As forecast within my Amphibious Nostalgia article in the February issue of Position Report, this describes one of the more humorous episodes revealing how the law of unintended consequences attended the FAA’s decision to confuse the airworthiness basis for several hundred airplanes in an apparent bow to nothing more than administrative convenience. To set the stage, the FAA had adopted “G111” as a universal type identification for the G64 Albatross airplanes, despite that only 13 of 466 airplanes were modified by Grumman to G111 configuration. Previously, the Albatross had been described by the FAA for various purposes as the G64, SA16, HU16 and UF. Subsequently, no one within the FAA or the user community knew which designator to use for operations, airworthiness or registration.
Historically, the regulator had taken the position that it would not issue flight crew type ratings for airplanes as to which no type certificate could be issued. After the Second World War, it used the “limited” category for some surplus military aircraft types, often extending the certification to only part of a production run, and often including only aircraft that had been modified by the military to some particular configuration. But most military aircraft were not issued type certification approval under the “limited” category, and could be legally registered only as “experimental” – that is, without type certification. It must be noted that the FAA violated its own rulemaking from time-to-time, and registered some G64s (and other ex-military types, as well) under the “restricted” category, despite that no provisions within the applicable regulations allowed it to do so legally. For flight crew licensing to operate large and turbine-powered airplanes that were surplus military, and not subject to type certification, the FAA traditionally used Letters of Authorization. The LOA system was efficient and effective, which probably doomed it for replacement by a system that more accurately reflected the way in which the issuing agency customarily conducted business.
As with too many things bureaucratic, and for reasons that the regulator itself was never able to explain well, it determined that LOAs would no longer be used, and instead type ratings would be required to operate all surplus military types, whether or not a basis for aircraft type certification had ever been established. Under the revised system, one passing a type rating check in an HU16 was issued a type rating for the G111, despite that he had never seen one. A flight plan filed for an SA16, HU16 or UF went into the computer as for a G111. Advertisements began appearing for the sale of G111s, despite that most aircraft so described were neither modified, nor capable by serial number of being so modified.
That most aircraft at issue could not be operated in conformance to regulatory requirements for performance, training and licensing – set forth in substantive regulations governing the certification and operation of airline transport aircraft – seemed to escape notice by the increasingly less experienced and knowledgeable people managing the agency. The stage was set for, and promoted the development and use of, highly subjective, arbitrary and non-uniform licensing standards, resulting in type ratings on FAA pilot certificates after testing that failed to meet the international standards required as a basis for a signatory country to issue licensing documents. Bureaucratic politics permeated the process, and before long, control over the crew licensing system for surplus military aircraft was – as charitably as it can be described – in disarray. Worse, the situation continues today.
This brings us to the events of a particular trans-Pacific flight in an Albatross, the last leg of which was from Honolulu to a maintenance station in the western United States. The 18-hour flight required full main tanks, full float tanks and 290-gallon drop tanks on the two hard points. Covering the additional contingency requirements for an engine failure near the halfway point required five 55-gallon drums of fuel behind the flight deck, with both electric and back-up hand pumps for transfer of the fuel to the main tanks.
Many wonder why one would be concerned about a water landing in the ocean, and believe that the large amphibians can be easily so landed in the event of an engine failure. The true facts are that a landing on open ocean water, with its unpredictable combinations of swells, waves and winds, make such operations an emergency under all but the best of possible circumstances. Operating recommendations by the manufacturers of even the largest amphibians always include that the designs are intended for takeoff and landings in “sheltered water close to shore”.
Even with only crew and fuel, the airplane was heavy and would require operation at Climb Two Power holding L/D-Max for several hours to reach 3,000 feet. Remaining aloft in the event of an engine failure would be possible in ground effect after hour-three, conditional upon jettisoning the drop tanks. The weather was good, and departure was planned for early evening, so that the crossing of the Sierra-Nevada Range and landing would be conducted in daylight the following morning.
