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Safety Recommendation Details

Safety Recommendation A-12-009
Details
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 NATIONAL AIR RACING GROUP UNLIMITED DIVISION: Require aircraft owners in the unlimited class 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
Is NPRM: 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: 3/28/2013
Addressee(s) and Addressee Status: National Air Racing Group Unlimited Division (Closed - Acceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: National Air Racing Group Unlimited Division
Date: 3/28/2013
Response: The UDNAG Rules Committee completely rewrote Appendix C, “Aircraft Specifications” to include the recommended revisions. This revision required a vote of UDNAG members qualified to vote on rules changes. On February 15, 2013, the Revised Appendix C was approved. Such revisions would normally take affect January 1 of the year following the vote to approve the revision; however, the revisions to Appendix C were immediately implemented. We commend UDNAG for these revisions, and in particular for immediately implementing them. With the revisions to Appendix C, Safety Recommendation A-12-9 is classified CLOSED—ACCEPTABLE ACTION.

From: National Air Racing Group Unlimited Division
To: NTSB
Date: 2/25/2013
Response: -From Thomas L. Camp, President: My August letter stated that implementation of this recommendation will improve safety for not only race fans but for our race pilots also. Our Rules Committee (Committee) considered this Safety Recommendation and concluded that we should require any aircraft owner/operator whose aircraft has undergone a major change or major alteration, as those terms are defined by the FAA, to provide Unlimited Division of the National Air-racing Group, Inc. (UDNAG) with copies of all relevant engineering evaluation data and flight demonstration materials and required analyses, plus provide the UDNAG with copies of all approvals by the FAA for any such change or alteration to the aircraft. These requirements should apply only to aircraft that have undergone changes or alterations since their last participation in an air racing event. We had not determined whether implementation of this recommendation would require a change in the UDNAG rules; however we noted that, should a rules change be required, we would consider early adoption. Following a successful 2012 National Championship Air Race event, our Rules Committee decided the best way to address this Safety Recommendation was to completely rewrite Appendix C, Aircraft Specifications. That, of course, is a revision of our UDNAG Official Competition Rules and requires a vote of our members qualified to vote on rules changes. On February 15, 2013, the Revised Appendix C was approved (March 1, 2013) with immediate implementation rather than on January 1, 2014 as provided under our bylaws. We believe that our Revised Appendix C goes further than the Board’s Safety Recommendation (A-12-9) and, therefore, the Board should be able to close this last and final issue. A copy of the Revised Appendix C is attached for review by the Board and its staff assigned to the accident investigation. We appreciate the opportunity to assist the NTSB with its final recommendation for the Unlimited Division. APPENDIX C UNLIMITED DIVISION OF THE NATIONAL AIR-RACING GROUP (UDNAG) AIRCRAFT SPECIFICATIONS These Specifications are the only official and approved aircraft specifications of the UDNAG and are a specific part of the Official Competition Rules (OCR's) of the UDNAG. Failure to comply with these specifications will result in disqualification of pilot and/or aircraft from race competition. Disqualification will be implemented by the UDNAG Board of Directors upon recommendation of the UDNAG Technical Committee and/or the UDNAG Procedure Rules Committee. I. GENERAL SPECIFICATIONS A. Aircraft must have a current registration certificate and a certificate of airworthiness issued by the Federal Aviation Administration. All certification, registration and current airframe, engine and propeller maintenance records must accompany the aircraft and be available for inspection by the FAA, the UDNAG Technical Committee and the event organizer. The owner/operator is responsible for compliance with all FAA rules and regulations applicable to the UDNAG race aircraft. B. UDNAG race aircraft must pass an inspection by the UDNAG Technical Committee at each racing event prior to practice, qualification or racing and at any other time during the racing event if deemed necessary by the event organizer or the UDNAG Technical Committee. C. Aircraft must display an assigned racing number on each side of the fuselage or tail and on the lower surface of the right wing, with the number facing inboard. The numbers must be at least 30 inches high and in a highly contrasting color. A stroke width