Author: Airlaw

About Airlaw

For more than 40 years, The Wolk Law Firm has concentrated its practice in the area of aviation law, with Arthur personally generating verdicts and settlements of nearly $1 billion during the last decade alone. He is known for obtaining and on appeal, holding, the largest verdicts for each type of air accident claim in recent aviation history.

    I have recently reviewed a number of discount fuel contracts, usually for jet aircraft, and imbedded in them is a surprise about which most owners and their pilots are completely unaware.

    Every one of the contracts I read require the aircraft owner to release, indemnify and hold harmless not only the discount fuel company but also the FBO who supplies the fuel from everything, whether negligence or not and regardless of the consequences.

    So if an FBO mis-fuels your aircraft or puts fuel full of contaminants in your airplane and you crash, you will be surprised, no doubt posthumously, that you have voided your insurance coverage by agreeing to relieve the FBO of any responsibility and on top of that have no remedy against either the FBO or discount fuel company.

    What’s worse is the hold harmless provisions also make you liable for the FBO or discount fuel company’s attorneys’ fees. That could run into the millions of dollars and that won’t be covered either.

    Oh, and in case you haven’t thought of it, the release, indemnity and hold harmless also means that when the fuel truck takes your right wing off on the ramp, you have agreed to release, indemnify and hold harmless the discount fuel company and FBO for that too.

    When your insurance company gets wind of the contract you signed, without asking whether it wished to assume the release, indemnity and hold harmless you agreed to, the first notice you get will be a declination of coverage.

    I brought this to the attention of a certain aircraft owners and pilots group who were touting the benefits of the discount fuel deal and all of them hadn’t ever read the contract they signed nor had they sent it to their insurance companies to incorporate into their policy as contractual liability. None of them cancelled the contract either. Be assured that when the sad event occurs, they will be the first to complain.

    Aircraft insurance is not like the one on your car. It has lots of provisions that can trap an aircraft owner into no coverage. This one is easy. No contract to save a few cents on a fuel purchase is worth the loss of coverage.

    Arthur Alan Wolk

    December 3, 2018

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    Funny, they didn’t mention that the runaway stabilizer was not annunciated to the crew, the failed AOA sensor was not annunciated to the crew, the operation and existence of the system was not disclosed to the crew and the fact that once in motion, the means to disable it were not provided to the crew. Add to this that in violation of the certifying regulations the crew couldn’t overcome its downward force using their combined strength and the excuses ring hollow, likely written by the company lawyers rather than the company pilots.

    United Airlines did pretty much the same thing when its Flight 585 rolled into the ground in Colorado Springs in the early 90’s instead of admitting that the Boeing 737 had a rudder actuator problem. Boeing then told the FAA that a rudder hard over was impossible which began a nine year legal sojourn I led to solve the problem and get compensation for the victims. In the meantime several more crashes from the same cause occurred killing 600 more people while the FAA and the NTSB embraced the Boeing line.

    United should have stayed out of this controversy but its knee jerk reaction was not to frighten its customers away from flying an airplane it had invested heavily in. What it should have done in consort with its other airlines cohorts with whom it likely speaks about pricing and service, is taken a united stance against Boeing so the problem is fixed, and Boeing is admonished never to pull a reckless stunt like this again. It wouldn’t work, but it would have been a safer and higher road to take…safer for the passengers and flight deck crews.

    This is what happens when you take a great design (the Boeing 737 is derived from the original Boeing 707 aircraft) and you stretch it, add huge new engines and wonder why it doesn’t fly without adding a bunch of band aids. The Maneuvering Characteristics Augmentation System MCAS is just such a band aid that no other B737 has or needs to have. The crash had nothing to do with the crew, it had to do with Boeing and the FAA’s utter failure to properly certify the 737 MAX.

    Arthur Alan Wolk

    11/21/18

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    The crash of Lion Air Flight JT 610 is beyond a tragedy for the 189 souls aboard. It is a disgrace.

    The Boeing 737 MAX is equipped with a flight control system designed to prevent the crew from accidentally stalling the airplane. It’s called the “Maneuvering Characteristics Augmentation System” In this instance stall means aerodynamic stall or the airplane quits flying not engine failure. The incidence of airliner crews accidentally stalling their airplanes is almost non-existent except when in the unlikely event the flight control system malfunctions and misleads the flight deck crew into mis-handling the emergency. This occurred over the Atlantic during an Air France Flight to Paris from Buenos Aires some years ago. All aboard were killed so every aircraft manufacturer was on notice that the systems were getting to complex and confusing even for experienced flight crews to master.

