We are aware that pilots in the northern U.S. often intentionally fly through layers of stratus clouds, knowing they will collect some ice. They learn about ice via the school of hard knocks rather than in an organized, safe fashion. Given the number of icing-related accidents of non-FIKI general aviation aircraft, we are deeply concerned about the absence of a legal way for pilots of those aircraft to get hands-on training so that they can make well-informed decisions about dealing with it safely. In our opinion, this is a gaping hole in the FAA's obligation to increase the level of flight safety-especially as no simulators exist that can reasonably duplicate the behavior in ice of the airplanes that most often collect it. We, nevertheless, do NOT recommend non-FIKI training in icing conditions.
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