USA Today "Unfit for Flight"

There has been a lot of discussion in the aviation community about this 3 Part Expose' Series in      USA Today - Most of our aviation community agree that - we should strive to make aviation safer.  Most of us on this side of the fence,  also agree that the condemnation of manufacturers in this industry was - just a little slanted.  I happen to know several of the players and the other side to many of the examples and lawsuits presented.   It is not as cut and dried as the articles suggest.

Mr Bertorelli - who I respect as an aviation journalist and pilot - made several good points in his Blog  As most people are aware - Aviation is the "most regulated business in the world".  In this industry we laugh at drug and medical device companies - because they have it easy.    In this environment how could an outside news agency find fault with our industry.    Given the economics of this particular business,  it isn't profitable to do a bad job.   Paul stated all of this in his blog very clearly:

There’s wide agreement that over regulation has had a hand in getting us into this mess, so further regulation — of manufacturers or more stringent training requirements —won’t get us out of it.   The entire community just doesn’t have the stomach for it. And neither do I, frankly.  Not to mention the utter lack of any economic engine to drive it all.

I was however struck today with one of Mr. Bertorelli's responses to this safety issue - and because an element of the rebuttal involved a segment of the aviation industry that I have become quite familiar.

At this point, we work on fuel level systems in aviation and most recently the automotive industry.

We have a unique but very narrow viewpoint.

GA Safety: All Heat, No Light

Excerpt from Paul Bertorelli's Blog 

As a refreshing change, the USA Today report almost tried to cast pilots as steely eyed but hapless victims of shoddy manufacturing and outdated aircraft designs. Were it only so. None of us have to look in the mirror to know that although out-of-the-blue mechanicals do cause accidents, preventing every one of that category wouldn’t change the accident rate much.

Even in some of the egregiously poorly prepared reports, the pilot obviously did something stupid—like flying into bad weather, overloading the airplane or, a perennial favorite, running the tanks dry because the fuel gauges aren’t accurate.  

That last item is a cultural thing in which automotive knowledge contaminates aviation thinking. It’s like that GEICO commercial; everybody knows the gauges aren’t accurate and we have means to work around this deficiency. 

Using a crash as a means of highlighting it seems somehow unsporting. Yeah, the stupid gauges should work, but no, they don’t.  So buy a totalizer or learn to use a watch.
But unless you, as the owner or pilot, take personal responsibility, your 35-year-old Cessna 172 is not going to be fitted with more accurate fuel gauges. 

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Unfortunately neither the NTSB or FAA equate "Bad Fuel Gauges" to Fuel Exhaustion,  but it is interesting that Paul does state this in his blog.  It is quite common to report to the NTSB or FAA after an accident that the fuel gauges are not accurate in your damaged aircraft.  There is no consequence to those statements.  If your flight plan did not indicate average fuel burn - look out.  

I also agree that fuel level is a cultural thing in aviation - I am not familiar with the GIECO reference Paul equates - but fuel level in automotive applications is barely adequate, the website tankonempty.com illustrates this very well.  The issue in aviation, is that for most small aircraft, the fuel level system was taken from a ground vehicle system, think automotive, tractor, truck - This system, was barely adequate for an automotive application as illustrated by the website above  - and this system really struggles with fuel quantities that are 3 times larger, and the fuel and vehicle movement that occurs in aviation.

When we talk to people outside aviation - and we state things like Paul's statement "Yeah the stupid gauges should work, but no, they don't"     - they look at first puzzled and then to a each non aviation person we have stated this quizzes us back "Don't small aircraft run out of fuel"  Yes they do. 
   The National Highway Transportation and Safety Administration - NHTSA in a recent automotive recall for bad automotive fuel fuel gauges on Chevrolet Trucks stated that the there was an obvious safety issue with having bad fuel gauges  - specifically from the recall announcement:

"If a customer runs out of fuel without any warning from the fuel gauge, it will cause the vehicle to stall and increase the risk of a crash, the company said."

In aviation, as Paul Bertorelli stated for fuel level  - "we have work arounds". 

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As I am focussed on a small aspect of the aviation safety issue - and this is seemingly the common aviation response to a significant issue. 

Because from where I am sitting -  maybe the pilot of the 35 year old Cessna 172 should at the least have the fuel gauges checked and calibrated at annual. 

