IMC in the winter.

[jrh]

I'll do it with someone who is experienced in the matter such as yourself, but you bet your ass I ain't flying into knowin icing conditions (aka PIREPS confirming ice) by myself without that experience. I don't think that's conservative of me, I think it's smart of me.

But I do agree with you

Nothing wrong with that. I'll never criticize anyone for wanting to take their time and build experience incrementally.

I'm only disagreeing with the folks who say it can't be done, period. It can.

 

[jrh]

When you read "Flight into known icing conditions prohibited" in the POH it's pretty straight forward.

Did you read the link I posted to the FAA's letter of interpretation on this matter?

This issue isn't nearly as clear cut as many people in this thread (yourself included) are making it out to be.

 

[averettpilot]

Did you read the link I posted to the FAA's letter of interpretation on this matter?

This issue isn't nearly as clear cut as many people in this thread (yourself included) are making it out to be.

"Pilots should not expose themselves or OTHERS to the risks associated with flying into conditions in which ice is likely to adhere to an aircraft"
"The agency's goal is to encourage proper flight planning in advance and to avoid unwarranted risk-taking..."

It also goes on to state a difference in terminology stated in aircraft manuals between "known ice" and "known icing conditions." Yes, ice is known once it has accrued and been observed. You can't use this "loop-hole" to say "Oh I'll just go up and show you ice and then fly right out of it to show you it's no biggie." You've violated the spirit of the FAA's definition because you knew the ice was up there otherwise you wouldn't have done it for the express purpose of providing your student with some no doubt valuable experience. Doesn't make it any more legal.

This letter basically says you can't claim ignorance if the information was out there prior to the flight and there was a reasonable expectation of ice accumulation. It also said that even in the absence of icing AIRMETs or pilot reports that if the CONDITIONS are present for icing to exist that this can be cause for enforcement action by the FAA. Of course this assumes that you got into trouble on your foray into the "unknown." Ignorance is not bliss in this industry.

Yes, I read the link.

 

[jrh]

"Pilots should not expose themselves or OTHERS to the risks associated with flying into conditions in which ice is likely to adhere to an aircraft"
"The agency's goal is to encourage proper flight planning in advance and to avoid unwarranted risk-taking..."

It also goes on to state a difference in terminology stated in aircraft manuals between "known ice" and "known icing conditions." Yes, ice is known once it has accrued and been observed. You can't use this "loop-hole" to say "Oh I'll just go up and show you ice and then fly right out of it to show you it's no biggie." You've violated the spirit of the FAA's definition because you knew the ice was up there otherwise you wouldn't have done it for the express purpose of providing your student with some no doubt valuable experience. Doesn't make it any more legal.

This letter basically says you can't claim ignorance if the information was out there prior to the flight and there was a reasonable expectation of ice accumulation. It also said that even in the absence of icing AIRMETs or pilot reports that if the CONDITIONS are present for icing to exist that this can be cause for enforcement action by the FAA. Of course this assumes that you got into trouble on your foray into the "unknown." Ignorance is not bliss in this industry.

Yes, I read the link.

Ok, we'll have to agree to disagree then.

If it were as simple as you're making it out to be, the FAA would have already issued an interpretation stating, "Flying into visible moisture with below freezing temperatures is prohibited." But they *haven't* because they see the importance of allowing pilots to make decisions in the moment, rather than follow broad, sweeping generalities.

Are you saying the example from my recent flight is unsafe? Or illegal? Or both? Because I consider it to be neither, and I'd have no problem telling that to a fed.

 

[averettpilot]

The interpretation the FAA had before this one was flying into visible moisture with below freezing temps. They changed to a more broad policy which allowed pilots to make more informed decisions on the flights they were taking. Under the former interpretation, the flight you illustrated would have most definitely at one point or another been illegal. Now, you just might have been a little reckless and I emphasize might because while you were rather detailed in your description I was not there and do not care to fully judge another pilot on their decision making. To comment on it, I might say that while you had known outs you couldn't be assured that conditions wouldn't deteriorate to a point outside your operational capabilities. Had I seen the conditions you described in a weather briefing on the ground I might have been inclined to say no-go, because as you had proven in actuality, the conditions were present for icing.

It is never as simple as black and white on a piece of paper, rather you have to gather all the facts before hand and make an informed decision about whether or not to go gallivanting off into weather that may be outside operational limits.

I'll pose this question to you. Would you have had a problem reciting those conditions to a fed had the flight turned out in a more negative fashion? Because as their letter of interpretation states, they would have checked up on your weather briefing to see if you had that icing information on hand.

 

[jrh]

The interpretation the FAA had before this one was flying into visible moisture with below freezing temps. They changed to a more broad policy which allowed pilots to make more informed decisions on the flights they were taking. Under the former interpretation, the flight you illustrated would have most definitely at one point or another been illegal.

The former interpretation was ridiculous by pretty much any standard. The FAA changed it because they saw how impossible to deal with and impractical it was in real world flying.

Now, you just might have been a little reckless and I emphasize might because while you were rather detailed in your description I was not there and do not care to fully judge another pilot on their decision making. To comment on it, I might say that while you had known outs you couldn't be assured that conditions wouldn't deteriorate to a point outside your operational capabilities.

Well, I suppose I couldn't be absolutely, 100%, beyond any doubt, assured of it. But we can't be assured of anything with any weather phenomena. All we can do is make reasonable assumptions. Isn't that what pilots do on *every* flight?

All TAFs, METARs, PIREPs, temps aloft forecasts, and what I saw with my eyes out the window indicated a stable, predictable situation.

I looked at the conditions, made a plan, and executed it. You could say the same thing about dealing with any potential hazard (wind, night time, equipment failures, etc.).

It is never as simple as black and white on a piece of paper, rather you have to gather all the facts before hand and make an informed decision about whether or not to go gallivanting off into weather that may be outside operational limits.

Right. Which is exactly what pilots should be before launching in to potential ice.

I'll pose this question to you. Would you have had a problem reciting those conditions to a fed had the flight turned out in a more negative fashion? Because as their letter of interpretation states, they would have checked up on your weather briefing to see if you had that icing information on hand.

Absolutely.

But here's the thing--nothing is going to happen as long as nothing happens. That might sound obvious, but it's the truth.

I wouldn't have launched on that flight if I'd thought there was any significant chance of a negative outcome.

The feds don't take action against a pilot who lands safely after encountering ice. They take action against pilots who back themselves into a corner, go too far, and have an incident.

Of course, more important than avoiding certificate action is simply staying safe. That's what I've been trying to say all along. If pilots looked at big picture scenarios and analyzed them from various angles, rather than following blanket rules of weather minimums or arbitrary definitions for "known icing," we'd all be a lot better off.

Trust me, I've canceled dozens, probably even hundreds of flights because of ice. It's a serious hazard that should not be taken lightly. However, that doesn't mean all flight operations need to cease as soon as a cloud shows up on a cold day.

 

[MikeD]

If it were as simple as you're making it out to be, the FAA would have already issued an interpretation stating, "Flying into visible moisture with below freezing temperatures is prohibited." But they *haven't* because they see the importance of allowing pilots to make decisions in the moment, rather than follow broad, sweeping generalities.

.

If the above were the definition, then no freight dog would ever fly during any number of missions.

 

[Douglas]

This thread is an example of a specific question on a specific situation in a specific location being generalized to all training in all portions of the country. Make way for good advice.


Thanks internet.

 

[ppragman]

My advice? Don't do anything patently stupid. It seems obvious at first, but icing flight is a no-no when you're not in a FIKI airplane. If you run into, turn around a get out of it. Or climb, or descend, as required to clear it. But first things first, get the hell out of there. Does that mean you can't fly in the clouds if its below 0C out in a non-FIKI approved airplane? Maybe, depends on the definition of "is," but I suspect its really going to depend a lot on the individual pilot, and on the conditions. Departing through a 400' layer at 500' AGL to clear above when its 20F out is different than climbing into your 172 and slogging it out at 4000' solid IMC for the whole trip when its 20F out. Regulation can't fix stupid (it can try) but brief potential exposure carries a different weight (in my humble opinion) than continuous potential exposure. I've encountered icing inadvertently in non-FIKI airplanes, I treat it as an emergency and immediately turn around in such circumstances. Basically, the point of the regulation isn't to say "you cannot fly when there's a cloud in the sky and the thermometer's less than freezing," its to say "don't hurt yourself, your passengers, or people on the ground by continuing in icing conditions when it was unsafe to do so." Continuing in icing conditions (notice that a lot of AFMs say "continued flight into known icing conditions is prohibited) is what's bad juju. That brings up the question, "well, what's known icing?" Its seen on the airplane, reported by other airplanes, or blatantly obvious by the conditions. Some AFMs go onto describe what that means for them, Cessna says "icing conditions" not "known icing conditions," and defines their terminology, old Pipers do not. Basically, all of this is set up to alleviate the manufacturer from litigation, and leave what is safe open to pilot judgment. Frankly, some pilots don't have the requisite judgment to say, "wait, this mission should be scrubbed," others are overly cautious - which in some ways is also a lack of judgment - and don't fly when they could. At risk of being jetcareer's hippy-Buddha pilot, I say "take the middle path." Launch when there's no doubt that you can safely complete the flight, but don't be afraid of everything. If you don't have the experience to launch into those flight conditions, and your CFI's "personal minimums" don't allow it - by the way, I hate the concept of personal minimums, maybe I'll start a thread about it - find a CFI who's more experienced, and has better judgment, and go with him/her.

 

[jrh]

My advice? Don't do anything patently stupid. It seems obvious at first, but icing flight is a no-no when you're not in a FIKI airplane. If you run into, turn around a get out of it. Or climb, or descend, as required to clear it. But first things first, get the hell out of there. Does that mean you can't fly in the clouds if its below 0C out in a non-FIKI approved airplane? Maybe, depends on the definition of "is," but I suspect its really going to depend a lot on the individual pilot, and on the conditions. Departing through a 400' layer at 500' AGL to clear above when its 20F out is different than climbing into your 172 and slogging it out at 4000' solid IMC for the whole trip when its 20F out. Regulation can't fix stupid (it can try) but brief potential exposure carries a different weight (in my humble opinion) than continuous potential exposure. I've encountered icing inadvertently in non-FIKI airplanes, I treat it as an emergency and immediately turn around in such circumstances. Basically, the point of the regulation isn't to say "you cannot fly when there's a cloud in the sky and the thermometer's less than freezing," its to say "don't hurt yourself, your passengers, or people on the ground by continuing in icing conditions when it was unsafe to do so." Continuing in icing conditions (notice that a lot of AFMs say "continued flight into known icing conditions is prohibited) is what's bad juju. That brings up the question, "well, what's known icing?" Its seen on the airplane, reported by other airplanes, or blatantly obvious by the conditions. Some AFMs go onto describe what that means for them, Cessna says "icing conditions" not "known icing conditions," and defines their terminology, old Pipers do not. Basically, all of this is set up to alleviate the manufacturer from litigation, and leave what is safe open to pilot judgment. Frankly, some pilots don't have the requisite judgment to say, "wait, this mission should be scrubbed," others are overly cautious - which in some ways is also a lack of judgment - and don't fly when they could. At risk of being jetcareer's hippy-Buddha pilot, I say "take the middle path." Launch when there's no doubt that you can safely complete the flight, but don't be afraid of everything. If you don't have the experience to launch into those flight conditions, and your CFI's "personal minimums" don't allow it - by the way, I hate the concept of personal minimums, maybe I'll start a thread about it - find a CFI who's more experienced, and has better judgment, and go with him/her.

I <3 you, ppragman. Well said.

Also, go ahead and start the "I don't have personal minimums" thread. I'm with you. I don't like the philosophy of personal minimums, either. I just don't want to derail this lovely thread.