Removal of Regulations Allowing for Polished Frost on Wings of Airplanes

As it currently stands with flights being allowed to operate with
polished frost on their wings upon takeoff, the industry is finding
itself with unnecessary safety hazards. Overall the practice of
polishing wings is unsafe and unnecessary to have in the Federal
Aviation Regulations. The reasons behind these beliefs are the lack of
information regarding polished frost, the immense hazards caused by
frost on the wings and control surfaces, and the lack of available
resources regarding the actual polishing.

Although polished frost is mentioned in the FAR's as being an acceptable
way of removing frost from the control surfaces and wings this is
basically the extent of the information given on the subject. If a pilot
was to realize they were allowed to take off with polished frost on
their plane, but they could not find any other information on the
subject, how would they know how to do this procedure? Therefore the
practice of flying with polished frost becomes even more dangerous due
to the lack of knowledge known about it by the pilots.

While researching this NPRM as well as polished frost itself I surveyed
ten of the local flight instructors and none of them even knew of the
regulation allowing polished frost or what was meant by polished frost.
Since there is an obvious lack of knowledge and teaching practices of
polished frost, the need to keep this rule the way it is does not make
sense.

From what I believe to be some of the most important facts that prove
polished frost should be removed from the FAR's is the deaths due to
frost on the wings, as well as how drastically it changes the
aerodynamics. In the NPRM itself it is stated that 11 accidents have
occurred due to people attempting to polish or smooth frost. Although
I'm sure there have been other accidents due to frost that people did
not try to polish, but these accidents occurred due to something the
regulations specifically state to do. There should not be a regulation
so vague that no one knows the exact specifications of how to perform it
and be safe while doing it.

Frost can be very detrimental to the characteristics of flight of the
aircraft you are flying. As was stated in the NPRM there is many
different ways your plane can be affected. A contaminated wing\'s
maximum lift may be reduced by 30 percent or more. Any loss of lift can
change the characteristics flight greatly, especially if it was an
inexperienced pilot who has only flown one type of plane and they were
unable to recognize the change. The angle of attack for maximum lift may
be reduced by several degrees and could lead to panic with the pilot if
they are unaware this is going to happen. Upon takeoff roll an increase
of drag could greatly increase the distance for lift off. Even if the
frost is polished smooth the increase in drag could be drastic. Finally
the airplane\'s handling qualities and performance may change
unexpectedly from that of the uncontaminated aircraft.

For anyone who is trying to fly a plane which has frost on it, whether
polished or not, should know the risks of flying with frost. Although
I'm sure that most of the people do not take time to think of the
associated risks of flying with frost on their plane, but if someone
does not take the time to learn about these consequences, then they
should not be attempting to polish the frost smooth anyway.

In dealing with the severity of the changes of aerodynamic principles of
the plane with frost, one must take into consideration the amount of
area covered as well as the thickness of the frost on the wing. Also
stated in the NPRM the location of the roughness in accordance with the
surface leading edge where significant variations greatly affect the
airspeed and the surface air loads.

One major problem with the polishing of frost on the planes is just as
the NPRM states that the manufacturer's guidelines are to be used in
referring to the procedure of how to go about it, but no manufacturers
list how. This just leads to more confusion in regards to the polishing
of frost. How can someone recommend checking the manufacturer's
guidelines in reference to polishing frost if none of the manufacturers
provide guidelines on how to do it? Also while looking through many
supplemental materials for information on the polishing of frost on
aircraft I was unable to find any information on the process or even
that it existed outside of the FAR's at all.

In conclusion polished frost procedures should be removed from the
FAR's. The practice of polishing frost on airplanes is dangerous because
of the lack of a definition of what polished frost is. Also the effect
that frost alone can have on the aerodynamic principles of an aircraft
is dangerous and can be fatal. Finally no sources are available to gain
information on the actual polishing of the frost, or the procedures on
how to perform this task. Therefore a regulation should not be kept in
place that makes flying less safe because of its lack of structure.