    Boeing airplanes have traditionally avoided the use of computer interventions which take control of the aircraft away from the flight deck crew and the Boeing 737 MAX is the first time Boeing has departed from that control system design philosophy in the Boeing 737 type. The MAX system literally uses two Angle of Attack sensors which feeds information to a horizontal stabilizer trim system that will force the nose of the aircraft down if the angle of attack (the angle between a line down the middle of the fuselage and the air it is flying through) gets too steep. The computer senses that at that angle even if incorrectly measured due to a malfunctioning angle of attack sensor, the airplane is approaching or will approach stall and trims the stabilizer nose down to prevent the aircraft from stalling. The problem is that the system won’t allow the crew to disable it in a timely way if at all and it will take control away from the crew all the way into the ground or ocean. In fact since the system only works when the airplane is in manual flaps up condition, lowering the flaps would have disabled it but nobody in the cockpit knew that because Boeing didn’t tell them.

    In the instance of the Boeing 737 MAX, there was nothing in the FAA Approved Flight manual FCOM to advise the crew of this anomaly or how to deal with it and nothing in the differences training (the training of flight deck crews in one type of B-737 to know what’s new or different about the MAX) to cover it. Therefore the Lion Air crew was stuck between the proverbial rock and a hard place trying to figure out what was wrong and what to do about it.

    There is no question that Boeing knew about the issue and the potential failure mode because it designed and built the system. It was obligated to create a Failure Modes and Effects Analysis so the various potential failures could be addressed. It also knew it had a responsibility under the Federal Aviation Regulations to design the system so it could be flown by pilots of ordinary piloting skills, without the use of excessive strength and the system must be able to be overridden by the crew using ordinary strength and easily disabled it if it malfunctions.

    Boeing was required to supply the FAA with an FAA approved Flight manual which only the FAA can approve which gives the crew all the necessary information to deal with emergencies and abnormal conditions and under no circumstances is one emergency allowed to create an even worse emergency. Clearly the FAA didn’t read it, didn’t understand it, didn’t flight test it and just rubber stamped it.

    This Maneuvering Characteristics Augmentation System was malfunctioning on four flights before the accident flight. The flight deck crews reported the malfunctions and Lion Air maintenance people claiming they used the manuals that Boeing supplied, troubleshot the squawk and claim they fixed the system as instructed. The problem is that this malfunction could not be effectively troubleshot on the ground as the angle of attack sensors typically fail in the air. That’s why each succeeding flight deck crew had the problem again. In addition the system cannot be effectively troubleshot by the methods the maintenance personnel were given in continuing airworthiness manuals that Boeing was required under the Federal Aviation Regulations to provide with all means necessary to maintain the aircraft safe for flight.

    Many other types of jet aircraft have a single switch that will allow the crew to disconnect the entire trim system. But because this was a stall protection system, often the means to disable it is more complicated so the protection is not lost. Clearly the crew of Lion Air JT610 was unable to disconnect or disable the system and the nose was pitched down in ever increasing amounts such that even tugging as hard as they could the crew could not overcome the dive to eventual oblivion. The very fact that the crew could not disable or override the system makes the system itself a violation of the same Federal Aviation Regulations.

    Arthur Alan Wolk handled the Boeing 737 rudder malfunction cases and litigated them, United 525 and USAIR in Aliquippa Pa. for nine years successfully settling the cases of the many passengers he represented after proving, in spite of Boeing’s denials, that the rudder control system was flawed. It has since been redesigned. It was flawed and Wolk proved it not only to the NTSB who were mesmerized for years by Boeing’s denials but to Boeing and its insurers as well.

    No one is more qualified to litigate Lion Air JT 610 than Arthur Alan Wolk and The Wolk Law Firm.

    Arthur Alan Wolk can be reached at the office 215-545-4220 or on his cell 610-733-4220.

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    Finally waking up after its year and half long nap, the FAA decided to follow the lead of the manufacturer and order an immediate inspection of certain CFM-56 engines that power Boeing 737 aircraft.

