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NTSB · Safety Recommendation

Safety Recommendation A-12-041

Recommendation

TO THE EXPERIMENTAL AIRCRAFT ASSOCIATION: Work with your membership, aircraft kit manufacturers, and avionics manufacturers to develop standards for the recording of data in electronic flight displays, engine instruments, or other recording devices to be used in support of flight tests or continued airworthiness of experimental amateur-built aircraft.

Safety Issue and Context

Experimental amateur-built (E-AB) aircraft represent nearly 10 percent of the U.S. general aviation fleet, but these aircraft accounted for approximately 15 percent of the total-and 21 percent of the fatal-U.S. general aviation (GA) accidents in 2011. Experimental amateur-built aircraft represent a growing segment of the United States' general aviation fleet-a segment that now numbers nearly 33,000 aircraft. The National Transportation Safety Board (NTSB) undertook this study because of the popularity of E-AB aircraft, concerns over their safety record, and the absence of a contemporary and definitive analysis of E-AB aircraft safety.

The study employed several different methods and data collection procedures to carefully examine this segment of U.S. civil aviation. This comprehensive approach resulted in a detailed characterization of the current E-AB aircraft fleet, pilot population, and associated accidents. Four sources of data formed the basis of this study. First, the NTSB performed a retrospective analysis of accident and activity data over the last decade to compare the accident experience of E-AB aircraft with that of similar non-E-AB aircraft used in similar GA flight operations.

Second, the NTSB conducted in-depth investigations of all E-AB aircraft accidents during 2011, which provided a case-series of accidents for more detailed analysis. Third, a broad survey of the community of aircraft owners and builders was conducted by the Experimental Aircraft Association (EAA) in July and August 2011, and the data were made available to the NTSB for analysis to understand the population of E-AB aircraft builders and owners.

Finally, discussions with EAA representatives, Federal Aviation Administration (FAA) officials, E-AB aircraft builders and owners, kit manufacturers, and representatives of E-AB aircraft type clubs provided insights on E-AB aircraft safety issues and solutions.

Response History

July 16, 2025 · Recipient Response · Experimental Aircraft Association

-From Jack J. Pelton, CEO and Chairman of the Board: For more than 70 years, the Experimental Aircraft Association (EAA) has contributed significantly to the continual improvement of the general aviation safety record. When the NTSB approached us in 2011 with the intent to study the root causes of experimental amateur-built aircraft fatal accidents, we agreed to support the effort. We assisted the NTSB by completing survey work that resulted in the 2012 Safety Study: The Safety of Experimental Amateur-Built Aircraft. In the past 13 years, EAA has been actively working to address the recommendations designated to us in this study and additional recommendations directed to us in 2021.

We have made significant progress and are continually working to improve the experimental safety record, as demonstrated by the reduction in experimental aircraft fatal accidents. To wit, in FAA Fiscal Year 2012 there were 73 fatal accidents in experimental aircraft. In Fiscal Year 2024, there were 37 accidents. This is despite the hours flown in experimental aircraft increasing by more than 350,000 from Calendar Years 2012 to 2023. We are not resting on our laurels by any means. There is ongoing involvement with the General Aviation Joint Safety Committee (GAJSC) to find non-regulatory solutions to improving safety records in general aviation.

EAA has created, promoted, and helped to implement the usage of multiple safety improvement tools in the past five years, including the EAA Flight Test Manual 2.0, which creates a framework for flight testing a homebuilt aircraft and is now part of a formal task-based flight testing program incorporated, optionally, into homebuilt operating limitations.

Additionally, EAA has published a guide for non-builder owners of experimental aircraft, to assist prospective buyers and owners of experimental amateur-built aircraft. This non-builder, or “second owner” demographic, was identified as a significant opportunity for improvement in the 2012 NTSB safety study. There is ongoing involvement with the GAJSC to find non-regulatory solutions to improving general aviation safety records.

In this communication, we respond to the safety recommendations and provide updates on the progress to address the recommendations since they were issued:

EAA worked with the three major avionics manufacturers for experimental aircraft to standardize their data recording rate to at least 1 Hz. This allows most homebuilders with modern avionics suites to record all data from test flights, as well as ongoing flight quality assessment through third-party service providers.

Read Recommendation

Recommendation Facts

Status
Open - Acceptable Response
Issued
July 12, 2012
Priority
CLASS II
Recipient
Experimental Aircraft Association
Adopted
May 23, 2012
Related Investigation
DCA12SS005
Related Report
SS-12-01

Version 2.0 of the EAA Flight Test Manual includes new flight test procedures that are friendlier to electronic data recording, while retaining the option of manual logging in the individual test cards. Additionally, new tests have been added to validate modern avionics systems, including EFIS outputs, angle of attack, and autopilots.

