Home Documents Images
Message Board
(Use
your browser's back button to return to the page that you were previously
viewing.)
|
April 2, 1992 |
|
|
|
Counsel |
|
|
|
Kansas City, MO 64106 |
|
|
|
RE: Rules Docket No. 91-CE-95-AD |
|
|
|
Dear Sir or Madam: |
|
|
|
I have followed the problem of water retention in the fuel system of PA-23 aircraft for many years through aviation trade publications and discussions with accident investigators associated with specific cases. Two unimpeachable facts are present. |
|
|
|
First, the airplane does not meet even the primitive air regulations to which the aircraft was certified, CARs 3.444(c) and 3.553. Ability to drain the fuel through a low point in the tanks means just that. There is nothing arguable, nothing mysterious. Second, blaming an accident upon "pilot error" when the pilot cannot reasonably perceive the hazard due to system design is ludicrous. |
|
|
|
To certificate an airplane does not mean it is "safe". It only means that at the time the certification snapshot is taken, the combined knowledge of the FAA and the manufacturer at that time led to a conclusion that the aircraft meets certain specifications. Accidents are investigated to evaluate, among other things, if the assumptions made prior to original certification were, indeed, accurate. When deficiencies are encountered, the FAA has a duty to either see that they are rectified or, at the very least, inform the flying public (pilots and their potential passengers) of the hazard over which the pilot has no control. To do otherwise would be dereliction of the agency's statutory duty … something I would not hesitate to say in a court of law. |
|
My qualifications in these areas are shown in the enclosed personal background summary. |
|
|
Very truly yours, _______________ |
Home Documents Images
Message Board
(Use
your browser's back button to return to the page that you were previously
viewing.)