The above listed references do not include many internal government memoranda and letters concerning the subject matter of aircraft accidents caused by undetected and undrained water in aircraft fuel systems. The listed references are intended to partially limit the instant discussion to the PA-23 aircraft. There is no intention to permanently exclude other general aviation aircraft which may suffer the same problem and which may not meet the requirements of the regulations under which they were certified. These other general aviation aircraft remain to be tested to the same degree as the Cessna 200 series and the PA-23. Once tested sufficiently, other aircraft may be the subject of separate correspondence.
	A reading of the references shows that in our opinion the PA-23 aircraft did not meet the requirements of CAR 3.553, CAR 3.444 (c), FAR 23.971 (b), or FAR 23.999. That opinion was based on a single test conducted in San Diego, California.
	Since that San Diego test, and at the request of an attorney concerned about the crash of PA-23 N1099P, which crashed in California on 4 November 1981, other tests have been conducted and many more documents reviewed.
	As a result of our document search, aircraft disassembly and inspections, as well as mock up tests, our former opinion has been supported by fact. This despite the assurances by both Piper and the FAA that the aircraft does meet certification requirements.
	In the depositions of Mr. Gilbert Carter and Mr. John R. James of the FAA taken in Atlanta on the 27th of March 1987, it is apparent that the extent of the FAA investigation into this matter was to:

	1.	ask Piper for a response to our letter, ref. a. above, and
	2.	make a cursory examination of the original drawings of a portion of the fuel system of the aircraft.

	Neither Piper nor the FAA examined the subject of this investigation, the PA-23 aircraft.
	While it is essential that original design drawings be reviewed at some point in such an investigation, it is just as important to view the hardware that comes off of the assembly line to determine if designer intention translates into reality. If investigation stopped at the review of original drawings only, a conclusion could be made that the Leaning Tower of Pisa is indeed vertical. Millions of tourists and the entire City of Pisa might differ with such an opinion.
	As can be seen in the TV film included with this letter, Mr. Wells and I not only examined and used drawings of the PA-23, but we also examined aircraft in the field. We removed and examined tanks taken from a PA-23 to determine the actual position and condition of these tanks. We further constructed an ideal mockup tank section out of plastic to demonstrate our findings.
	In the case of Vinson versus Piper in California, which Piper settled after viewing our tests on video, Piper's own expert, a Mr. Bill Davies, substantially agreed with our tests. Mr. Davies lost 10 to 12 ounces of water in a PA-23 main tank while the aircraft was in a normal ground attitude. That amount of water cannot be accommodated by the fuel strainer while in flight and can lead to engine stoppage.
	The NTSB has long recognized that water in great quantities can be held in aircraft which have "flexible, rubberized bladder-type fuel cells in their wings". That quote comes from the NTSB letter dated March 8, 1983 to the FAA which also made many recommendations to partially correct this problem. They recognized that this water was not able to be detected or drained by the procedures specified by the manufacturer of the aircraft.
	The former CARs and the current FARs require either a tank sump or a fuel strainer (gascolator) to remove water from aircraft fuel systems before that water can reach the engine. Most of the manufacturers of general aviation aircraft have chosen the fuel strainer in lieu of a tank sump to attempt water-in-fuel separation and isolation. This choice was made for a variety of reasons, economy being the foremost. The FAA requirement of the capacity of this fuel strainer is only one ounce for every 20 gallons of fuel in the tank. As can be seen, this requirement is woefully inadequate. This lack of proper capacity, or the use of a proper tank sump has been responsible for a number of aircraft accidents and many fatalities.
	In conclusion, we, Norman L. Horton and Jerry L. Wells, factually state, based on our research, investigations and tests, that the PA-23 aircraft does not meet the requirements of the regulations under which it was certified in respect to detection and elimination of water and other contaminants from the fuel system while the aircraft is in a normal ground attitude.
	We further recommend that all PA-23 aircraft make an attempt to demonstrate such compliance at the next scheduled annual or 100 hour inspection, whichever occurs first. If compliance cannot be demonstrated, that the aircraft be grounded until at least partial compliance can be shown by the installation of quick drains in the after inboard corner of each tank. We realize that quick drains in each tank will not fully meet the requirements of this regulation, but it will insure the elimination of most of the significant water from the fuel prior to flight if pilots are properly instructed in preflight procedures.
	The purpose of this letter is to correct life threatening deficiencies in one general aviation aircraft and thereby perhaps save lives and property. If this letter or the enclosed film create questions or comments, please communicate directly with Mr. Wells or Mr. Horton at the address on the letterhead. We can and will provide additional documentation or demonstrations if requested by the NTSB or the FAA.

Norman L. Horton