General aviation aircraft owners, amateur-built and otherwise, now have access to a range of products that analyze both airframe and engine parameters. They can constantly monitor engines for early signs of failure and grade or coach pilots on their performance in critical phases of flight. EAA and its members have been involved with the testing and development of several of these apps and software packages. Between this work and the efforts, we have undertaken to ensure data outputs are usable for analysis; we believe the intent of this safety recommendation is met.

Conclusion

During the past 15 years, EAA has worked closely with the FAA and industry on many safety initiatives not only for the amateur-built community, but for all of general aviation. EAA is highly involved in the General Aviation Joint Safety Committee (GAJSC) as an industry co-chair and as a subject matter expert in various working groups. On this committee we have met and exceeded our goals for improving the safety of the general aviation community.

EAA continues to commit to improving the safety of recreational aviation activities in all of its forms, particularly experimental amateur-built aircraft. We appreciate our unique ability to work collaboratively with the National Transportation Safety Board members, as well as your staff. This relationship has allowed us to make meaningful improvements in safety. EAA will continue to foster improvements to safety in the experimental flying community.

We thank you for your interest in the safety and vitality of the amateur-built sector of aviation. We stand ready to continue to work with you, your fellow board members, and your dedicated staff now and in the future.

March 12, 2019 · NTSB Correspondence · Experimental Aircraft Association

We note that you are working with three avionics manufacturers to develop recording technology that includes readable electronic memory within electronic flight instrument system (EFIS) flight displays for EA-B aircraft. You indicated that the data gathered from the EFIS flight displays would be linked to an electronic copy of the flight test manual and used to develop an aircraft-specific POH. We also note that you are compiling a list of other manufacturers who are developing similar technology so that they can be included in the standard-development process.

We believe that your efforts thus far are responsive to this recommendation. Pending periodic updates and the developed standards, Safety Recommendation A-12-41 remains classified OPEN—ACCEPTABLE RESPONSE.

August 20, 2018 · Recipient Response · Experimental Aircraft Association

-From Sean Elliott, Vice President, Advocacy and Safety: EAA is working closely with three major avionics manufacturers to develop recording technology within EFIS flight displays for experimental aircraft. Garmin, Dynon, and Advanced Flight Systems have all made significant progress in electronic data gathering technology, and continue to reach new limits with their EFIS displays. As development continues, these manufacturers and EAA are working together to make readable electronic memory available to be used in flight testing experimental aircraft.

We plan to link the data gathered from the EFIS flight displays to an electronic copy of the Flight Test Manual in order to develop a Pilot Operating Handbook (POH) specific to that aircraft. After the data is received by the manual, pilots would have information for that individual aircraft, and would be able to fly based on its specifications.

While working with the three main avionics manufacturers, EAA continues to explore the progress that has been made by other manufacturers. We are gathering a list of companies working on this type of technology so that we can work together to create standards.

April 17, 2013 · NTSB Correspondence · Experimental Aircraft Association

We believe that the plan you described for exploring the feasibility of, and potential methods for, developing voluntary standards for electronic data gathering will satisfy this recommendation, once that plan has been implemented. In the meantime, pending our review of the standards once they have been developed, Safety Recommendation A 12-41 is classified OPEN—ACCEPTABLE RESPONSE.

January 24, 2013 · Recipient Response · Experimental Aircraft Association

-From Jack J. Pelton, Chairman of the Board: EAA, working with avionics and equipment manufacturers, will explore the feasibility and potential methodology of developing voluntary standards for electronic data gathering. This will necessarily be a long-term effort, as most data processing and collection today follows proprietary methods specific to each manufacturer and device. We do have some concern that the NTSB may be overestimating the prevalence and installation rate of devices with recording capability in amateur-built aircraft.

These devices are found in some higher-end aircraft, but as a percentage of the fleet, they represent a relatively small segment so the safety dividends of this effort could be limited. However, we agree that over time, avionics and instruments with data recording capability will gradually continue to become more prevalent in amateur-built aircraft.

We caution the NTSB that there is concern within the pilot/owner/builder community over the cost of this equipment and the potential use of collected data. Experience has shown that data collected by avionics and instruments has been used as evidence against a pilot or aircraft builder in liability legal proceedings. This precedent has had a chilling effect on the use and documentation flight data in support of flight testing and continued airworthiness.

While these are difficult challenges with no short-term solutions, EAA is committed to engaging with equipment manufacturers and our members to seek solutions and accommodations for increased and more comprehensive use of data in support of flight-testing and maintenance of amateur built aircraft.