Notice of Proposed Rule Making

Docket Number: FAA-2007-29281

Notice Number: 08-06

Comments By:

Harold F. Phillips

**Introduction**

In this paper I will discuss the Notice of Proposed Rule Making over the
use of polishing frost and how if passed will do away with this
procedure and the terminology in FAR 91. 527, 125.221, and 135.227. I
will also give my comments over the proposal.

**Summary**

This Notice to Proposed Rulemaking is stating that the ability for
pilots and aircraft owners to "polish frost" off the wings is
politically incorrect and not a safe practice to follow. FAR 91.527, FAR
125.221, and FAR 135.227 are the focus of this notice.

FAR 91.527 reads no pilot may take off an airplane that has -- (1)
frost, snow, or ice adhering to any propeller, windshield, or power
plant installation or to an airspeed, altimeter, rate of climb, or
flight attitude instrument system, (2) snow or ice adhering to the wings
or stabilizing or control surfaces; or (3) any frost adhering to the
wings or stabilizing or control surfaces, unless that frost has been
polished to make it smooth.

FAR 125.221 and FAR 135.227 state no pilot may take off an airplane that
has frost, ice, or snow adhering to any propeller, windshield, wing,
stabilizing or control surface, to a power plant installation, or to an
airspeed, altimeter, rate of climb, or flight attitude instrument
system, except that takeoffs may be made with frost adhering to the
wings, or stabilizing or control surfaces, if the frost has been
polished to make it smooth.

In part 91.527 the phrase "unless that frost has been polished to make
it smooth." will be omitted. Parts 125.221 and 135.227, the phrase
"except that takeoffs may be made with frost adhering to the wings, or
stabilizing or control surfaces, if the frost has been polished to make
it smooth." will also be omitted.

The research provided demonstrate that the risk of having any frost on
the wing will cause the wing to produce less lift and be a hazard to the
operation of the aircraft in question, and the safety of the crew and
passengers. Research has shown that the maximum lift of the aircraft in
question may decrease as much as thirty percent, the angle of attack for
maximum lift may be reduced by several degrees, increased parasitic drag
will be created, and the handling and performance of the aircraft may
change unexpectedly from that of an uncontaminated aircraft.

Research on the economically impact was also conducted and found that
the benefits will out way the cost severely. All companies that are
abiding under the described FARs above will have no problem financially
to prevent or remove frost form the wings of their aircraft.

**Comments**

I am in favor of this Notice of Proposed Rule Making. There is no
reason, in my opinion, to not change FARs 91.527, 125.221, and 135.227.
The research provided proves that frost is a hazardous to flight and
that to fix this problem will not be a financial burden to anyone.

There is no safe way to fly an airplane with frost on the wings. I am an
aviator myself and the thought of knowing that aircraft can depart an
airport with frost of any kind on the wings is a scary one. The
performance of that aircraft in an emergency will not be as good as it
needs to be. In slow flight the aircraft is closer to a stall than if
the crew had deiced the wings and incase of a missed approach to land
this could be detrimental if they needed to hit their best angle of
climb to miss an obstacle.

The plan to prevent and remove the frost will not be a financial burden
according to the research within the NPRM. The estimated costs for all
who are affected will not affect them in a major way due to the fact
their profits are much higher than the cost.

**Conclusion**

I have reviewed this NPRM and found myself in favor of removing the
terminology of departing with "Polished Frost" and banning any such
procedure to be used within the United States. The use of such a
procedure would be a breach in the duty of a safe flight to any
passenger flying on any aircraft that didn't remove the frost completely
or to the specification of the FAR.

**Reference**

(nd), DOT and FAA, Notice of Proposed Rule Making. Docket Number:
FAA-2007-29281, Notice Number: 08-06, RIN 2120-AJ09