    The Emergency Airworthiness Directive which should have been issued days after the uncontained failure of the fan of another Southwest Airlines B-737 over the Gulf of Mexico in 2016, requires inspections of certain engines which have accumulated 30,000 cycles, off and on equal one cycle, and repeated inspections every 3000 cycles.

    Engines which have accumulated 20,000 cycles must be inspected by August.

    That tells me that the manufacturer already had the data to support the Emergency A.D. and that the extended time period requested by the airlines to comply with the long proposed A.D. here in the U.S. was even more unwarranted and outrageous.

    Nothing has been said about reviewing the engineering and testing data on the engine nacelles which have proved themselves incapable of containing such engine failures, a very dangerous design flaw.

    This accident and the break neck speed that it took the regulatory authorities to get moving once again demonstrates that from an engineering standpoint no one has to die or be injured before an airplane is fixed or a safety problem is identified, but the business model of the airlines and the attitude of Government makes it necessary that there be deaths or injuries before they are willing to do anything in a timely manner.

    There needs to be a change of culture in this industry because one death is too many when it could have been easily prevented.

    Arthur Alan Wolk

    April 21st, 2018

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    The death of a beautiful wife and mother did not have to happen. When she boarded Southwest Flight 1380 in New York she could not have known that both the airline she trusted, the FAA, part of the Government that is thought of as the watchdog for flight safety, and the NTSB the independent government agency that’s supposed to investigate accidents and make Safety Recommendations had ignored explicit warnings that a disaster was in the making.

    In 2016, a Southwest Boeing 737 suffered a similar fan blade separation while over the Gulf of Mexico. It landed safely in New Orleans. The fan blade was found to have suffered a fatigue failure and while exiting the engine nacelle it too destroyed much of the front of that device that is supposed to contain such disintegrations. It didn’t.

    The French manufacturer of the CFM-56 engine that powers all Boeing 737NG aircraft issued a Service Bulletin requiring airlines to perform ultrasonic inspection of the fan blades based upon time in service and the European Authorities felt the chances for loss of life was serious enough to issue an Airworthiness Directive that required all EU based airlines to perform the Service Bulletin. Our Federal Aviation Administration, always asleep, and always too little too late, is still fooling with a similar Airworthiness Directive for U.S. based airlines but hasn’t yet ordered the inspections. The manufacturer of the aircraft, The Boeing Company, did nothing to determine why uncontained engine failures were not “contained” by the very device that’s supposed to contain them.

    While airlines are required to perform Service Bulletins, it is clear that Southwest, the airline that suffered the in-flight emergency in 2016, didn’t feel it was urgent enough to accelerate inspections on its own aircraft even after suffering the near tragic event that just as easily could have cost the life of its passengers and crew.

    More than a year and a half later, with nothing done in the face of the events that warned everyone, the airline, the FAA, the manufacturer of the airplane, that a time bomb, the fan blades could explode, be uncontained, and bring down an airplane, Southwest 1380 killed a passenger.

    Every airplane telegraphs its intention to fail long before it happens. An accident is no surprise, it’s always a consequence of the people in charge who fail to act quickly enough.

    The death of this lovely woman is beyond a disgrace, it is unwarranted, it is the result of a total absence of care, a gross abuse of a system that was supposed to protect the flying public.

    Touting that there had not been a fatality since 2009 in U.S. airline operations, the FAA and NTSB were lauding their own skill and job performance while ignoring the hard facts. They failed in their duties and without some coercion from Government airlines do as little as possible.

    The Service Bulletin gave the airlines too much time. The Airworthiness Directive gave the airlines too much time. The FAA is incompetent and the NTSB should have issued a Safety Recommendation after the 2016 incident and didn’t.

    To learn more, see my TV interviews about the incident.

    Arthur Alan Wolk

    April 19th 2018

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    Two beautiful families on vacation in Costa Rica were killed along with their guide and flight crew when the Cessna 208B Grand Caravan crashed on takeoff on December 31, 2017 in Nandayure, Guanacaste Province, Costa Rica.  The NTSB, en route from the United States along with representatives of Cessna, the airplane’s manufacturer and Pratt and Whitney Canada, the engine manufacturer, mentioned high winds as perhaps playing a role.  That disturbing statement shows how the NTSB will immediately seize on nothing to set up its conclusion that the pilots were to blame for this accident.