If the gauges are too far gone - he should have the maintenance facility send in a Service Difficulty Report to the FAA - let the Feds know we have an issue out here in the field.   Let's quit making excuses or work arounds for equipment that should and by law be required to function correctly. 

I think we as a community should start questioning these common assertions and take off the cultural blinders.  

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I think we all want to make aviation safer - including USA Today.

Fuel Gauge INOP for initial CFI Check Ride

A Posting from Pilot Instructor Forum 

Hi all,

I am taking my initial CFI check ride this weekend. I went out to fly the airplane (C-R182) from the right seat to practice some maneuvers before the check ride. But, I realized the left fuel gauge is indicating zero no matter how much fuel is in the tank.

It sounds to me like the issue is somewhat controversial. I've heard "fuel guages only need to be accurate when the tank is are empty" and I've also heard that per 14 CFR 91.205 (b) 9 the airplane needs to be equipped with an operable "Fuel gauge indicating the quantity of fuel in each tank".

I tend to agree that the fuel gauge needs to be operable, but there's no time to get the fuel gauge repaired before the check ride. Any advice?

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Yes, per §91.205 a fuel guage for each fuel tank is required for day / night VFR and IFR flight is required to be operational.
You could argue as others did that it only has to “correct” when on empty and I would agree but it has to read something. The other way of looking at it is that the fuel guage has to read something other than empty when their is fuel in the fuel tank.
If your airplane has an approved MEL, it might be allowed to be inoperative provided you verify the amount of fuel in the tank, but for your initial CFI test do not take a chance of busting because of an unairworthy aircraft.

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Remember the Tomato Flames acronym.  F is for fuel gauge.  You must have a functioning fuel gauge.  The acid test is safety.  Do you feel safe flying an airplane with an inop fuel gauge.  I would tend to want to get a ferry permit to get it to a repair facility, or better yet, get it fixed where it sits if you can.  There are too many fuel exhaustion accidents (preventable) per year to take a chance like this.  I know this sounds a little over-reaching, but as a CFI, you are the prime example to the flying public.  To show your willingness to take a chance on an inop fuel gauge sends a dangerous example to your potential students that the Pilot Examiner or FAA Safety Inspector should flunk you for.  Get it fixed then take your exam.

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“I tend to agree that the fuel gauge needs to be operable, but there’s no time to get the fuel gauge repaired before the check ride. Any advice? ”Seems like a no-brainer to me.  You have an unairworthy airplane you’ve been training in and you’re contemplating taking a checkride in it?  for a CFI? BTW, Part 23 says the fuel gauge must be *calibrated* to read 0 when there is no usable fuel in the tank.  Being calibrated to read 0 doesn’t mean that this is the only indication that needs to be accurate.  All scales must be calibrated at a certain weight, and the error increases the further away from that weight that you get.  Even so, the error is usually required to be within a certain range.  Part 23 doesn’t publish that range, but likely there is one.  Someone I know has requested an LOI on the topic from the FAA’s General Counsel’s Office, but it won’t be available until October.

Note: That letter was not published by the FAA General Counsel 
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In reading the above responses a couple of thoughts come to mind.  While by regulation the fuel indicators must function, relying on them for anything other then an indication of possible fuel present is more dangerous then not having a guage at all.  Our flight school had 36 aircraft and there wasn’t a guage in any of them that was even close to accurate.   Many times a student pilot or CFI would request fuel for a plane by reading the guages (without comfirming visually) only to find the tanks topped off.   And conversely, taking off with what they thought were full tanks only to land an hour later with one tank dry.The comment:” There are too many fuel exhaustion accidents (preventable) per year to take a chance like this.  I know this sounds a little over-reaching, but as a CFI, you are the prime example to the flying public.  To show your willingness to take a chance on an inop fuel gauge sends a dangerous example”

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While I wholly agree with the assertions that physically checking and monitoring the fuel quantity using known values is the best practice, the reg is very clear about what is required to be working at all times.  If you fly with a fuel indicator broken (which it clearly is), then you are essentially shooting yourself in the foot.  Yeah, you might get away with it, but then again, you might not.Also, in regard to MEL’s, 91.213 is very specific that any equipment required to be in operation by regulation (such as 91.205) by default can’t be included among the inoperative equipment in an MEL.

