The proliferation of reliable, accurate cockpit automation has always offered a reckless segment of the pilot community the opportunity to operate in the IFR system without going to the trouble of earning the instrument rating. We all know a pilot friend who is probably flying a technically advanced aircraft—TAA, one with an IFR-approved GPS navigator, a moving map and two-axis autopilot—into IMC but without an instrument rating. Do you really think the temptation to use all that panel-mounted equipment under IFR and/or in IMC, even if the pilot is not rated or current, is easily resisted? I can guarantee there’s someone at your local airport right now who either has or will do just that.
I once knew a guy fitting this description who regularly flew a turbocharged piston single almost everywhere, often in IMC. I once called him on it and he blew me off; our friendship drifted apart for several reasons and I’m pretty sure he’s stopped flying. But this was 20 years ago, and it’s only gotten easier to file and fly instruments without the rating.
When someone is so cavalier as to dismiss the obvious risks of such behavior, there’s not much we can do without solid evidence. Sure; we could rat them out to the Feds, but that seems extreme and can open an unpredictable can of worms for everyone. Counseling was my choice, but I failed to convince him he was flouting not only the FARs but good sense. Yes, as I recall, he carried passengers on such flights.
I’m sure VFR-only pilots rationalize their behavior by comparing it to flight-following services, only without meeting those pesky VFR minimums, and assure themselves they are experienced enough to not into trouble. Nothing could be further from the truth, actually, since if they were experienced enough to not get into trouble, they would already have the instrument rating.
Background
On January 2, 2021, at about 1541 Eastern time, a 1964 Piper PA-24-250 Comanche 250 was destroyed when it collided with terrain during an attempted instrument approach to the Oakland Southwest Airport (Y47) in New Hudson, Mich. The non-instrument-rated private pilot (male, 60) and two passengers were fatally injured.
The flight departed Canton, Ga., at 1221, and proceeded GPS-direct at 7500 feet msl with flight-following services from ATC. At 1452, the pilot advised Toledo Approach he would have to “convert to IFR” to reach his destination and was cleared direct under IFR at 7000 feet msl. At about 1513, the pilot asked Detroit Approach about icing and was told there had not been a related Pirep in the last hour. The pilot then asked for the VOR-A approach into Y47. He added that if he missed the approach, he would proceed to Pontiac, Mich.
At 1533, and 3000 feet msl, ATC vectored the flight to intercept the final approach course to Y47. He was also given a Pirep from about 16 miles south of Y47 in which a pilot reported an overcast at 300 feet with no ice descending through the layers. When asked his intentions, the accident pilot replied he would “give it a shot.”
At 1535, the pilot was cleared for the VOR-A approach; the VOR portion of the approach had been Notamed as unavailable, a notice of which was displayed at the radar controller’s position. The last radio contact with the airplane was when ATC reminded its pilot to cancel IFR.
Recorded ADS-B data show the airplane approached Y47 at about 2000 feet msl and 100 knots, and then passed over the airport and decelerated in a left descending turn to 1475 feet and 85 knots. It entered a second, tighter turn and descended to 1150 feet and 60 knots. Track data was lost at 1541:20, at 975 feet and 71 knots.
Investigation
The pilot’s two logbooks were reviewed. The pilot had logged 41.5 hours of simulated instrument conditions, 15.2 of which were with an instructor. He also had logged 99.6 hours under actual instrument conditions, 4.8 hour of which were with an instructor, for a total of 141.1 instrument hours. The last logbook entry indicates the pilot had logged 1278.8 hours total time.
A pilot who was at Y47 when the accident occurred reported the weather conditions “…were not favorable for flying—fairly low ceiling, heavy clouds, light mist and rain with low temperatures.”
The wreckage was later examined by investigators from Piper Aircraft and Lycoming Engines, supervised by an FAA inspector. The fuel selector was on the right auxiliary tank, the flaps were retracted and the stabilator trim was between neutral and slightly nose-up. There were no pre-impact mechanical anomalies identified that would have precluded normal operations.
Probable Cause
The NTSB determined the probable cause(s) of this accident to include: “The pilot’s failure to maintain proper airspeed and his exceedance of the airplane’s critical angle of attack, which resulted in an aerodynamic stall. Contributing to the accident was the pilot’s lack of an instrument rating and the low visibility at the time of the accident.”
The NTSB added: “Although the Notam stated the VOR portion of the approach was unavailable it is unlikely that this played a role in the accident as the pilot had overflown the airport on the approximate approach course and was circling the area when the accident occurred. There was no record that the non-instrument rated pilot obtained a weather briefing or filed a flight plan for his flight.”
The approach flown by the accident pilot doesn’t exist today, having been replaced by an RNAV (GPS) procedure. The current approach has a published minimum descent altitude of 614 feet agl, substantially higher than the reported nearby weather on the day of the accident.
What can we say about this accident? One thing is to note the pilot displayed three of the five hazardous attitudes the FAA has identified as detrimental to aeronautical decision-making, including anti-authority, invulnerability and macho. We can leave out impulsivity—this was not the pilot’s first rodeo—and probably resignation, though we don’t know his exact state of mind.
It’s also difficult to learn much from this accident, except for the obvious: There are good, solid, time-tested reasons pilots lacking an instrument rating should not be flying in IMC. Because he got away with it for more than 120 flight hours, though, the cynical among us might point out that he didn’t do all that badly. Fine.
At the end of the day, it shouldn’t come as a surprise this pilot ended up losing control. Better training leading to earning the instrument rating might have taught him that decisively performing the missed approach was the better course of action, followed by a diversion. That same training, however, is something the pilot apparently avoided, convinced some combination of equipment and daring would work out better for him than buckling down and finishing the rating.
The definition of a TAA—technically advanced aircraft—has evolved over the years. Some 20 years or so ago, when the small aircraft transportation system (SATS) was first being developed jointly with NASA, the FAA coined the term to mean an aircraft with an IFR-approved GPS navigator, a moving-map display and a two-axis autopilot. It was more a term of art than a defined aircraft category. That changed in 2018.
The change came in response to industry input that complex single-engine airplanes—those with retractable landing gear, a constant-speed propeller and wing flaps—were becoming both rare and expensive. But the then-current FARs required a minimum amount of time in complex airplanes to be eligible for a commercial pilot certificate. So, the FAA changed the rule, as part of an effort to provide “regulatory relief” and accommodate “technically advanced airplanes as an alternative to the use of older complex single engine airplanes.” Along the way, the agency changed the TAA definition. It now reads:
(1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;
(2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving map using Global Positioning System (GPS) navigation with the aircraft position displayed;
(3) A two axis autopilot integrated with the navigation and heading guidance system.”
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