all of the risks and we take measures to deal with them. And we work every day on doing it better." And it has to be the truth.

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Further reading: Prof. Sharon Beder, 'The Fallible Engineer', New Scientist, 2nd November 1991