Flying with an Inoperative Fuel Gauge - Legal or Not?

A Forum Dialogue about Fuel Gauges in Aircraft

I'm not sure where to post this so I guess I'll just post it here.

So today while pre-flighting my club's 172. I flipped on the master switch to check the fuel gauges. The right fuel gauge, indicated correctly. While the left fuel gauge however, was pegged on empty, even though there was full fuel in the left tank.   I know that fuel gauges should only be accurate when they are empty,  however under 91.205 it states that an operative fuel gauge(s) indicating the quantity of fuel in each tank has to work for a VFR day flight.

I asked the mechanic and he frowned upon me and gave me a lecture on how "fuel gauges should only read zero when empty blah blah," and that I could still fly the airplane.

Wearily I went and asked of one of the CFI's in the FBO and he told me If there is fuel in the tank and the gauge indicates zero or empty then its just an inaccurate gauge. If however, there is no fuel in the tank and the gauge indicates fuel, then that is an inoperative guage.

My question is, I am legal to fly? And what are you thoughts on this? I really dont want to be nit-picky about regulations on the airplane that I fly but, that is my name going into that logbook and I just didn't want to risk it.
Thanks!

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"You wrote this, so it should answer your question.  A further question could be: What is so critical about flying the particular mission you're seeking to (a pleasure flight), that would require you to go against the above? Especially if something were to happen on that flight that attracted Fed attention, related or even unrelated to the inop gauge? Would the club back you then?"

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"Tell the club to fix their stuff. There's no excuse for that kind of Mx laziness, and allowing it or making excuses for it with the "kick the can down the road" mentality they seemingly have, only perpetuates the problem."

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I'd say no, till it is either fixed or deactivated in accordance with the MMEL.The whole "it only has to be accurate at zero" argument to me is moot, It is currently at zero AND it is not accurate.   A broken clock is right twice a day.

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Dip your tanks and use those numbers in your calculations. Flt time x Rate of fuel burn = Gallons of fuel needed then add in your fuel reserves. I don't rely on what a fuel gauge in a 172 says.

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Personally, I wouldn't fly it. I certainly don't want to nitpick a plane apart, but the thing is, the fuel gauge isn't doing anything *at all*!

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I'd fly a plane that had a gauge reading "some fuel" when there was, indeed, some fuel in the tanks, and reading "empty" when it's empty.

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But having a gauge sitting on "empty" 100% of the time isn't acceptable, in my opinion. What's the point in even having the gauge then? Might as well just draw a picture of a gauge on the panel with magic marker, because it would be just as useful.

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Ultimately, I'd pull the "would you rent this plane to a fed?" question on them. If they wouldn't be willing to show it to a FSDO inspector, they need to fix it.

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Notice where the "zero" comes from. It is a guideline for when the fuel gauge must read zero. This is to keep manufacturers from using zero "total" fuel when calibrating the gauge instead of "usable". Other than that there is no mention of gauge "accuracy" in the reg

Also.
Notice the word "operable" in the Part 91 reg?Is the gauge in an "operable" condition if it is always reading zero? No.

Is the gauge in an "operable" condition when reading inaccurately? No.

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I've talked to the maintenance officer for the club and he said he will check it out tomorrow. But I'll definately crank her over and taxi her next time if it ever happens again. Thanks! For all your guys input, it really helps a lot. I knew it wasn't legal,

But yet for some strange reason the mechanics and CFI's at the FBO had a million ways to explain and get around it.