The flight was prior to GPS, and no inertial equipment was installed. As with substantially all oceanic crossings in aircraft of that era, navigation was to be accomplished based primarily on the “Lindbergh Method” – that is, by establishing an initial heading based on predicted winds, and adjusting it hourly towards the equator by the degrees of latitude over ninety degrees times the degrees of longitude passed, to effect a “great circle” route. Having made many oceanic crossings using this technique with older aircraft types, I was comfortable with the accuracy of this navigational methodology. Indeed, as Lindbergh found when he approached Ireland in 1927, it is normal when the wind forecast holds, to be within a few miles of the projected point of landfall after some sixteen to twenty hours enroute.
Decommissioning of the high-powered low-frequency oceanic beacons at Hilo and San Francisco in order to save a few hundred dollars per year had not yet been undertaken by the all-too myopic FAA, and the non-directional beacons were therefore available – using the beat frequency oscillation (BFO) feature and subject to the prevailing levels of atmospheric interference – to validate radial positions. Star shots were available as a backup, although the low-altitude nature of such crossings always made visual contact with the heavens problematic due to higher cloud cover. In addition, taking star shots on aircraft without a navigation bubble on top of the fuselage always introduced a parallax error, as well, requiring a correction estimate to a process that inherently suffered from accuracy issues.
A DVFR flight plan would be required to allow penetration of the Air Defense Identification Zones outbound from Hawaii and inbound to California. Oceanic airspace at low altitudes was uncontrolled, and a flight plan was filed for the HU16 at 3,000 feet and 130 knots. The remarks section included the notation that position reports would be made at hourly intervals, due to the fact that only some two degrees of longitude would be traversed in each hour aloft. The long “reef runway” would be required at Honolulu International, with a shallow right bank in ground effect along Waikiki Beach, then a similar bank to the left passing Koko Head, through the Kaiwi Channel, and then establishing the initial enroute heading once north of Nakalele Point.
The wheels and tires on the Albatross are relatively small and light, making heat buildup a concern for long taxi routes at heavy weights. The airplane is not equipped with nose-wheel steering. Normal procedure requires rudder and main gear braking for steering on taxi, but brake heating on long taxi routes can easily push the tires to deflation. To avoid brake heating, the trick was to use control surface deflections and differential power for steering, keeping electrical loads down to minimum, as engine generators would be off-line at RPMs under 1500. Daylight was important for the takeoff and first several hours so that an engine failure at heavy weights, with a requirement for an ocean landing, would not be further complicated by darkness. This also meant that no lights would be required for the taxi, and thus the absence of generator power at low RPMs for taxi was more easily tolerated.
The takeoff roll was extended and the aircraft accelerated in ground effect during gear retraction before power reduction to Climb One Power. Although the FAA had certified the few G111 airplanes with a decision speed of 89 knots and a takeoff safety speed of 96 knots, in both cases without regard to weight, those numbers were all for show and bore no relationship to what was actually required with Albatross aircraft. Leaving the aircraft on the water to a speed of 89 knots would place the nose gear doors and hull panels on the edge of implosion failure due to water pressure. Obtainment of 96 knots before an engine failure from land or water would leave one above the velocity of minimum control, but 19 knots short of being able to continue with perfect procedure, and 29 knots short with average procedure. This evening the engines continued to run and Waikiki passed slowly along the port side as the aircraft slowly accelerated to the 131 knots necessary at the takeoff weight and in clean configuration to maximize lift over drag.
Once clear of the islands, established on the initial heading, holding L/D-Max speed at Climb Two Power and with a negligible rate of climb, contact was established with San Francisco Radio on high-frequency (HF). The response to the initial position report and radio check was the start of what can best be described as an ongoing argument about whether the FAA, using only interpretive rulemaking, had the power to alter the laws of cosmology and physics. I was advised that, due to new policies arising from the “war on drugs”, I would be required to maintain a minimum of 5,500 feet MSL under visual flight rules, and after official sunset would be required to be on an IFR flight plan at a minimum of 7,000 feet MSL.