    This is the dilemma of aircraft accident investigation when the NTSB is “assisted” by only the companies most likely to face legal liability for this tragedy.  Any trained accident investigator who looks at the immediate aftermath of the crash can see the smoke rising straight up. That belies any assertion of high winds. Moreover, a Cessna Grand Caravan will not crash just because of non-hurricane force winds; which, in fact, will make it climb better not worse.

    This appears to be a tragic case of engine failure which while not common, is not uncommon either. The causes of that failure vary, but generally in the P&W PT-6 engine it is likely to be a pneumatic fuel control malfunction, provided there is no catastrophic failure of internal engine components.  The actual investigation which will be much more thorough will be done by the lawyers and their experts who represent the occupants of the aircraft. Critical will be the preservation of the wreckage before it is manhandled into uselessness by the “official” investigators.

    This awful tragedy, that has deprived the world of young vivacious people who have contributed so much to our society already, must be carefully investigated and the cause learned because a single engine aircraft that carries so many people must not be allowed to have another engine failure that takes so many lives.

    The Wolk Law Firm grieves with these families and hopes that out this hopelessness some good can come.

    Arthur Alan Wolk

    1/2/18

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    Technology is changing rapidly in aviation.

    • The old 6 pack design has given way to the glass cockpit.
    • Computer screens have replaced round dials.
    • Electric airplane instruments have replaced unreliable gyroscopic instruments.
    • GPS navigation is the norm while old style VOR’s and ILS approaches are being phased out.

    To effectively litigate airplane crashes it is vital that your lawyers are well versed on advanced cockpits and the airplanes they are installed in.
    The future causes of airplane accidents are not just because of stubborn reliance on antiquated engine technology but failures of the glass technology that often disappear after the accident. Knowledge of this technology is vital to solving the puzzle of why airplanes crash.

    The Wolk Law Firm has two Airline Transport rated pilots, a former Naval Aviator who is also a flight instructor, another multi and single engine rated pilot and they are supported by two of the most sophisticated aviation lawyers in the country.
    We are even rated with the unusual Airplane Transport Pilot certificate for seaplanes both multi-engine and single engine and type ratings in jet fighters and this Eclipse EA 50 twin jet which flies for the firm. We are current in the Air Traffic Control System and we know the regulations, the procedures and the art of flying airplanes.

    Our experience which totals thousands of hours as pilot in command is vital to quickly and effectively investigate and determine the causes of even the most baffling airplane accidents. There is a reason the Wolk Law Firm is regularly consulted as on air experts after an airplane crash, it’s because we consistently provide reliable, well founded views on why airplane accidents happen. We are proud of the work we have done over nearly 50 years. We have raised a thousand children and been responsible for safety improvements in both general aviation and commercial aircraft.

    That’s how The Wolk Law Firm has earned its reputation as the standard against which other plaintiffs’ aviation law firms are judged.
    We hope that one day airplane crashes will be a thing of the past but until they are, we will be here to help.

     

    Arthur Alan Wolk

    December 23rd, 2016

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    It’s easy to comment favorably on a decision on the importance of aviation safety, which was just decided by the United States Third Circuit Court of Appeals in Sikkelee v. Precision Airmotive Corp., et al., when your legal life is litigating air crash cases for plaintiffs.  No. 14-4193 (3d Cir. Apr. 19, 2016).  However, the Third Circuit got it right and its opinion is exhaustive, well-reasoned, and most importantly, accurately represents the reality of the regulatory environment in which aviation product manufacturers operate.

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    Few outside the air crash litigation world know how the party system at the NTSB works. When an airplane crash happens, it isn’t just the NTSB investigator-in-charge who goes to the scene to investigate. Under NTSB rules, manufacturers’ accident investigators are invited as parties to the investigation.

    Thanks to former NTSB Chairman Jim Hall, a Rand Report indicted this procedure as allowing aircraft manufacturers who had litigation in mind to be the fox guarding the henhouse by influencing the accident investigation away from failures in their components. This is the reason that pilot error is virtually always the cause assigned by the NTSB for an accident.

    Well, in spite of good public money having been spent on the Rand study and the lessons that were supposed to be learned from it, the NTSB has taken the justly criticized party system a step further. The NTSB now permits the manufacturers of aircraft, whose accidents it investigates, to pass on promotions of NTSB air safety investigators to senior air safety investigator status. That’s right, in order to get a promotion at the NTSB, to advance in one’s career and receive more money and stature, the promotion hinges on approval from the people investigated. Put another way, if an investigator regularly finds a defect caused an aircraft accident instead of pilot error, he has essentially no chance of promotion.

