(b) Precipitation conditions.-For precipitation conditions, the following apply:

(1) The airplane must have a means to maintain a clear portion of the windshield, during precipitation conditions, sufficient for both pilots to have a sufficiently extensive view along the flight path in normal flight attitudes of the airplane. This means must be designed to function, without continuous attention on the part of the crew, in

(i) Heavy rain at speeds up to 1.6 VS1, with flaps retracted;

(ii) The icing conditions specified in 25.1419 if certification with ice protection provisions is requested.

(2) The first pilot must have a window that

(i) When the cabin is not pressurized, is openable under the conditions prescribed in subparagraph (1) of this paragraph and provides the view specified in that paragraph; and

(ii) Gives sufficient protection from the elements against impairment of the pilot's vision.

ANNEX F

BEFORE THE CIVIL AERONAUTICS BOARD, WASHINGTON, D.C.

(Docket No. —)

Aircraft Owners and Pilots Association, Petitioners v. Civil Aeronautics Board,

Respondent

PETITION TO AMEND CIVIL AIR REGULATIONS

The Aircraft Owners and Pilots Association hereby requests that the Civil Aeronautics Board amend Sections 3.382 and 4b.351 of the Civil Air Regulations to provide specific measurable visibility standards from the pilot's seat with respect to the following:

(a) Angle forward above the horizon unbroken.
(b) Angle forward below the horizon unbroken.

(c) Angle above the horizon 90° to left.

(d) Angle below the horizon 90° to left.

(e) Angle to the left.

(f) Angle to the right.

It is further requested that definite and measurable standards be fixed requiring visibility from the cockpit directly above, below and to the rear of the aircraft either by direct view, by optical means, or other devices.

This petition is based upon the following facts:

The present regulations Sections 3.382 and 4b.351 above specified are general in terms and do not provide for adequate minimum standards of cockpit visibility. Air carrier aircraft which have been built under the standards of Part 4 and subsequently Part 4b of the Civil Air Regulations are inadequate with respect to cockpit visibility. Of six models of air carrier aircraft examined, not one met the minimum standards recommended by Report No. 32 of Committee S-7 of the Society of Automotive Engineers, Inc., which is composed of twelve representatives of airline and large plane manufacturers.

The record of aircraft collisions demonstrates that an important factor common to the collisions, which factor caused or contributed substantially to the cause of the accidents, was the limited visibility from the cockpit of either one or both of the planes involved.

Respectfully submitted.

AIRCRAFT OWNERS & PILOTS ASSOCIATION
By J. B. HARTRANFT, Jr.

President-Petitioner.

STATE OF MARYLAND,

County of Montgomery, 88:

J. B. Hartranft, Jr., being first duly sworn deposes and says that he is President of Aircraft Owners and Pilots Association, Petitioner in the foregoing petition; that he has read the foregoing petition and that to the best of his informa

tion and belief every statement contained in the petition is true and no statement in the petition is misleading.

J. B. HARTRANFT, Jr.

Sworn to and subscribed before me this 15th day of March, 1956.

CLARENCE C. KEISER,
Notary Public.

My commission expires May 6, 1957.

ANNEX G

AOPA POSITION: FAAP PRIORITIES

1. Statutory Basis.-The Federal Airport Act provides in Sec. 3 that the National Airport Plan is "to provide a system of public airports adequate to anticipate and meet the needs of civil aeronautics . . . and shall not be limited to any classes or categories of public airports" and that the Administrator shall "take into account the needs of both air commerce and private flying The Act provides in Sec. 4 that the Administrator may grant funds for the establishment of a Nationwide system of public airports adequate to meet the present and future needs of civil aeronautics..."

2. Agency Policy.-Priorities for Allocation of Federal Funds are established by AC 150/5100-2 dated 5/9/66 and Policy Statement dated 5/24/66.

8. AOPA agrees that.—(a) Requests exceed funds available; (b) Priorities are necessary; (c) Best use of available funds should be made.

4. AOPA disagrees with.-(a) The priorities established; (b) the underlying concept that funds should be concentrated at airports with a "significant volume of commercial air traffic" regardless of the fact that other airports needed to complete the system have not been established.

5. AOPA Recommended Priority.-Requests for aid should be satisfied in the following order:

(a) Initial purchase of land and initial development to provide a new public airport to complete the National Airport Plan.

(b) Provision of improvements to meet minimum standards for elementary (i.e., parking, lighting, etc.) airport facilities.

(c) Provision or improvement of airports to relieve congestion at major airports in metropolitan areas.

(d) Provision of Category I capability at airports without any instrument capability.