of two-and-one-half (2.5) inches (minimum) is recommended. D. Aircraft must be flown by the pilot in the aircraft, (i.e., no remotely piloted aircraft). E. The specifications set forth in this document may be temporarily changed at a race site for the duration of that event only by a unanimous vote of all members entered as pilots (or race qualified members if after qualification). Bylaws of the UDNAG, Article VII, Section 1, Paragraph (g). F. For a member of the UDNAG to reserve and pay for a race number, that member must currently own an aircraft that he intends to race or must currently be building an aircraft that he intends to race, and that member must be able to prove either option to the UDNAG Board of Directors. If a new aircraft project is not completed in five years, the member looses the number for one year; if that number is not taken by another member within that year, then the member can reapply for that number if it can be proven that work is progressing on the project. If the holder of that race number has not entered and attempted to race the aircraft for which the number was obtained within the past five years (with respect to the date of passage of this added rule), the holder looses that number. That number will then be available for other owners with current aircraft to pay for and use. The number will be good for the entire calendar year in which it was paid and must be renewed yearly. The member will lose the number if it is not renewed by April 1 of each year. Numbers cannot be lent from member to member without approval of the UDNAG Board of Directors on a case-by-case basis. II. ENGINE AND PROPELLER A. All UDNAG race aircraft must be propeller-driven and powered by a reciprocating engine or engines. The propeller must be driven by the reciprocating engine. (Rotary engines are considered to be reciprocating.) No aerodynamic turbine, turboprop or rocket thrust devices may be used. Exhaust-driven superchargers are permitted. B. There are no other restrictions on engines or engine modifications. C. Propellers used may be those that have been previously used on production aircraft and may be used either in the stock configuration or in a shortened or trimmed configuration. New custom propellers made from components not used on production aircraft, whether using composite, synthetic, or any other materials may also be used, but flight test verification at anticipated race speeds and race power settings of that exact propeller must be provided to the UDNAG Board of Directors. The UDNAG Board of Directors may, if they deem it necessary, require the owner/operator to have the design and flight test data reviewed by qualified technical personnel for this purpose in a similar manner to which "Custom Built" aircraft designs are reviewed. The UDNAG race aircraft owner/operator will bear the costs of this review. III. AIRFRAME A. There are no restrictions on airframe modifications. B. All UDNAG race aircraft and any major change or alteration thereto (FAR 21, Section 21.93, FAR 1.1 or FAR 91, Section 91.9 and any other applicable FARs) must be designed to accepted structural design criteria to meet the limiting load factors of +6.0 g and -3.0 g and must be capable of demonstrating these load factors if required by the UDNAG Technical Committee. Positive load factors will be verified by demonstration, and negative load factors may be verified by submission of computational methods and procedures, which must be available for review. Flight testing at anticipated race speeds and race power settings must be completed and documented by the UDNAG race aircraft owner/operator no less than 90 days before participation in an air racing event. C. UDNAG race aircraft that are not modified versions of previously designed and built fighter aircraft and any previously designed and built UDNAG race aircraft that has had a major change or alteration incorporated since the last time the UDNAG race aircraft participated in an event sanctioned by the UDNAG will be designated as "Custom Built" aircraft. The UDNAG race aircraft will be required to meet certain design and test criteria to ensure its safe operation, above and beyond those criteria specified in the preceding sections. The design of any flight-worthy aircraft should, for the safety of the pilot and those on the ground, be substantiated by the proper computational analysis and receive approval from the FAA. The following criteria are considered essential to ensure that an aircraft is properly designed and adequately tested. 1. Structural load analysis for the +6.0 g and -3.0 g load factors, including consideration of design loads, limit loads, and ultimate loads, will be submitted. The ground rules and basic calculations for the structural load limits must be presented in a format that indicates the aircraft designer is familiar with and has used accepted aircraft design procedures and safety factors. 2. A flight flutter test 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 configuration flight envelope. 3. Weight and balance data for an empty and full UDNAG race aircraft will be submitted. Weight and balance documentation must include the forward and aft center-of-gravity (CG) limits for the UDNAG race aircraft in its actual race configuration. 4. The flight test plan and flight test results must be documented and submitted to verify safe operation of the UDNAG race aircraft within its flight envelope at anticipated race speeds and race power settings. 5. The items specified in 1 through 4 above will be made available by the UDNAG race aircraft owner/operator no less than 90 days before participation in an air racing event for review by the UDNAG Technical Committee to ascertain the validity and credibility of the submitted data. The UDNAG Board of Directors may require, upon recommendation of the UDNAG Technical Committee, impartial qualified personnel such as Registered Professional Engineers or people known to be experts in their fields, to review and comment on the data. The review will be made far enough in advance that appropriate modifications, recommended by the qualified experts, if necessary, can be implemented, tested and re-evaluated. The UDNAG race aircraft owner/operator will bear the costs of this review. 6. Evidence of FAA approval of items 1 through 5 above plus demonstrated compliance with any and all additional requirements or criteria as may be required or deemed applicable by the FAA or event organizer must be submitted by the UDNAG race aircraft owner/operator before participation in an air racing event. IV. FUEL AND FUEL TANKS A. Any type of fuel or additive may be used. V. SAFETY AND EQUIPMENT A. All UDNAG race aircraft must have an operable oxygen system, which must be used when practicing, qualifying and racing. Oxygen masks must be the “Military Type;” rebreather bag type masks are not permitted. B. UDNAG race aircraft must have a seat belt and shoulder harness, which must be used when practicing, qualifying and racing. C. UDNAG race aircraft must be equipped with a functioning two-way communication radio, which must be used when practicing, qualifying and racing. The radio must have transceiver tuned to race frequency at all times during a race. Pilot must use a second radio if he desires to communicate with his ground crew during a race. D. It is recommended (but not required) that a UDNAG race aircraft be equipped with fire extinguishing systems for the cockpit and engine compartment. E. UDNAG race aircraft weighing less than 5,000 pounds gross takeoff weight must have an aft facing light mounted in the aft fuselage or tail section of the aircraft that can be clearly seen from a distance of 3,000 feet, and this light must be on at all times when the aircraft is on the racecourse. This light is to warn on-coming aircraft that a low profile hard-to-spot aircraft is ahead. It is recommended that all UDNAG racing aircraft install such a light as a safety item. (Sometimes ground colors and aircraft colors are not quickly discernible when an aircraft is being approached from the rear at high speed in traffic). F. All high-pressure gaseous storage bottles (above 500 psig) must be hydrostatically tested and certified every five years. Proof of certification within five years, as of the date of the inspection, must be presented to the UDNAG Technical Committee before a UDNAG race aircraft will be allowed on the racecourse.

From: NTSB
To: National Air Racing Group Unlimited Division
Date: 9/28/2012
Response: The UDNAG’s race committee concluded that it should take the recommended action, although it has not yet determined whether this will require a change in the organization’s rules. If a rule change is required, it would become effective on January 1 of the year following approval. However, because the UDNAG believes that early adoption was warranted, for the 2012 NCAR the UDNAG asked the Reno Air Racing Association (RARA) to provide a list of all entries, indicating whether or not the owner/operator has reported a major change or alteration to an aircraft. For aircraft for which a major change or alteration is reported, the UDNAG asked RARA officials to request evidence showing that an engineering evaluation and a flight demonstration within the anticipated flight envelope of the aircraft have been performed. We stated during our August 27, 2012, Board Meeting that we were pleased that the UDNAG had taken steps to further scrutinize aircraft entered in the 2012 NCAR, and we encouraged the UDNAG to expedite its review so that rulemaking can be incorporated before the 2013 NCAR. Accordingly, at the meeting, Safety Recommendation A-12-9 was classified OPEN—ACCEPTABLE RESPONSE, pending further updates on the UDNAG’s progress in responding to this recommendation.

From: NTSB
To: National Air Racing Group Unlimited Division
Date: 8/22/2012
Response: Correspondence control #201200364 was closed administratively, see correspondence control #201200449. No response letter was mailed using correspondence control #201200364.

From: National Air Racing Group Unlimited Division
To: NTSB
Date: 8/22/2012
Response: -From Thomas L. Camp, President: On July 6, 2012, I responded to the NTSB’s Safety Recommendation letter dated April 10, 2012. At that time, I informed you and the NTSB that we, the Unlimited Division of the National Air-racing Group, Inc. (UDNAG), would not comment or implement the Safety Recommendations until the NTSB completes its investigation and issues its final report and all factual reports to the public. Since the time of our initial response, we have had several discussions with NTSB staff and believe that we can, at this time, respond to the Board’s Safety Recommendations. We believe that implementation of this recommendation will improve safety for not only race fans but for our race pilots also. Our Rules Committee (Committee) considered this Safety Recommendation and concluded that we should require any aircraft owner/operator whose aircraft has undergone a major change or major alteration, as those terms are defined by the FAA, to provide UDNAG with copies of all relevant engineering evaluation data and flight demonstration materials and required analyses, plus provide all approvals by the FAA for any such change or alteration to the aircraft. These requirements will apply only to aircraft that have undergone changes or alterations since their last participation in an air racing event. We have not determined whether implementation of this recommendation will require a change in the UDNAG rules; however, we believe early adoption is warranted. The Reno Air Racing Association (RARA), working with the Reno FSDO, is responsible through its entry eligibility process for identifying aircraft that have undergone major changes or alterations since the last time the aircraft raced at Reno or within the last 12 months prior to the current racing event. Under RARA’s Official Rules for Competition for 2012, once RARA becomes aware that a change or alteration has occurred, the owner/operator must submit such documentation and related correspondence, as required by the cognizant FAA, to the Reno FAA and RARA at pilot registration and to the UDNAG prior to or during the pre-race aircraft inspection. In this connection, we have asked RARA this year to provide the UDNAG with a list of all entries and whether the owner/operator did or did not report a major change or major alteration. If a change or alteration has been reported, we have asked RARA officials to request evidence (if required by the FAA) supporting an engineering evaluation and a flight demonstration analysis within the anticipated flight envelope of the aircraft. The evidence obtained by RARA from the owner/operator should be made available to the UDNAG and our Class Compliance Team as soon as it is received by RARA, but no later than the pre-race aircraft inspection.

From: National Air Racing Group Unlimited Division
To: NTSB
Date: 7/6/2012
Response: -From Thomas L. Camp, President: On April 10, 2012, the National Transportation Safety Board (NTSB), over your signature, sent a letter containing four Safety Recommendations for consideration by the Unlimited Division of the National Air Racing Group, Inc. (UDNAG). These Safety Recommendations were derived from the NTSB's ongoing investigation of the September 16, 2011, accident that occurred at the National Championship Air Races in Reno, Nevada. In your letter you urged the UDNAG to take action on the Safety Recommendations and requested a response from UDNAG within 90 days addressing actions we have taken or intend to take to implement the NTSB's recommendations. We appreciate the efforts of the NTSB staff in their investigation and the Board's Safety Recommendations A- 12-9 through A-12-13. At this time, however, we are not prepared to comment on or implement the NTSB's recommendations until the NTSB's final report and all factual reports are issued. It is our understanding that these reports will be complete and made available to the public by the end of August, 2012. Following our review of these reports, we will provide you and the NTSB with a letter summarizing actions taken or to be taken relative to the four recommendations.