Home Documents Images
Message Board
(Use
your browser's back button to return to the page that you were previously
viewing.)
|
|
|
16 October 1987 |
|
|
|
Mr. Paul K. Bohr |
|
|
|
Dear Mr. Bohr: |
|
|
|
We were pleasantly surprised by your letter dated July 19, 1987 concerning our open letter dated 11 June 1987 to both the NTSB and the FAA. |
|
|
|
However, we were equally as surprised, but oppositely so, by your letter dated September 23, 1987 concerning your examination of our submitted facts. |
|
|
|
It appears that even as of this date there has been no adequate examination of a number of PA-23 aircraft as manufactured and used in the field today. It also appears that there has been no introduction of water into the tanks to test for water retention. |
|
|
|
We would certainly agree that the original design drawings will show compliance with the requirements of the regulations How else would certification be granted ? No designer in control of his own faculties would submit non-complying drawings to the FAA for certification. With that point we have no argument. Further, we will agree that a "conforming" tank, which you examined, might well meet the requirements to "conform" to the regulations. Otherwise it would not "conform" and would not be certified. |
|
|
|
But, if that is where the interests of the FAA terminate, we have been mis-informed of the mission and function of the FAA. Hence, we are apparently seeking to save the lives and property of pilots and passengers through the wrong organization. It appears from your letter that the FAA has no interest in how originally certified aircraft are later manufactured and sold to the public. It also appears that the FAA cares not that pilots and passengers have died and will die in the future in these aircraft. |
|
|
|
Where does one go to correct such a situation as this if not the FAA ? |
|
|
|
You cite that five (5) of the eight (8) reported Pa-23/23-160 contaminated fuel accidents/incidents occurred on take off or initial climb out. From that you conclude, without any factual support, that proper pre-flight draining of the tanks was not performed by the pilots. If these aircraft were supposedly not pre-flighted on perfectly level ground, and the aircraft actually "conformed" to the requirements of the regulations, we would agree with your conclusion. However, neither of these situations exist in the real world. Our survey of ramps and parking areas show that most of them are not level. Our survey of PA-23 aircraft shows that they in fact do not "conform" as we found them in use in the field. Further, fueling pit areas are intentionally sloped so that rain water does not get into the pits or surround the fuel pipes an tanks. |
|
|
|
Our evidence shows that at least on one accident several coffee cans of fuel and water were drained from the tanks until only clear fuel drained from the fuel filter. Yet, after take off and on the downwind leg the aircraft crashed without power. Water was found in the carburetors. This was the accident of 4 November 1981 in Southern California. Another similar accident occurred n Bluefield, West Virginia on 25 February 1984. These two accidents were reported to be caused by water in the fuel. I refer you to the Safety Recommendations A-85-77 thorough -80 issued by the NTSB dated October 16, 1985 which cites eleven (11) other accidents of PA-23 aircraft caused by water in the fuel. Even so, many fuel contamination accidents/incidents are either mis-reported or not reported at all. |
|
|
|
Your statement that our demonstration of a factual situation "should not be used as evidence of non-compliance" boggles the mind. We not only found non-compliance and showed it to you on television tape, but we further demonstrated non-compliance in an ideal flat bottomed plastic tank. What you are saying is that the fingerprints of a defendant found on the handle of a knife buried in the heart of a victim "should not be used as evidence" against that defendant. |
|
|
|
What must be done to convince the FAA that the regulations are indeed not complied with ? By your own admission the intent of the designer was not met….the tank bottom is not level but low at the aft end. Your studies show one (1) degree. Our measurements on aircraft in the field show a lot more. Therefore, your statement that the "fuel system is in literal compliance with CAR 3.444(c) and 3.553" is not understood. We ask you to read again those regulations and consult your dictionary for the meaning of the word "literal". CAR 3.444(c) says "….water will drain from all portions of the tank to the sediment bowl". Note the word all. CAR 3.553 says "Drains shall be provided to permit safe drainage of the entire fuel system…." Note the word entire. The regulations, as written, should be enforced or changed. It is as simple as that. |
|
Mr. Bohr, neither of us has a Doctorate in the English language, but on the other hand, neither of us is illiterate. We, like thousands of other pilots, can and do read the regulations......and we are held accountable to the FAA for compliance. Should we expect less of the FAA ? |
|
As to the potential economic impact of our suggested action, consider this. Just one accident caused by water contamination in the fuel has already cost the industry far more than it would cost to equip all the 2000 remaining PA-23 aircraft with quick drains in the aft inboard corner of each tank. |
|
It is our opinion that, surely, more accidents will follow unless you, the FAA, and Piper take immediate appropriate action to prevent them. |
|
|
|
Sincerely,
|
|
P.S. Since our original letter was an "open" letter, your reply thereto and this letter will be so classified. It is our sincere belief that as many aviators as possible should be made aware of this situation. |
|
NLH |
Home Documents Images
Message Board
(Use
your browser's back button to return to the page that you were previously
viewing.)