Hi Dave,
Comments interspersed below.
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On Sep 21, 2009, at 10:05, [email protected] wrote:
Bill,
That's all well and good. But my experience with waiching how the FAA
does business with the airline industry since 1993 leads me to these
conclusions--
1. The FAA is going to do what they are going to do.
I agree; but we, the people have the right to demand, and demand
strongly, that the FAA follow their own procedures for issuance of an
AD.
Yes, there is an agenda here and we aren't privvy to all the details.
You have expressed your opinion, so this is mine: The details are not
important. The FAA and it's "culture" today want private aviation out
of their hair. We are the individuals with intelligence that threaten
their unilateral and dictatorial exercise of authority. Once we are
out of "their" skies they will have undisputed and unlimited authority
over any and all commercial use of the airways (in the name os "we, the
people, of course). Not one of them will ever stand in the
unemployment line.
Express your outrage if you wish, but don't expect it to accomplish
anything constructive.
There is a difference in mindlessly raging and holding an agency
properly accountable, to such extent as that is possible. There will
come a time when the FAA is essentially unaccountable, but that time is
not yet here.
Better yet, express your outrage to your congressman or senator, or
directly to the Administrator,
I agree we should make these people part of our efforts.
because you are wasting your ink to include that in any response to
the ACS.
It is my ink to "waste". If we owner/pilots do not insist strongly
that the FAA comply with their own procedures, which at least pay lip
service to being accountable to those they serve, they will act
ever-more unaccountable at an ever increasing pace. We have legitimate
means at hand to slow it the progression of unreasonableness and so I
believe we need to dig in our heels and fight them where we are with
what we have just as hard and effectively as we can. The meek do not
inherit the earth...they inherit the dirt. I believe something was
lost in the translation from one language into another.
2. Hoping this problem will go away or that the solution will be
simple and easy is like burying your head in the sand. There will be
an AD forthcoming.
While there will always be another AD forthcoming, we have an
obligation to assure that those adopted address a genuine fleet problem
and not merely serve to validate an open-ended FAA means with which to
ground an ever-increasing number of perfectly safe operational
airframes.
3. Not cooperating or withholding information from the FAA is in
nobody's best interest.
I disagree. Just as a criminal would be stupid to tell the prosecution
anything and everything, we aircraft owners, whom I would argue are
treated as criminals by the FAA, do not best serve ourselves by making
their achievement of their unknown agenda easier. The information I
shared here and would withhold from them is available to them in their
files in many forms and places. To access it, they have to devote
effort. That is effort not available to them to otherwise bother us.
Accordingly, I do not deem my request that this information not be made
freely available to assist them in our persecution to be unreasonable.
The ultimate decision at this point will be up to each person on this
list.
The less information the FAA has to work with, the more severe their
"fix" to the problem will be.
That is precisely the reason for a "comments" period in the AD process.
But before a "fix" to a problem is possible, there must be agreement
as to precisely what the problem is. In this case, the problem is the
very arrogance and ignorance of the originator. It looks at an
accident that, at best, is a statistical "fluke" before there is even a
final "finding" as to cause. I have information that I will present
that I believe will conclusively show that the cause was NOT holes in
the wing spar, whether authorized or unauthorized. To such extent as
the collective efforts of Ercoupe owners are effective, this particular
threat to the Ercoupe fleet should die a natural and well deserved
death.
I think we should provide them with as much information as possible to
help them make the best decision.
I absolutely disagree.
That does not guarantee that we will be able to live with the
solution, but I guarantee it will be worse if they make a decision in
a vacuum.
No. if we give them the weapon and bullets to achieve their goal(s),
their own authority and influence unused will then be employed to our
further disadvantage. That's what they DO, day in and day out; and we
pay them while meekly allowing them to do it.
4. Cooperation is probably the best way to get information from the
FAA regarding exactly what they are looking for.
Again, I disagree.
Even the FAA has an obligation on some level to appear reasonable.
What they have presented is mere speculation inadequate to support a
logical hypothesis. It is in no way sufficient to justify a new AD.
If we allow them to slip their proposed and unwarranted intrusion into
things so common in the field as could ground operational Ercoupes in a
heartbeat without proper and meaningful substantiation or appeal, we,
and only we, are to blame,
My airplane has holes drilled in the main spar cap to mount the seat
pan. The seat pan is of original design but it's obviously a
replacement with no documentation in the FAA 337 file. The previous
owner found broken screws and stripped threads and enlarged some of
these holes to drill out the broken screws and re-tapped them from #6
to #10. The A&P who did the annual and another AI who did the pre-buy
were both aware of this and signed it off-- neither considered it an
issue. Without knowing the specifics, it's hard to know if my
airplane will be one of the ones affected, but I'm assuming it will.
Good assumption. Holes drilled and threaded are much more likely to
serve as a point of origin for stress failure than even larger clean
holes for through fasteners.
I'm hoping to get more information soon through the EOC that will help
me determine if I need to be concerned or not. If I don't get some
more information withing the next four to six weeks, I will be
contacting the FAA and to explain what I've found and sending
pictures.
I have been a member of EOC since the early eighties. Having completed
terms as EOC Regional Director, Vice President and President, what I
"bring to the table" is at least worthy of unbiased consideration. If
there were ever a time for Ercoupe owners to speak with a common theme
and voice, this is it. Information I provide will likely be in the EOC
"official response(s) and that of Univair.
For you to unilaterally step forward out of our ranks and provide the
FAA with such pictures may give them precisely the information they
need to implement this nonsense.
I would instead suggest that you have your mechanic enlarge these
holes (not to exceed 11/65" (.171) in diameter and install through
fasteners, otherwise your spar will likely be found unsafe. You may
have the money to buy another Ercoupe and the time to part out your
present one, but any of us don't. Their flying days could quickly end
if AD 2003-21-01 is amended and implemented as presently proposed. You
seem to expect this to happen and accept that as fact. I don't and
won't.
Getting into a pissing match over this will only hurt us in the
long-run.
This unilateral characterization of the give and take of legitimate
discussion implicit to a (hopefully) coordinated effort on the part of
Ercoupe owners is both offensive and inappropriate. It cannot refer to
exchanges with the FAA, because they do not communicate with the
necessary frequency to sustain such an exchange.
The airlines have the money, lobbying power, and legal resources to do
damage control when the FAA puts a heavy burden on them to comply. We
don't, and I doubt I doubt Univair does. We're little fish to the
Feds.
I agree.
Ultimately it will be their engineering department that makes the call
based on data supplied from the field, and all the "what iffing" and
armchair analysis from a bunch of owners is just wasted energy.
JMO, YMMV,
Dave
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I am reminded of the expression "Lead, follow, or get out of the way.
You insinuate dogmatic opinions into an important discussion that needs
to take place. You argue, in essence, that "resistance is futile" and
collaboration with our oppressor is the only sane choice. I do not
choose to be their slave of my own free will.
While our energy may well appear "wasted" in hindsight, any ultimate
defeat will be honorable and acceptable only to such extent as we
honestly and fanatically resisted such outcome to the total exhaustion
of available resources. This is not Singapore. It is the Battle of
Britain. We are the few. We must be David to the FAA Goliath.
Sincerely,
William R. Bayne
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(Copyright 2009)
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