Hi Ed,
Consider the following:
Skip, as Executive Director of the EOC, is not trained as a mechanic
or engineer.
We don't have first-hand knowledge whether or not Skip assigned John
Wright, Sr. the task of working with the FAA on behalf of the EOC; or
if John has done whatever he has done (which may be nothing, in terms
of actual and direct comment to the FAA in response to this ACS. While
I believe Skip will respond on behalf of EOC, we may not know what is
in that response before the close of the comment period in a week and a
half. He has all that we have in terms of data and opinions, and will
give each and all due consideration, I'm sure.
While Univair is somewhat of a "wild card", I don't think it is
reasonable for us to presume that their response(s) will not be in good
faith, or purely motivated by potential profit. Again, they are just
down the street from the FAA ACO and now have all that we have in terms
of data and opinions. I see no reason to believe or expect that they
will not give all such "outside" input and information due
consideration as this ACS progress continues to unfold.
Accordingly, I don't think we should presume to enjoy the luxury of
doing nothing in the hope that the response of "others" will be both
appropriate and convincing.
I agree that individuals who comment at this time pointing out the
appalling lack of pertinent information in the current version of this
ACS should request that said ACS be withdrawn and redrafted so as to be
reasonably complete and reissued with a new comment period.
I would point out that the actual and formal AD process has NOT yet
been initiated. There must be some form of "notice of rulemaking"
published in the Federal Register with a reasonable comment period.
In that sense, everyone - individuals included, will have a second
"bite at the cookie".
I would also point out that assumptions can be dangerous. I have
verified that Bill Yeates will not be making official comment with
which to submit his Fred Weick letter. He has generously provided it
for someone else to take and run with. Had the question as to Bill's
intent not been discerned and confirmed, Fred's letter would not have
ultimately been of any significance in resolving problems associated
with the pending ACS. So, in such sense, all is not always as we might
presume or wish.
Sincerely,
WRB
--
On Sep 27, 2009, at 11:53, Ed Burkhead wrote:
I don’t know that “we” as individuals or the forum need to provide the
FAA with any suggestions. That is something appropriate for our Type
Club and the technical representatives who have the interests of the
fleet in mind.
It’s possible that the Type Certificate holder, Univair, might tend
toward resolutions that provide them with a windfall of profit.
Bill Bayne and Bill Yeates have provided some very useful data on the
subject.
If some members feel an urge to respond independently, I’d mostly urge
them to ask for a time extension so we can review the facts rather
than respond to the ACS in total ignorance.
Ed