(e) Improvements to provide additional runway and ramp capacity at existing airports.

(f) Provision of Category II capability.

(g) Improvements to existing facilities by enlarging, strengthening or marking runways, taxiways and ramps.

(h) Provision of Category III capability.

REASONS FOR AOPA POSITION ON FAAP PRIORITIES

(1) The primary purpose of the Federal Airport Act is to establish a nationwide system of airports to meet existing and future needs of civil aeronautics. All other considerations are secondary.

(2) The best use of Federal aid is to encourage provision of fundamental and essential facilities. Improvements above this minimum level should take lesser priority in the order of their sophistication.

(3) Loss of privately-owned, public-use airports due to tax and economic pressure is creating an airport shortage. The surest remedy is public ownership. (4) The ability of a community to survive depends on its ability to participate in the air commerce system. Carriage for hire is only a part of air commerce. Not-for-hire operations are also vital to the economy.

(5) Completing the airport system will serve more additional people and their communities than adding improvements to a few airports.

(6) Meeting existing needs will pave the way for satisfying more sophisticated future needs by making more of the public aware of the benefits of airport development.

(7) AOPA's priority list is more likely to generate broader public and congressional support for airport development since it enables new service for new peo

ple and new communities instead of merely improving service for those already served.

(8) The high priority projects:

(a) Are generally low in cost and therefore a great number can be undertaken.

(b) Will procure the most time and cost critical item-land-which will increase in cost more rapidly than labor or material.

(c) Will expand and complete the system, thereby making the aircraft and each existing airport even more useful and valuable.

(d) Will not eliminate low priority projects because the number and cost of high priority projects is unlikely to require all the funds, whereas satisfying sophisticated requirements first is likely to preempt most funds; nor is there sufficient money to complete all such projects anyway.

Mr. FRIEDEL. I want to thank you very much, Mr. Kayne. I will reserve my time.

Mr. Dingell, have you questions?

Mr. DINGELL. No questions, Mr. Chairman.

Mr. FRIEDEL. Mr. Devine?

Mr. DEVINE. I am glad you appeared here today. One, you are in a position to give us valuable information, and, two, I have had a good bit of mail from the general aviation segment, which always seems to be in a defensive position. Apparently they feel they have been badly handled by the press or someone because every time there is a midair collision there is an inference that it is the fault of general aviation. I think that is one of the reasons we asked the representative of AOPA to appear, in order that you may give your views on the subject and point out that all these accidents, of course, are not due to private aviation. You have a very rich background. I have read your biography that is attached to your statement. You are aware of all the problems of the air traffic controllers. I think that is one of the sensitive areas that has to do with air safety, particularly midair collisions.

In going over your testimony, I would like to ask one question in the area of visibility. You point out in your statement that there is a strong objection to increased visibility, or at least changing the air frame structure by the air frame manufacturers. Would you tell the committee for the record why is there that objection? What is the reason?

Mr. KAYNE. Mr. Devine, I think you are referring to my statement which was carried more or less in full starting on page 6 of the written testimony. We did include a statement there. This is more or less historical at this point. There was a statement that there was strong objection from the airframe manufacturers with respect to imposing, you might say, rigid and detailed minimum standards for cockpit visibility. Captain Ruby very competently touched on that this morning when he, in effect, stressed some of the difficulties that an airframe manufacturer has in increasing the visibility for the pilot from within the cockpit.

Mr. DEVINE. He suggested decreasing, actually, in the more sophisticated aircraft. In the SST when we saw the mockup on the west coast, they have to drop the nose prior to landing so they can see when they come in.

Mr. KAYNE. I believe there are some foreign models of the SST projected that will have a shield that will drop in front of the windshield when they are at high altitude in flight, to protect the windshield from undue heat and pressure, and so on.

In any event, obviously, as airplanes got faster and the pressure or stress on the hull of the airplane, including the windshield became greater, the tendency, of course, was to make the windshield smaller and stronger. If you have a large expanse of glass, this means that the glass has to be much stronger to withstand the pressure over a larger

area.

So there apparently has been some tendency to reduce visibility. I might stress again that our recommendation here is not directed particularly at airline aircraft. It is airline aircraft, yes, but also we would like to see better visibility out of some of our general aviation aircraft. Mr. DEVINE. Are we getting to the point of no return on speed, perhaps?

Mr. KAYNE. I would not try to minimize the difficulties, Mr. Devine, of the manufacturers or designers in producing high speed aircraft with better visibility from them. The military at one time or another have approached this by placing the pilots in, you might say, a bubble configuration, so that he was elevated above the fuselage a little bit and could see out better. There have been a number of schemes on this. This is one that we would like to see greater concentration on, on the part of not only the manufacturers and researchers, but we think possibly NASA should be able to contribute some very good research work in this field.

