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EAA Government Advocacy

An Hour is Not an Hour

Current Measurement Creates Bias Against Homebuilts - The FAA's newly issued Advisory Circular 90-109, Airmen Transition to Experimental or Unfamiliar Airplanes, states that in 2009, accident data indicated that while experimental airplanes are involved in approximately 27 percent of fatal accidents in the United States, they fly only 3.4 percent of the total GA fleet hours. FAA Administrator Randy Babbitt also cited this statistic during a GA Safety Media Roundtable in March.

There’s danger in using numbers without context, making an unwarranted target out of amateur-built aircraft. The numbers, standing alone, may be accurate based on GA survey data. However, measuring accidents-per-hour-flown is fundamentally flawed when comparing types of flying. That’s where the context is important.

An hour in a large GA airplane, used primarily for cross-country flight, is not directly comparable to an hour in an experimental amateur-built aircraft used for recreational flying. It would be akin to comparing an hour driving a motorcycle on a racetrack to an hour in a semi-truck on an interstate highway in the Great Plains. The two situations simply are not directly comparable, and the FAA must acknowledge that fact.

A typical hour of a GA corporate or business flight more than likely would be at a certain flight level, flying direct with the autopilot engaged. Alternatively, within that same hour, a recreational aircraft could have been to several airports, made numerous touch-and-goes, while maneuvering the entire time. The operations are, in no way, comparable. Yet this is exactly how the FAA is measuring safety.

In 2010, 941 amateur-built airworthiness certificates were issued. If all of those aircraft completed the 40-hour Phase 1 test-flight period, they would account for more than 37,000 hours! Yet these hours are compared to corporate or business flying, even though the test flights contain higher risk and required tasks and are conducted in remote locations to protect persons and property on the ground.

It would make considerably more sense to base GA safety metrics on a per-flight basis. EAA acknowledges, however, that such data is currently difficult-to-impossible to attain. The current hour-to-hour comparison is biased by systematic differences in typical flight durations and activities associated with subcategories of GA. EAA, along with the General Aviation Joint Steering Committee’s Safety Analysis Team—of which EAA is a member—has identified the need for improved GA safety metrics and is working toward that goal.

Until that work is complete and a more accurate GA safety metric can be obtained, comparisons must be properly framed and acknowledge the shortcomings of using a per-flight-hour metric based on GA survey data.

Local Decisions Still Better for Through-the-Fence

Revised FAA Policy permits the continuation of existing residential through-the-fence (TTF) agreements through 2014 when the policy will be reviewed again, subject to certain standards. Prior FAA policy discouraged TTF access to federally obligated airports from off-airport residences. The interim policy seeks to strike a balance by accommodating residential TTF access where it already exists, but not allowing new agreements.

EAA’s long-standing position, however, is that local airports should be able to make the decision regarding residential TTF access agreements based on local conditions, the community, and projected funding received from homeowners. With FAA policy prohibiting new residential TTF arrangements, it creates another barrier to growing aviation. EAA has worked to include language in the House FAA reauthorization bill that would permit local airport sponsors to determine the appropriateness of TTF access at their own facility.

No Labels No Auto Fuel

For the 60,000 pilots holding an auto fuel supplemental type certificate for their airplanes, ethanol and flying do not mix. Obtaining auto fuel without ethanol is absolutely essential for safe flight. EAA members go to several gas stations to find premium auto fuel that does not contain ethanol.

That’s why a bill in the Nebraska state legislature that would eliminate labeling requirements for ethanol-blended fuel at local gas stations is a bad idea. The bill’s sponsor contends that ethanol is only one of nearly 300 chemicals that compose gasoline. EAA counters that ethanol is the only one of those 300 that could cause an aircraft’s engine to fail during flight. EAA members in Nebraska have been busy contacting their local representatives, asking that at least one grade of fuel remain ethanol-free and is clearly labeled as such.

FAA Announces Moratorium on New Living History Operating Exemptions

The FAA recently announced a moratorium on issuing any new living history flight operating exemptions. The purpose of the moratorium is to allow the FAA to update its policy, governing the types of aircraft allowed to operate under these special exemptions carrying passengers for hire. EAA’s B-17 currently operates under such an exemption and will not be affected by the moratorium on new issuances. EAA is urging the FAA to work collaboratively with owners of historic aircraft in developing this new policy.

GA Caucus Back Over 100 Members

With each new Congress following an election, House caucuses must be re-established and representatives solicited for membership and participation; in other words they start from scratch. Previously the House General Aviation Caucus was one of the largest, with 135 members. Although there is a new Congress, there is good news already. Because of the efforts by EAA and other aviation organizations, as well as lawmakers such as Rep. Sam Graves (R-Missouri) and Rep. John Barrow (D-Georgia) and their staffs, the House GA Caucus now numbers more than 100 members once again. This is essential to all of us, as it means that nearly one-quarter of all members are part of a House group that specifically discusses GA issues.

Transition Training is Key in Moving the Safety Needles

EAA is interested better understanding the key factors leading to amateur-built aircraft accidents as part of our commitment to continually enhancing safety within that community. As you have read on the previous page, EAA is concerned with the current FAA safety metrics and is actively engaged with a new Safety Analysis Team. This team is a working body under the GA Joint Steering Committee (GA-JSC), with a goal of clarifying what the accident data is truly telling us.

But that is not all. During the past year, EAA has co-chaired an FAA Flight Standardization Board that examined amateur-built safety and developed a targeted strategy for improving our record. This FAA/industry group developed the content of a new FAA advisory circular aimed at providing transition training guidance to new builders and second owners.

Transition training is a critical part of being a safe pilot. It does not matter what level of experience a pilot has. Transition training is a must for every pilot moving to a new airplane. At the core of a good transition training plan is a quality flight instructor and the use of a well-thought-out curriculum.

The new FAA advisory circular, AC 90-109, is a first step toward developing that transition training plan. It provides detailed guidelines for those seeking to transition to a new type of aircraft. It separates the possible aircraft types into “buckets” arranged by similar flight characteristics. Based on these “buckets” the AC gives the basis of a training plan and the beginnings of a quality transition program. Armed with this information, one has to only seek out a qualified CFI to put that plan into practice. Add a few hours of training time and, voilà, you have a successfully transitioned pilot ready to safely act as pilot in command.

If we as a community embrace the importance of seeking a well-thought-out transition training plan, we will see an improvement in safety, and that is what I call a needle-mover!

Government Relations Briefings

Read more about out what else is happening in the world of EAA's government relations.

EAA's Government Relations department works to preserve the freedom of flight and reduce the regulatory barriers affecting affordability and access to EAA members’ participation in aviation. Protecting the freedom to fly is the foundation on which all of the organization’s advocacy initiatives are built. EAA fights to preserve this freedom by providing clear solutions and practical alternatives backed by hard work and dedication. EAA’s 55-year history of success is a testament to that philosophy.

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