Fatalities due to loss of instruments in IMC can be avoided if the FAA would allow "experimental" EFIS units ($2500 with 2-hour battery backup) installed on certified aircraft. This draft letter, intended to go across the chain of command of the FAA, makes the pitch:
Dear _______________: Lives are lost every year when aircraft in instrument meteorological conditions (IMC) impact the ground after losing their instruments due to engine or electrical power failure. Now, breakthrough technology has resulted in an inexpensive instrument which can save virtually all of these lives. With no downside. In a perfect world, the FAA should be requiring such instruments aboard instrument-certified aircraft. Instead it prohibits them.
I am seeking your help in removing this prohibition. At this point, all I want is for you to look at this subject, not act on it. I believe that when you assess this matter, you will not only conclude that it is a no-brainer, but your conscience will urge you to act. Incidentally, I have worked on FAA programs (see footnote) and no one is suggesting that it will be easy.
First, you need to know that I have no financial interest in this. I'm an engineer with 30 years experience in satellites and aviation who sold his company, was able to retire early and then satisfied a life-long dream of becoming a private pilot. And my interest is not even personal, since I am a VFR-only pilot.
Second, all you need to do is take a harrowing look at an IMC fatal accident to feel a great sense of despair. One such accident (click for details) occurred only a few months ago. In it, the pilot of a single engine Cessna P210 in IMC starts losing an engine at 19,000 feet. Despite substantial and effective assistance from ATC for a prompt descent, the pilot loses all engine power, loses his instruments, reports "difficulty maintaining control of the airplane in this IMC" and soon loses his life when the aircraft impacts the ground. Without vacuum for his standard instruments, maintaining directional control in IMC was almost impossible. These types of accidents happen all the time. But they can be avoided.
Third, then, is to look for a solution. And here we are fortunate. At least two companies (Blue Mountain Avionics and Dynon Avionics) make Electronic Flight Information Systems (EFIS) in the vicinity of $2,500 which are self-contained and provide an hour or more of operation on backup batteries. Using breathtaking but proven technology, these solid-state units have all components housed in a standard 3 1/8" round package. They connect only to the power bus and to the pitot/static plumbing, requiring no vacuum. And the wealth of information they provide is stunning, considering their small size, low power consumption and moderate cost. In the figure you can see that the unit gives attitude, airspeed, altitude, vertical speed, compass heading and turn rate. It even provides turn coordination with lateral ball acceleration.
Fourth, we need to ask if there is any downside to allowing these instruments to be installed on certified aircraft solely for reference and backup purposes. When you consider the all-solid-state design (eliminating mechanical and moving devices such as gyros) and the low power consumption (typically 8 watts, 20 watts if the internal battery is charging), it is immediately evident that inclusion of this instrument will not adversely affect an aircraft. Especially considering that the standard installation will be via a fuse or breaker.
Fifth, we need to ensure that pilots who have these instruments on certified aircraft use them only for reference and backup, not as primary instruments. One solution is to placard the instrument. A better one is for the instrument to have a start-up sequence where the pilot has to accept these conditions of use before the unit will activate. In the example shown at right we have also included an indemnification and release statement protecting the manufacturer, to deal with the point in the next paragraph. The "reference and backup only" statement is also displayed on subsequent screens, as was shown on the first figure above.
Sixth, getting the FAA to allow the use of these units on certified aircraft is not enough. We need to provide an environment where the units can continue to sell at these prices. We want to avoid the certification costs and liability concerns that in many instances force a manufacturer to more than quadruple the price of its units for certified aircraft. The solution is to allow these units -- without certification, specifically labeled as "experimental" and modified only to incorporate the start-up sequence described above -- to be installed in certified aircraft. Again, a review of the design, construction and performance of these units over years of use in experimental aircraft will show that they are reliable products which will not adversely affect aircraft and which can be approved for installation now, without certification. Retaining their "experimental" label has two advantages. First, it strengthens the "reference and backup only" condition of use. Second, it substantially relieves the liability concerns of manufacturers, with the users accepting that they, not the manufacturers, will be responsible for any damages and claims resulting from an accident.
Lastly, we want to suggest two approaches to convince the FAA. In one approach the FAA recognizes that technology -- and common sense -- have outpaced its well-intended refusal to allow non-certified products on certified aircraft, and makes an exception in this case. This is the preferred approach, allowing the FAA to herald that it has entered the 21 century, that it is willing to change decades-old policy when technology and other factors warrant it. But if resistance within the agency threatens these goals, then there has to be another way. One of them is to use the scheme employed by sellers of traffic alert devices, which plug into the cigarette lighter of aircraft to circumvent the prohibition of using non-certified devices connected to the power bus of a certified aircraft.
In any event, an effort must be found to achieve this life-saving objective.
In the end, all we seek is a single-sentence statement from the FAA identifying these units and stating "When installed per the manufacturers' directions, these experimental units may be installed in certified aircraft for reference and backup use only, via the standard Form 337 process."
_________________
* Ernie Martin has Bachelor's and Master's of Science degrees in Engineering (the Master is from Caltech). He spent nearly 20 years in satellite communications and 10 years in the jet engine business. He has worked on FAA projects and for a time worked directly with John McLucas, former FAA administrator. He has also consulted for various companies, including GE, and currently heads ConsultResearch, Inc. Based in Miami, he frequently flies his 1973 Cessna 337G Skymaster over Caribbean waters and has flown his previous Skymaster on search-and-rescue (SAR) missions over the Florida Straits and on a trip across the United States. He may be reached at.