Mr. DEVINE. To get to another area, would it be your opinion, Mr. Kayne, that proximity warning indicators in general aviation aircraft, which would be perhaps within the financial means of some of the private pilots, and collision avoidance systems on the commercial aircraft, the two devices, although having the same purpose but being different in operation, do you think they would help solve some of these midair problems?

Mr. KAYNE. I think they would help greatly, sir. I know there has been some discussion informally between pilots. In fact, we have talked this over with some of the airline pilot group. There was some talk of that at their last safety forum here in Washington. The thinking is that the airlines, and this is my personal opinion, too, must have a collision avoidance system in their aircraft, for one.

Two, we have conceived this proximity warning indicator, which I will refer to as PWI, as a simple device, possibly on a noncooperative basis, so that this gives you warning of someone else in your vicinity. We hope that could be a building block to go into the collision avoidance system. If it would not be, then you could carry the two systems, say, in an airline airplane. We could carry one but they could carry both the sophisticated and the simple system and then they would have protection against themselves and protection against any intruder of any kind that did not have a system or if the collision avoidance system was not operating.

Mr. FRIEDEL. I know back in 1957-58, an invention was placed on the dashboard of an aircraft and there would be an indication that if a plane was coming from the right, the light would light, on the right side, or from the left on the left side, and at mileages that were indicated. The only thing you could not do with that was to tell at what altitude the plane was. I believe this is a simple device and not very expensive, so far as I know. That would be a tremendous help to the general aircraft, the small planes. Why that was not pursued, as

I would like to see it pursued, I cannot understand. I think it is not expensive. This should be pursued immediately. At least give them that much for the smaller planes. The others may have radar that would give altitude, but the small plane would know if a plane is to the left or the right, 5 or 10 miles away, and he would start looking for it.

Mr. KAYNE. I agree with you, Mr. Chairman, we think this would be a great help. I did notice that Congressman Fascell has introduced a bill, H.R. 11677, directing the FAA Administrator to research the development of such a device. We are wholeheartedly in favor of this. We hope that this action will really be pushed.

Mr. FRIEDEL. I think they have been really slow in coming to the conclusions on this. I know in 1957 and 1958 at Atlantic City we witnessed it and they were experimenting with it then. I would like to see something move forward on this immediately. I think this was given to the Government for $1, by an inventor from Baltimore, Mr. Charles Adler. I think he deserves a great deal of credit.

That is all I have to say right now.

Mr. DEVINE. I have a question on your annex D to your statement, Mr. Kayne. You pointed out the number of collisions between commercial aviation and general aviation and the number of collisions between commercial and commercial; but you do not have statistics on midair collisions between general aviation and general aviation. Can you provide such statistics at a later time?

Mr. KAYNE, Yes. I might say that is a fairly substantial number, without equivocation. I think it is easy to understand this because quite a few of those collisions incidentally result not in a loss of life but they happen between students who are training at a small airport and they are going around and around, shooting landings and takeoffs. Invariably one of them is concentrating so much on his airplane that they brush wing tips.

Mr. DEVINE. Would you provide that information?

Mr. KAYNE. Yes; we will.

(The following material was received by the committee:)

SUPPLEMENTAL STATISTICS ON COLLISIONS BETWEEN GENERAL AVIATION AIRCRAFT, SUBMITTED BY AIRCRAFT OWNERS AND PILOTS ASSOCIATION

Congressman Devine requested statistics on collisions between general aviation aircraft similar to those provided in Annex D to AOPA's written testimony before the Subcommittee.

Our source of information on these accidents has been the Civil Aeronautics Board and now is the National Transportation Safety Board (NTSB).

We have queried the NTSB for the desired statistics, but they are either unable or unwilling to make this information available. We suggest that it can be obtained by an inquiry from the chairman of the Subcommittee.

We do have partial information indicating the number of collisions between general aviation aircraft, but we are lacking the number of fatalities. The number of collisions for each year is indicated below and we believe that the number of fatalities resulting from these collisions in each year will be somewhat less than the actual number of collisions. We have arrived at this conclusion by a process of elimination applied to available statistics. For example, in 1963 there were 11 collisions between general aviation and two collisions between general aviation and military aircraft. These collisions produced a total of six fatalities. In 1964, the ratio was 12 general aviation and two general aviation military collisions with a total of 11 fatalities.

Collisions between general aviation aircraft are as follows: