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Aviation Safety and Management Consultants:
Horton & Wells' PA-23 Water Retention Calendar

About Norman Horton of Aviation Safety and Management Consultants, ASMC

May 20, 2004 Introduction


April 26, 1985

Norman Horton and Jerry Wells of ASMC perform a water retention test on a Piper PA-23 model aircraft in San Diego, California.

May 1985

Malfunction & Defect Report submitted to the Federal Aviation Adminstration (FAA) in San Diego on above problem. The FAA took no corrective action.

June 20, 1985

A letter to the FAA and the National Transportation Safety Board (NTSB) about water retention in a number of aircraft tested by ASMC. Here are the aircraft models that were tested:


Cessna 177
Cessna 206
Cessna U206
Cessna T207


Cessna 182

September 3, 1985

The NTSB's response to ASMC's June 20, 1985 letter (above).

October 9, 1985 The Federal Aviation Administration's (FAA's) response to Piper Aircraft Corporation regarding ASMC's June 20, 1985 letter. The FAA requests that Piper provide comments that explain the methods used to show that the PA-23-150 and PA-24-250 aircraft models comply with the requirments of CAR 3.553 and CAR 3.444 (c) pertaining to fuel drain provisions.

December 5, 1985

The FAA's response to NTSB Safety Recommendation A-85-77 and Interim Reply to NTSB Safety Recommendation A-85-78.

April 21, 1986

Piper Aircraft Corporation's Service Bulletin 827 is issued in response to the FAA's reaction to NTSB Safety Recommendation A-85-78 (above). The service bulletin addresses fuel system draining procedures for water contamination applicable to Piper PA-23-150/160 Apache aircraft models with serial numbers 23-1 through 23-2046.


June 11, 1987

A letter to the FAA and NTSB from ASMC citing internal documents that indicate that the Piper PA-23 aircraft model complies with FAA regulations. A video of tests performed by ASMC indicates that the PA-23 model does not comply with FAA regulations. The video was submitted to the FAA with this letter.

July 13, 1987

The FAA acknowledges receipt of ASMC's June 11th letter (above).

August 3, 1987 NTSB Chairman, Jim Burnett, responds to ASMC's June 11th letter.

September 23, 1987

A letter from the FAA that seems to say that the PA-23 is not dangerous, apparently denying ASMC's contention. (See the FAA's letter dated November 2, 1987 given below for a clairification of the FAA's ommission of the word "not" in this letter.)

October 16, 1987

ASMC's letter to the FAA that takes the FAA to task because it did not examine an aircraft; instead, it asked the aircraft manufacturer, Piper Aircraft Corporation, if the airplane meets certification requirements.

November 2, 1987

A letter from the FAA to ASMC stating that its above October 16th letter is "offensive and inflammatory." Nevertheless, the FAA expresses that it will continue its investigation. (Finally, the agency will look at an aircraft.) The agency also inserted the word not in this letter where the word was omitted in its September 23, 1987 letter (above).

December 14, 1987

In response to the FAA's above November 2nd letter, ASMC suggests that the FAA either fix affected aircraft with a solution compliant with regulations or change the regulations.

December 15, 1987

A letter from ASMC to Piper Aircraft Corporation with other letters enclosed. Piper did not respond.

December 28, 1987

A letter from the FAA to ASMC. After thirty-three months, the FAA reveals that it is still working on the problem.

December 30, 1987

A letter from the NTSB to the FAA stating that ASMC may be correct. The NTSB recommends that the FAA conduct a test on a real aircraft, and if necessary, issue an airworthiness directive, AD.


January 20, 1988

An open letter to the FAA from ASMC discussing who bears the cost when an aircraft manufacturer sells a model that does not adhere to certification standards set forth in FAA regulations.

February 18, 1988

In this letter, the FAA's Aircraft Certification Division's manager finally gives attention to ASMC's findings acknowledging after nearly three-years of discussing the problem that ASMC is correct.

March 2, 1988

A letter from ASMC to the FAA's Aircraft Certification Division expressing thanks for the FAA's agreement with ASMC's findings.