Aircraft Fuel Mismanagement Cause and Effect

Aircraft Fuel Mismanagement - Cause and Effect

This is what we know about aircraft fuel instrumentation 

• "Maybe they’re also more in the habit of keeping an eye on the clock in flight, even sneaking the occasional glance at those notoriously inaccurate fuel gauges."  
• "Airplanes are legendary for having inaccurate fuel quantity gauges"
• "These devices are notoriously inaccurate, showing empty when there are gallons left in the tank and showing full for the first 1/2 hour."
• "Aircraft fuel gauges can be notoriously inaccurate."
• "Without a means of measuring fuel flow, you must rely on the aircraft fuel gauges or total time of flight. Aircraft fuel gauges are notoriously inaccurate (they are only required by the FAA to read accurately when displaying empty)." 
• "Aircraft fuel gauges have a well-deserved reputation for being unreliable and the FARs only require that fuel gauges read correctly when they are empty!"
• "Second, as others have said aircraft fuel gauges have historically been poorly designed and grossly inaccurate. Many will indicate something significantly different in a climb vs a descent and there are some airplanes with fuel gauges that are designed to read full until a substantial amount of fuel has been consumed."
• "Don’t bet your life on your fuel gauges, visually check the fuel level by “dipping” all tanks. Some aircraft models have notoriously unreliable fuel gauges."
• "All light aircraft gauges are notoriously, infamously and reliably, unreliable."
• "FAA safety guidance information states that fuel gauges are subject to malfunctions and errors, and certification regulations only require that a fuel gauge read “zero” during level flight when the quantity of fuel remaining in the tank is equal to the unusable fuel supply. Therefore, fuel gauges should not be depended upon for checking the fuel quantity in a tank"
• "Sounds great in theory, but I have not yet seen an accurate Cessna fuel gauge, Ever. A fairly expensive AD would be the only thing that would ever change that."
• "Unfortunately, fuel quantity gauges in aircraft are often inaccurate at quantities above zero. While this does not mean that they can be ignored, it does justify the use of another tool to provide a more accurate total picture of the fuel quantity."

... and on and on and on and on and on.

This is who takes the blame.

• "The pilot's inadequate preflight preparation, which resulted in fuel exhaustion, and subsequent loss of engine power during cruise flight."

• "The pilot's inadequate in-flight planning/decision which resulted in fuel exhaustion. A contributing factor in the accident was the pilot's inadequate preflight planning/preparation to ensure an adequate fuel supply was available for the intended flight."
• "The pilot's inadequate preflight planning which led to fuel exhaustion and subsequent loss of engine power."
• "A loss of engine power due to fuel exhaustion during approach, inadequate preflight planning/preparation by the certified flight instructor (CFI)."
• "The pilot's inadequate preflight inspection, which failed to determine the fuel supply in each fuel tank, and his mismanagement of the fuel supply, which resulted in fuel starvation."
• "A loss of engine power due to the pilot's inadequate preflight planning which resulted in fuel exhaustion."
• "The pilot's inadequate preflight planning and his failure to verify fuel consumption during flight that resulted in fuel exhaustion and subsequent collision with obstacles and the ground."
• "The pilot's departure with insufficient fuel for the planned flight, and his improper in-flight fuel management, which resulted in a total loss of power in both engines due to fuel starvation."
• "The pilot's inadequate preflight planning and failure to verify the amount of fuel onboard the airplane prior to departure, which resulted in loss of engine power due to fuel exhaustion."
• "The pilot's inadequate preflight preparation and failure to verify the fuel supply, which resulted in fuel exhaustion and subsequent loss of engine power."
• "The pilots improper preflight planning and preparation which resulted in a loss of engine power due to fuel exhaustion."
• "The pilot's failure to refuel, resulting in fuel exhaustion and a subsequent loss of engine power."
• "The pilot's inadequate preflight and mismanagement of the fuel supply, which resulted in fuel exhaustion."
• "The pilot's inadequate preflight planning of fuel required for the flight that resulted in fuel exhaustion and the subsequent loss of engine power."
• "A total loss of engine power due to fuel exhaustion as a result of the pilot's inadequate preflight fuel planning."
• "A total loss of engine power during a go-around due to fuel exhaustion as a result of the pilot's inadequate preflight planning."
• "The inadequate preflight inspection by both pilots, resulting in a loss of engine power due to fuel exhaustion."
• "A total loss of engine power due to fuel exhaustion as a result of the pilot's inadequate preflight planning."
• "Improper planning/decision by the pilot, which resulted in fuel exhaustion due to an inadequate supply of fuel."
• "A loss of engine power during approach due to fuel exhaustion as a result of the pilot's fuel mismanagement."
• "A total loss of engine power due to fuel exhaustion as a result of the pilot's inadequate preflight fuel planning."

... and on and on and on and on and on.

I am suggesting the aviation community take a closer look at the causes and effects of Fuel Exhaustion and Fuel Starvation events.