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Safety Recommendation Details

Safety Recommendation A-12-013
Synopsis: On September 16, 2011, about 1626 Pacific daylight time, a modified experimental single-seat North American P-51D, N79111, collided with the airport ramp in the spectator box seat area following a loss of control while maneuvering during the unlimited class1 gold race at the NCAR at Reno Stead Airport (RTS), Reno, Nevada. The airplane was registered to Aero-Trans Corp, Ocala, Florida, and operated by the pilot as Race 177, the Galloping Ghost, under the provisions of 14 Code of Federal Regulations (CFR) Part 91. The commercial pilot and 10 people on the ground sustained fatal injuries; based on preliminary information, 66 people sustained serious injuries, and numerous minor injuries were reported. The airplane fragmented upon impact with the ramp. Visual meteorological conditions prevailed, and no flight plan was filed for the local air race flight, which departed RTS about 10 minutes before the accident. Numerous photographs and videos of the accident sequence have been collected from the public during the investigation, and an airplane performance study is being conducted. Based on available information, the airplane was established in a turn while passing pylon 8 on the 10-pylon course (see figure) when it experienced an upset. Its airspeed was about 460 knots (530 mph) at this time. After the initial roll upset, it entered a severe rolling climb maneuver and traveled a downward spiral flightpath to impact the ramp in the box seat area. Preliminary findings in the NTSB’s ongoing investigation point to the need for safety improvements regarding evaluation of aircraft with structural or flight control modifications, the unlimited class course design, and training for air race pilots concerning potential physiological effects of high g4 operations.
Recommendation: TO THE RENO AIR RACING ASSOCIATION: Require aircraft owners, as a condition of eligibility to participate in the Reno National Championship Air Races, to provide an engineering evaluation that includes flight demonstrations and analysis within the anticipated flight envelope for aircraft with any major modification, such as to the structure or flight controls.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Aviation
Location: Reno, NV, United States
Is Reiterated: No
Is Hazmat: No
Accident #: WPR11MA454
Accident Reports: Pilot/Race 177, The Galloping Ghost, North American P-51D, N79111
Report #: AAB-12-01
Accident Date: 9/16/2011
Issue Date: 4/10/2012
Date Closed: 5/9/2013
Addressee(s) and Addressee Status: Reno Air Racing Association (Closed - Acceptable Action)

Safety Recommendation History
From: NTSB
To: Reno Air Racing Association
Date: 5/9/2013
Response: We have reviewed the information you provided regarding procedures used during the 2012 NCAR event to evaluate race aircraft that had undergone major modifications and are pleased that RARA will incorporate these procedures into the NCAR Official Rules of Competition for the 2013 and subsequent NCAR events. RARA’s actions satisfy Safety Recommendation A-12-13, which is classified CLOSED—ACCEPTABLE ACTION. We appreciate the cooperation you have demonstrated and your commitment to aviation safety.

From: Reno Air Racing Association
Date: 3/13/2013
Response: -From Michael J. Houghton, President and CEO: On September 19, 2012, the Reno Air Racing Association, Inc. received the National Transportation Safety Board response to our report on Safety Recommendations A-12-14 through A-12-17. Your letter states that RARA's actions satisfy the Safety Recommendations for items A-12-14 through A-12-17, which were classified as "Closed-Acceptable Actions" at the August 12, 2012 National Transportation Safety Board meeting. Item A-12-13 still remained opened. Attached is RARA's Response to NTSB Recommendation for A-12-13. If you have any concerns or questions, please do not hesitate to contact me. RARA Response to NTSB Recommendation A-12-13 The procedure described herein is submitted to provide information required to close NTSB Recommendation A-12-13, issued on April 10, 2012. NTSB Recommendation A-12-13 is directed to the Reno Air Racing Association (RARA) and reads as follows: “Require aircraft owners, as a condition of eligibility to participate in the Reno National Championship Air Races, to provide an engineering evaluation that includes flight demonstrations and analysis within the anticipated flight envelope for aircraft with any major modification, such as to structure or flight controls." During preparations for the 2012 National Championship Air Races (NCAR) event, RARA and Reno FSDO developed procedures to evaluate race aircraft which had undergone major modifications within their anticipated fight envelopes. The procedures were tested on an Unlimited-class aircraft and a Biplane-class aircraft, both of which had undergone major modifications. The resulting flight evaluation and analysis met the requirements of RARA and the FAA evaluation teams which included the Reno FSDO and the aircraft owners' local FSDO. As a result, the modified aircraft received RARA authorization to participate in the 2012 NCAR event. The RARA and the FAA participants in the evaluation believe that the coordination, direction and resulting tests and analysis met the intent of this NTSB Recommendation. RARA will incorporate this procedure into the NCAR Official Rules of Competition, as detailed below, for the 2013 and subsequent NCAR events. This procedure applies to aircraft with Experimental Airworthiness certificates; aircraft with Standard or Limited airworthiness certificates are subject to FAA airworthiness standards contained in 14 CFR Parts 21, 23,43, and 91 and in predecessor Civil Air Regulations (CAR's) and Civil Aeronautics Manuals (CAM's) with regard to their airworthiness standards and airworthiness certifications. No later than March 1st of each race year,(with April 1 being the applicable date in 2013), an owner/operator desiring to participate in that year's NCAR, must notify its appropriate Race Class if his/her aircraft is a new race aircraft or a prior race aircraft with one or more major modifications. The Class will immediately notify RARA Operations of the specifics of the new aircraft's performance, or the specifics of major modifications to a returning aircraft. This notification will include the name, telephone number and email address of the FSDO who will be overseeing the flight test, data analysis, and certification of a new or modified race aircraft. RARA Operations will notify the RARA Maintenance Coordinator who will advise the Reno FSDO that a new race aircraft or an aircraft with major modifications has requested authorization to compete in an upcoming NCAR. This notification will include a copy of the data package provided by the owner/operator and/or the Race Class. The Reno FSDO will establish contact with the geographically responsible FSDO where flight testing will be performed. The FSDO personnel shall, together, ensure the proposed engineering evaluation, including flight demonstrations and analysis within the anticipated flight envelope for the aircraft, will meet the RARA eligibility requirements. If RARA and the Reno FSDO do not agree that the presented material is adequate for race approval, the owner/operator may be given an opportunity to provide additional justification. All race aircraft seeking authorization to participate in a NCAR race must be designed to acceptable structural design criteria to meet the limiting load factors as specified by the appropriate Race Class. A flight flutter analysis, test plan, and test results will be submitted to verify that the aircraft will safely operate within the structural limits and not be in the flutter region at anticipated race speeds and load factors within the anticipated race flight envelope. Weight and balance for an empty and full race configuration will be required. Weight and balance documentation must include the forward and aft center-of gravity (CG) limits for the potential race aircraft within its flight envelope at anticipated race speeds and race power settings. The flight test plan and flight test results must be documented to confirm that the potential racer will be operating within the flight envelope at anticipated race speeds and race power settings. Flight testing must be completed, documented, and submitted by the race aircraft owner/operator no less than 90 days prior to participation in a NCAR event. In addition to the foregoing requirements, all aircraft of each class authorized by RARA to participate in that year's NCAR will be required to undergo an Aircraft Compliance Inspection prior to any aircraft flight at Reno-Stead that supports pilot qualification, race qualification, race practice or racing. The Reno FSDO and RARA's Maintenance Coordinator will review all discrepancies noted and corrective actions to correct discrepancies documented by the Class Aircraft Compliance Inspection Team, if any. The RARA Maintenance Coordinator and the Reno FSDO shall have final authority as to the release of each race aircraft for competitive flight operations. Any flight-critical aircraft maintenance performed during race week (e.g. engine change, cylinder change, flight control removal/replacement, etc.) will be documented and re-inspected by the Class Aircraft Compliance Inspection Team, with the results of said process submitted to RARA and the Reno FSDO.