    This has caused a furor among air safety investigators at the NTSB, some of whom who refuse to play ball with the manufacturers’ attempts to place the blame for every accident on the dead pilot. Unfortunately, what these guys don’t know is that the system is fixed against them. Compared to the aircraft manufacturers the air safety investigators are powerless.

    Not to worry! Nobody in the air crash litigation profession relies on the NTSB reports. We do our own investigation, which is more thorough and we know more about these airplanes and why they crash than anyone at the NTSB, so good does triumph over evil most of the time.

    What is sad, however, is that the good guys who want to do the “independent” air crash investigation work that the “Independent Safety Board Act” was designed by Congress to accomplish are frustrated that their zeal to be independent is frustrated by a good ole boy network of Government and industry that stacks the deck against them.

    So much for the promised return to integrity in Government!

    – Arthur Alan Wolk

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    Aircraft wings and tails have forever been the collectors of enough ice to make them quit working like wings and tails. All it really takes is visible moisture, a cloud for example, and temperatures that approach freezing. The movement of the metal surfaces through the air is often enough to lower the temperature below freezing so even outside air temperatures above freezing will allow enough ice to form to give plenty of aerodynamic trouble.

    Aircraft manufacturers have historically used de-ice devices to deal with ice, at least enough of it to satisfy the FAA’s paltry requirements to certify an aircraft for flight into “known icing conditions”. De-ice devices concede that the manufacturer will allow the aircraft to accumulate ice before activation is supposed to shed the ice, hence the term de-ice.

    De-icing devices are typically rubber boots that inflate to break the ice off. The inflation pressures are supplied by an engine driven vacuum pump, bleed air taken from the compressor section of turbine engines or separate pumps electrically driven. Engine driven vacuum pumps have proven to be prone to failure just when they are needed most because of heat, sudden demands that fail their internal carbon blades, general deterioration or contamination just to name a few of the many reasons for un-annunciated sudden failure. Bleed air drawn from the compressors of little turbine engines is often not enough to completely inflate the boots, the air can often becomes contaminated with moisture and causes ice to form in the inflation tubes, and bleed air drawn from the compressor means less air for the engine to develop the necessary power to climb out of icing conditions or even to provide cabin heat.

    Electrically driven air pumps is clearly the better idea because the pumps are single purpose and can supply full inflation pressures regardless of aircraft altitude, cabin heat requirements or moisture.

    All of these systems share the same problem. They are designed to remove ice allowed to accumulate rather than preventing its accumulation. It is the accumulation of ice that has proven to be the undoing of many pilots and their aircraft because the manufacturers have hidden a very important fact. They don’t work effectively in the icing conditions that these airplanes regularly fly in and that most pilots think are safe to fly in. None of the federal agencies have taken strong action but there has been talk for decades about the problem. Nonetheless people continue to die each icing season.

    Most deicing boots cover less of the airfoil than is required to remove dangerous accumulations of ice. Most deicing boots are impacted by the lack of adequate inflation pressure especially at altitude or with cabin heat on, and many deicing boots will accumulate moisture that will affect the amount of inflation. Couple this with some very unforgiving airfoils that have sharp stall characteristics and the use of deicing boots for known icing certification can be disastrous.

    Federal authorities have been uniform in blaming pilots for icing accidents. Clearly these blame merchants are either not pilots, or have never flown in the clouds in the winter. Icing is unpredictable and even when forecast occurs only forty percent of the time. To blame a pilot for a crash because he didn’t predict weather even the National Weather Service can’t get right seems unfair since for the most part pilots are unaware of the limitations of their deicing equipment as manufacturers have not been honest about the limitations.

    Other Than Trace To Light Icing, Deicing Equipment In Most General Aviation Airplanes Doesn’t Work.

    Neither the testing nor the equipment was ever designed to permit continuous flight in moderate icing conditions. The regulations require it but the manufacturers do not test for it and the aircraft will not handle it. Not a believer, look at the accident reports. They are replete with pilots who cannot believe their multimillion dollar aircraft can’t handle continuous moderate icing, a question they no doubt carry to their deaths.

