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25 March 1994

Mr. Barry D. Clements Manager, Small Airplane Directorate Aircraft Certification Services Federal Aviation Agency 601 EAST 12th Street Kansas City, MO 64106

Mr. Clements:

We received a letter over your name which was illegibly signed. There is no other indication as to who wrote the letter. It must have been misaddressed since it did not respond to our letter of 5 January 1994. Nothing was said in the letter in regards to:

	a.	the basic problem of water retention in the tanks of the PA-23 series,
	b.	the failure of the PA-23 series to comply with the CARs under which it was certified,
and	c.	the entire letter was in direct contradiction to the first paragraph on the third page of our 5 January letter. We specifically asked that you not rehash the problems of the past. We are aware of the actions of the FAA in this regard and there was certainly no need to repeat them. It is apparent that the person who wrote the intended response did not bother to read the file on this case.

However, we find it difficult to criticize anyone for not reading the file on this case, since it goes back some nine years. As a matter of act, we are probably the only organization that has a complete file. The FAA has bounced the problem around from one office to another so many times that in all probability no one has a complete file.

We are painfully aware that the FAA does not agree with our simple and inexpensive solution to the problem of hidden water in the tanks of the PA-23 aircraft……i.e. to put a drain where the undetectable water collects. But, I again refer you to a research project that was done by an engineer for Cessna in about 1984 on this subject. His name is Stanley O'Brien and his report exceeds 50 pages. It is an excellent look at the problem of water contamination in aircraft tanks and the FAA should request a copy from Cessna. They may deny that they know about the report, but I have copy and will supply you with one if you so request. It emphasizes drains in the low points of all tanks. In fact Mr. O'Brien recommends several drains in the tanks in addition to the fuel supply line.

Incidentally, the statement in your Feb 10 1994 letter to us that the PA-235 and -250 were not included in AD 92-13-04 because they had individual line drains for the main and auxiliary tanks is technically correct. But, the drains you speak of are just that, …line drains. They drain the line that brings fuel to the gascolator and nothing else. There is only one line that takes fuel out of the tanks and that is the main fuel line. A drain on that line near the gascolator does nothing to get water out of the after inboard corner of any tank. Your failure to include the -235 and -250 in the AD may lead owners of those aircraft into a sense of false security. This omission should be immediately corrected. I refer you to Piper Parts Catalog for the-2150 pages 2F5 through 2F14. If that doesn't convince you, go out to a Piper PA-23 -235 or 250 and try to find a separate drain line out of any tank.

Mr. Clements, we, Mr. Wells and Mr. Horton, certainly do not wish to be "hostile or inflammatory", as we were once called by Mr. Paul Bohr. All we are trying to do is to eliminate a problem that sometimes becomes fatal in the PA-23 aircraft as it did in the case of Dr. Calabro and his wife Ruth who were killed in the crash of PA-23 N54746 on 26 July 1991 near Manteo, North Carolina. That crash was years after we informed the FAA of the basic problem of undetectable and undrainable water in the tanks of that aircraft. There have been other water accidents that I will not list, but just one accident caused by a known design deficiency in any aircraft is not acceptable. The corrective system is just not good enough.

So, after all these years, our question still remains the same. When is the FAA going to correct the design defect in the PA-23 series that lets water collect in the after inboard corner of each tank that cannot be detected or eliminated ? Keeping the water out, or rather, trying to keep the water out by whatever means is admirable……..and it must be done. But you know and we know, that in the real world water is going to get into these tanks through some contaminated fuel source, and that water can not be detected by the normal preflight. Under those conditions, people are going to die. Those planes are not properly certified, and the FAA is aware of that fact. If nothing else the FAA should publish that fact and advise the owners of those aircraft that their aircraft are not properly certificated. It is my understanding that the FAA has issued an STC for putting drains in the after inboard corner of these tanks. That should be made mandatory.

As tax paying, well meaning, informed citizens of this country it is our conviction that we should receive reasonable answers to logical questions asked of any governmental entity. Our efforts to get such answers will continue. We intend to use any route necessary to elicit appropriate responses.

Sincerely, and Respectfully, Norman L. Horton Jerry L. Wells

 

Memorandum From the office of: Norman L. Horton

Our letter to Barry D. Clements of 25 March 1994

Copies to:

1	The Honorable David R. Hinson Administrator Federal Aviation Administration U.S. Dept. of Transportation 800 Independence Ave. Washington, D.C. 20591
2	Mark M. Lacagnina Editor Aviation Safety P.O. Box 3970 Frederick, MD 21705-3970
3	Chuck Miller
4	Senator Bob Packwood 259 Russell Senate Office Building Washington, D.C. 20510
5	Representative Bob Smith (deliver to Mrs. Gilman in MFR)
6	Bernard Burton, Esquire

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