From: NTSB
To: Reno Air Racing Association
Date: 9/19/2012
Response: Although the actions RARA has taken are steps in the right direction, the process RARA plans to use that is described in the July 9, 2012, letter (to ensure compliance with current Federal Aviation Administration [FAA] requirements, to implement operating limitations that reflect the current airplane configuration, and to initiate an appropriate logbook signoff for flight testing) do not necessarily ensure that an engineering evaluation including flight demonstrations and analysis within the anticipated flight envelope has been performed. RARA is still evaluating its role in establishing eligibility requirements with regard to FAA regulations. Accordingly, at the August 27, 2012, Board Meeting, Safety Recommendation A-12-13 was classified OPEN—ACCEPTABLE RESPONSE pending our receipt of further information showing that the process proposed by RARA specifically requires an owner of an aircraft with a major modification to provide an engineering evaluation that includes flight demonstrations and analysis within the anticipated flight envelope.

From: Reno Air Racing Association
Date: 7/12/2012
Response: -From Michael J. Houghton, President and CEO (July 9, 2012): For the past several years, RARA has worked closely with the Reno Flight Standards District Office of the Federal Aviation Administration to identify those aircraft which have undergone major changes and/or repairs/modifications as defined by 14 C.F.R. 1.1 § 21.93, since the last time they raced in the NCAR or in the previous twelve months as specified in the Official Rules of Competition. RARA queries each owner/operator in writing as part of the race entry process to determine whether or not a major repair/modification affecting weight, balance, structural strength, performance, power plant operation, flight characteristics, or other qualities affecting airworthiness has been performed in the specified time period. Entries identified as having undergone a major repair/modification are reviewed by both RARA and the FSDO to ensure there has been compliance with current FAA requirements regarding the specific major repair/modification, that the operating limits issued by the FAA reflect the current aircraft configuration, and that all required flight testing, as specified by the involved FSDO, are appropriately documented and signed off in the aircraft log book. RARA intends to work with the FAA and each of the classes of racing to make the above-referenced review an item of special emphasis in connection with the 2012 NCAR for any aircraft identified pursuant to the above stated criteria. Moreover, RARA, working with both the FAA and representatives of each class of racing, is undertaking a review of its existing processes/procedures in order to determine if they can be more effectively implemented in a manner consistent with the FARs. -From Michael J. Houghton, President and CEO (July 12, 2012): On July 9, 2012, the Reno Air Race Association, Inc. ("RARA") sent its responses to the April 10, 2012, recommendations made by the NTSB to RARA. On July 11, 2012, the FAA released the draft of Advisory Circular ("AC") 43-209A, entitled "Recommended Inspection Procedures for Former Military Aircraft." It is noted in paragraph one of that draft AC that it "provides recommendations for the development of inspection program requirements for the certificates of former military aircraft in the experimental category for the purpose(s) of exhibition and air racing that operate in the United States in accordance with Title 14 of the Federal Code of Regulations (14 C.F.R.) Part 21 , §21.191 (d) and (e)." The FAA has asked for comments on the draft by August 9, 2012. Inasmuch as the draft AC was not issued until after we sent our responses to the recommendations of the NTSB, particularly A-12-13, RARA did not have the benefit of having reviewed and/or commented on it in the context of our response. However, the NTSB should be assured that RARA will, as part of its ongoing review of its procedures and processes, consider the draft AC and extent to which the information/recommendations contained therein should be implemented by RARA. Thank you for permitting RARA to participate in this important undertaking.