I tried to explain that, as much as I would enjoy cruising at 7,000 feet – or even 5,500 feet – the laws of physics would render that impossible for the first 10 hours of the 18 hour flight. In addition, as much as I would prefer to make the entire flight in daylight conditions, the cosmological fact of the earth’s rotation rate as compared to the cruising speed of the aircraft rendered that impossible, as well. The delay in response implied that “tilt lights” had been illuminated throughout the system, and that consultations were now being conducted far beyond the hallways of only oceanic traffic control.
A response was finally received, and can best be described as a restatement of the original advice, although delivered in a firmer tone, and with warnings of regulatory issues that would result from my willful violation of regulations. Immediately sensing that logic would be insufficient to carry the day, I simply replied that I would argue the powers of the FAA versus those of Mother Nature with agency managers in Washington after arrival.
Following that initial joust, the mundane progress of an extended over-water flight settled into reality. Some 17 hours later, the VOR came to life with receipt of the signal from Point Reyes, and our position was verified as “on course”. Transition to San Francisco Approach Control was effected, at which point we were ordered to land at Sacramento. Understanding the futility of my efforts from the start, I nonetheless attempted to argue that our destination was but one hour further east, we already had altitude for the mountain range crossing, and that conversation with the FAA could be accomplished after a landing at the intended point of destination. The response was that a failure to follow the directive to land at Sacramento would result in “armed intercept”. It was clearly time to abandon any further attempt at logic or diplomacy. I turned towards Sacramento.
The arrival, approach and landing at Sacramento were uneventful until clearing the active runway and contacting ground control, as which point we were instructed to follow a lead vehicle to a remote ramp location. The scope of our welcoming committee became apparent as the airplane was surrounded by a fleet of black utility vehicles, police cars, and a large truck with “S.W.A.T.” painted on the side. After shutdown, I slid the side-window open and the co-pilot headed for the rear door.
The view outside was astounding. I shouted for the co-pilot to stop immediately, and under no circumstances to open the rear door until communication had been established with the officials outside. With more than a dozen vehicles surrounding the airplane, there was a sea of blue windbreaker-style jackets, adorned with large gold letters representing the FBI, FAA, DOT, Coast Guard, and Immigration & Customs Enforcement. In addition, local police and SWAT personnel were everywhere, with automatic weapons trained on the airplane. Airport police and drug-dog teams were in place. Only the Boy Scouts were not represented.
It was disconcerting to say the least. Knowing that young people who enjoy spit-shining their shoes and polishing their brass just a little too much were those holding military-style weapons, I decided that any fast movements should be avoided. I shouted that no weapons were on board the airplane, there were only two occupants, and asked for advice on what they wanted us to do. The answer was to exit the airplane slowly and with our hands visible at all times. I shouted that it would be necessary to extend the portable stair unit over the side from the rear door, and that it was made of metal tubing but not a weapon.
Slowly we exited, at which point a man wearing a jacket identifying him as with the FAA approached. His look of incredulity was my first clue that we were in the middle of a bureaucratic “goat-rope”. “We were told,” he said, “That a Gulfstream III had filed a flight plan from Hawaii with an 18-hour estimated time enroute.” Suddenly it was clear. FAA Flight Service had changed the HU16 aircraft type on the flight plan to a G111, in order to conform to the new type identifier. The dispute with oceanic traffic control about enroute altitudes brought operations people into the picture, and they assumed that a business jet was going to make a drug run to Latin America while making position reports as though flying slowly from Hawaii to the mainland.
We were searched, but with only two citizens, crew bags and an otherwise empty airplane, the process went quickly. There was disappointment on the faces of all concerned, and particularly the young SWAT Team members upon the realization that they were not going to have the opportunity to shoot anyone that day with their exotic military weaponry.
The caravan of official vehicles drove slowly away, and we continued our journey. I never heard further from the FAA about my inability to suspend the laws of cosmology and physics.
Mark H. Goodrich – Copyright © 2014
“The Great Albatross Caper” was first published in the September 2014 Issue (Vol 11 No 3) of Position Report magazine.