    Even the manufacturers can’t agree with either each other or the Government about when to de-ice. Some say wait until three quarters to one inch of rime ice accumulates before activating the boots. Others say, no, activate boots at the first sign of ice. Some say wait for less clear ice to accumulate before activation and others say activate the boots when such ice is anticipated. Some say don’t activate the boots on approach because it will slow the aircraft by ten knots or so and other say use the boots continuously. Some say ice bridging occurs if you use the boots too soon and too frequently and others say that’s an old pilot’s tale, dead old pilot no doubt.

    Some NACA five digit airfoils, widely used in general aviation and some smaller turboprop commuter aircraft grow ice aft of the boots just because of their angle of attack in flight. Some will accumulate ice aft of the boots at the highest point of lift at twelve percent cord and others will react violently especially when the ice accumulates on the horizontal tail. Some airplanes will suffer an ice-induced tail stall for which recovery virtually no pilots have been trained. It is opposite normal stall recovery and may not be recoverable at all.

    The manufacturers of big airplanes, transport category airplanes, have long recognized that the use of deicing boots is not a safe solution for the demands of air carriers who may have to fly in ice for a long time. Years ago they abandoned de-icing boots in favor of anti-ice systems. As one famous aeronautical engineer from a well known manufacturer has said: “You could not expect de-icing boots to effectively remove ice from an aircraft that had to fly from Paris to New York much of it in icing conditions so we heated the leading edges of the surfaces instead so ice wouldn’t accumulate.”

    Anti-ice as it is called is the only safe way to keep modern aircraft safe in icing conditions. Heating the leading edges of the aerodynamic surfaces is the best way. In turbine aircraft, bleed air from the compressor of the engine is routed though the leading edges. It heats stainless steel strips and they will not allow the accumulation of ice. This requires lots of bleed air and that robs the engines of power and increases fuel consumption. It requires much more power than is necessary for the flight itself and typically is found in larger more powerful aircraft although it is also used in regional jets and many executive jet aircraft but sadly not all. Requiring more power means more expense to buy, greater expense to operate but greater safety is the prize. Other anti-icing options include, weeping wings which bleed glycol or other anti-icing fluids through tiny holes in a mesh leading edge, and electrically heated leading edge devices. The electrically heated leading edge devices will become more and more prolific once low weight high power electrical generators are introduced currently being developed for the newest transport category airliners.

    Fortunately for jet operators, much of their flying time is above the weather including icing conditions but as many of the very light jets compete for scarce airspace and air traffic delays due to bad weather become more common, these low powered mostly de-icing equipped jets will suffer from accidents due to the limitations of this equipment. The propeller driven piston powered airplanes are simply doomed to suffer accidents in icing conditions because “certified for flight into known icing conditions” is a cruel hoax for which they are clearly ill-equipped. Small turbine propeller driven aircraft are equally hexed because their tiny engines just don’t have sufficient bleed air to do the job to inflate the boots under the most demanding of flight conditions.

    The answer is straightforward. First, the Federal authorities must get their acts together and make a sensible realistic definition of “known icing conditions”. Second, the Federal authorities must ensure that manufacturers comply not only with the letter of the law but also the spirit of the law. If a manufacturer anticipates as it should that a “known icing” certified aircraft will be flown in lots of different icing conditions then it must ensure the aircraft will do it safely. Today that is not so. Third, the Federal authorities must mandate that all aircraft with a “known icing” certification be equipped with anti-icing equipment sufficient to prevent the accumulation of ice and that all power plants have sufficient reserve power to effectively operate this equipment. Fourth, the Federal authorities must carefully review prior known icing certifications and monitor new ones to ensure not that the aircraft meets the letter of the law but that it will be safe to fly in all reasonably anticipatable icing conditions. Under no circumstances should Federal authorities be allowing manufacturers to rewrite their flight manuals after certification to accommodate the reality of accidents in airplanes that never met the requirements in the first place.

    Safe flight in icing conditions can’t be the luck of the draw, it must be totally predictable, repeatable and without chance. The only thing manufacturers have control over is to design and build in the capability of an aircraft to safely fly in icing conditions. A higher authority has control over the existence of and the severity of icing conditions that are likely to be experienced. Given man’s control over the former and his lack of control over the latter it is incumbent upon him, and well within the technology, to ensure that emergence safely from the latter is guaranteed.

    – Arthur Alan Wolk

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