nathanm@hp-pcd.UUCP (06/15/84)
This letter to the FAA was reprinted in the "1st Issue of June, 1984"
edition of Western Flyer. I'm not familiar with the AD, but I found
the letter attention-grabbing enough to pass on for your reading
entertainment and possible discussion. Opinions not those of the
management, submitter or, for that matter, anyone else.
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Nathan Meyers
hp-pcd!nathanm
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Paul Pendleton
Wichita Cert. Office, Rm. 238
Mid-Continent Airport
Wichita, KS 67209
re: Airworthiness Directive 84-10-01, pertaining to the fuel system of
most single-engine, high-performance Cessnas.
This letter is in response to your AD note 84-10-01. Obviously,
you have no idea of what is involved or the cost entailed by your
asinine AD.
May I suggest as a start you personally try to follow your AD
directions and see how long it takes you to comply with the removal
and replacement of these tanks. After attempting to remove any
wrinkles from one tank, which will probably cause a perfectly good
tank to fail, thereby costing hundreds of dollars more to replace,
I'm sure you will be so frustrated that you will give up working on
the other side. After a few trips to the hospital to get the cuts
in your arms and hands sewed up the bill for labor alone will be in
the hundreds of dollars.
Also, there is the danger of having the fuel removed from the
aircraft itself. OSHA would take a dim view of the procedures that
defueling an aircraft entails. And the EPA would not like all the
free gasoline vapors that will be released into the atmosphere. All
of this to comply with this ill-thought-out AD. The cost and time
are bad enough, but we people who fly the aircraft certainly know
how much fuel is left in the tanks when empty and how much water is
drained from the sumps on preflight. If excessive amounts of
contaminants are there, we know there is a leak and get it fixed.
But maybe that would be difficult for you to figure out, since your
bureaucratic mind doesn't work logically, hence this AD.
Your Section C3 of this AD is completely stupid, as most
service facilities have no capability to safely store the large
quantities of fuel removed from the aircraft. Even if the facility
can store the fuel, it will probably be contaminated and not be
reliable for use in the aircraft again. Most aircraft in this AD
hold 60 to 100 gallons, and at $2-plus per gallon would add to the
cost of compliance anywhere from $120 to $200. You obviously
don't care how much the compliance of this AD will cost since you
are a government employee who doesn't care how much the public
must pay to keep you employed.
Section C3-VI is even more dumb. If you were to install such
a placard, a minimum of three inches by seven inches, it would cover
most of your flight instruments, which, I would think, would be even
more hazardous than a little water in the fuel.
I wonder how many accidents per operating hour such a condition
might have caused. Since you mention no statistics to back up your
claims, I can only surmise that such an analysis has not been
performed. And the only real justification for this AD is to prove
to your superiors that you are doing something for your paycheck;
however all I see is another bureaucrat jamming a rule (law) at us
that we have no recourse against.
Please rescind this AD, as it is not cost-effective or will
significantly increase the safe operation of the aircraft involved,
but then when did our government ever care how much something
costs?
D.M. Gossett
Coeur d'Alene Avionics
Hayden Lake, ID