February 17, 1988

A letter from an owner of a Piper PA-23 aircraft addressed to Aviation Consumer Magazine. The owner describes his experience with an in-flight engine failure caused by water contamination stating that trapped water in each tank measured 3.5 times the gascolator capacity. (The gascolator capacity is 3.3 ozs; so the trapped water was in excess of 11.5 ozs., which is close to ASMC's estimates.)

September 8, 1988

A letter from the FAA indicating that a NPRM was published.

November 6, 1988

Airworthiness Directive AD 88-21-07 is published. This AD does not provide a solution for positive detection of fuel contamination during a preflight check.


May 19, 1989 An AMSC inner office memo noting a phone conversation between Horton and the FAA regarding AD 88-21-07.
May 29, 1989 A letter from Horton to The Aviation Consumer.

November 15, 1989

Another PA-23 water crash at Pembroke, Fla..

December 21, 1989

A letter from ASMC to the FAA giving a historical review of the problem and asking what the FAA proposes to do about it.


January 24, 1990

A letter from the FAA to ASMC stating that the FAA is interested in the problem and that it has done something about it.

December 10, 1990

AD 90-23-18 becomes effective. Dual fuel drain kits, SB 827A 4 Nov.88 Wedges under tanks, SB 932A 30 Aug 90 Enlarged filter bowls, SB 932A 30 Aug 90.

December 19, 1990

The Aircraft Owners and Pilots Association, AOPA, forces the FAA to hold AD 90-23-18 in abeyance and to eventually cancel it.


January 24, 1991

Another PA-23 aircraft crashes. It crashed immediately after takeoff.

April 2, 1991

ASMC contacts the FAA's Atlanta office to discuss the status of the AD to correct the problem. The FAA reveals that it plans to issue a NPRM asking owners of PA-23 aircraft to submit comments for proposed solutions with a due date of July 1, 1991.


As of April 2, 1991, about six-years had past since the FAA was made aware of the water retention problem, and nothing constructive had been done to correct it. Apparently, the affected aircraft still did not meet certification requirements, and the FAA appeared to be literally closing its collective eyes when confronted with the matter. Owners who crashed and died cannot make comments about the problem. And it seems that owners who are alive do not want to spend their money to correct the problem; hence, nothing constructive was (or has been) done.

August 21, 1992 92-13-04 Piper Aircraft Corporation: Amendment 39-8274. Docket No. 91-CE-95-AD. Supersedes AD 90-23-18, Amendment 39-6782. This amendment became effective on August 21, 1992.
March 5, 1993 A letter from ASMC to ABC News.
January 5, 1994 A letter from ASMC to the Administrator of the Federal Aviation Administration.
February 10, 1994 A letter from the FAA Administrator to ASMC responding to ASMC's January 5, 1994 letter (immediately above).
February 1994 A memorandum and letter from ASMC to Senator Bob Packwood.
March 25, 1994 A letter from a Member of Congress to the Administrator of the FAA.
March 25, 1994 A letter from ASMC to the FAA's Aircraft Certification Services.

April 19, 1994

A letter from the FAA's Aircraft Certificaton Service to ASMC responding to ASMC's March 25, 1994 letter (immediately above).

June 17, 1994 A letter and a trip report from the FAA's Atlanta Aircraft Certification Office to ASMC regarding the May 24, 1994 meeting of these parties in Shirley, New York to look at aircraft wreakage of a Piper PA-23 airplane.
August 22, 1994 A letter from ASMC to the NTSB.
October 11, 1994 A letter from the NTSB to ASMC responding to ASMC's August 22, 1994 letter (immediately above).

July 22, 1995

A letter from Norman Horton of ASMC to Flying Magazine.

Fall 1995

Norman L. Horton authors his "Reflections on Aviation Accident Prevention."

January 3, 1996 A letter from Aviation Safety magazine's editor responding to Horton's Reflections on Aviation Accident Prevention (immediately above).
March 20, 1996 Horton's response to Aviation Safety magazine's January 3, 1996 letter (immediately above).




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