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published in an FAA magazine which radically changed a long

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standing FAA emergency procedure regarding aircraft which have lost their two way voice communications and must continue a flight under instrument flight cnditions. The author informed me that his new interpretation was correct. I pointed out to him that he was contrary to FAA's Own glossary and the FAA Flying Handbook. He expressed ignorance of the glossary and was obviously not knowledgeable of the Handbook. He finally acknowledged that the glossary said exactly what I maintained, but dismissed it as "International Civil Aviation Organization definition" and did not apply to the U.S.A., even though it was in the FAA glossary and we were members of ICAO. I received a letter from the head of ICAO operations and he emphasized that the new FAA interpretation was incorrect. The FAA author was not swayed, saying that we had our own rules. I pointed out that this new interpretation could cause confusion and possible accidents at the air terminals. The author informed me that there would be no confusion since there would be radar at the terminals to sort things out. The FAA author of this drastic change was obviously not aware that most of the airports in this country that have instrument approaches do not have radar control and must rely upon established published procedures that provide safety.

I finally gave up on Oklahoma City FAA people changing their view and wrote a letter, with documentation, to the FAA Operations people in Washington. I did get a quick reply from a head honcho who agreed with me and the long established FAA procedure. A copy of his letter was sent to the FAA people in Oklahoma City, but was ignored. Subsequent FAA Instrument Question books contained questions where the answer is wrong unless you accept the new procedure, which is unsafe.

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FAA does not tell applicants for various pilot written tests exactly which questions they missed apparent reason that they are afraid that they may be challenged, in court, on the validity of questions test. FAA does tell applicants the general area of the missed question such as Regulations, Air Space, approaches, etc. However, that can cover a multitude of questions, and the pilot then is certified by FAA, not really knowing what he does or does not know.

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Over the past 20 years, I have had occasion to write FAA in order to clarify regulations and procedures that posed a potential safety hazard or were being generally misinterpreted or exploited to short requirements for pilots to obtain their ratings. These were legitimate questions whose answers were not clear to FAA Flight Examiners and to those of us with considerable experience. sent certified letters to FAA and have yet to receive answers. Two years after one letter, I received a telephone call from one FAA official in Washington, D. C. who said that

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he had just been given the letter from me for action. We discussed the procedure in question, which could have recently quite possibly played a part in the South American accident whereby an aircraft on instruments hit a mountain, and could have played a part in the accident that killed Secretary Brown. The FAA official in Washington agreed with me that the procedure allows an aircraft to descend only in the manuevering side for the approach. I explained that their own FAA Examiners and other pilots were interpreting the FAA procedures otherwise. I asked the FAA official to please put in writing what he had just told me. I have yet to have my certified letters answered.

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I also asked FAA, in writing, to clearly state if they approved of two pilots taking credit for being the pilot-in-command of the same aircraft at the same time even though FAA says the pilot-in-command is the ultimate authority for the safety of that aircraft. How can two pilots be the ultimate authority at the same time? I know, and FAA knows, that flight schools and individual pilots logging this time twice so as to acquire requirements to obtain their FAA ratings. To get Commercial or Air Transport Pilots certifications, So that passengers may be carried for hire, the applicant must show that he acquired so much pilot-in-command flying time. It scares the hell out of me to think that I am about to board a commuter airplane that is about to go into weather conditions and it is possible the Captain, and co-pilot, may not have ever flown in actual weather conditions. This could be the first time that the Captain has ever truly been the pilot-in-command since he soloed for his Private license. This is not a problem with major airlines, since their co-pilots will have years of experience before they become Captain. The co-pilot should have been required to get honest time before he got his Commercial Rating. Again, FAA will not put in writing or publicly clarify this situation. The fatality of the 7 year old being in control of an airplane points up the laxity of FAA in this area.

I know of one case where a commuter airline found out that one of their Captains had only a total of several hundred hours total flying time when it takes a total of at least 1500 hours to obtain an FAA Airport Transport license. The individual had padded the log book, which again, is little console to paying passengers. After an accident FAA always says that the individuals involved had met the FAA standards in getting their ratings. They don't tell you that the individuals may have had to take perhaps 10 flight checks or multiple written tests before passing. I have heard of an airline Captain that took over 10 simulated check rides before being passed. When the FAA fails a pilot applicant, the re-checks will only include those items which were failed. The applicant is not put through the rigors of a complete flight as he may later encounter and probably under adverse conditions. As a flight instructor for over 50

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years, I have seen pilots that

never should have obtained their license, and I can cite quite a few of those that killed themselves, and others, in aircraft accidents. FAA believes that everyone has a right to have a pilot's license and FAA even bends the rules and eases the requirements to assure that those who want a license can get one. We get many student pilots training in this country, not only for economic reasons, but also because we are much more lenient than other countries. Even So, some countries require considerable additional training.

The head of FAA is a political appointee and generally knows little about flying. It is a joke to hear the FAA Administrator say that they have the most knowledgeable people in the business. Airlines pilots will tell you about the arrogance and immaturity of FAA Inspectors that board their airplanes, flashing their badges under the Captain's nose and declaring that they are checking a 30 year pilot's capabilities. The FAA would be wise to hire those airline pilots who retire at age 60 and let them be their flight inspectors. I am sure that many of those pilots would relish working for another five years, and the country would certainly benefit.

The flight part of FAA is a mess and needs cleansing. I would be happy to furnish documentation.

638 Driftwood Drive Lynn Haven, Fl 32444 Tel. (904) 265-2297

Maman

William M. Cowan

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I am writing to solicit your support for the return of ValuJet Airlines. ValuJet has provided economical airfare to millions of travelers. A large percentage of Americans cannot afford to travel on the airfares offered by major carriers. The Atlanta market has for years maintained a monopolistic dominant carrier. With the introduction of ValuJet Airlines, the airfares were lowered.

I am in sincere remorse of the tragic accident on ValuJet Flight 592, but we must learn from our mistakes and put methods in place to circumvent future occurrences. Ultimately, the public is suffering along with 4000 displaced workers in due respect to those who lost their lives a result of the recent air tragedy. I am an employee and customer of ValuJet Airlines, I strongly believe our maintenance, safety program and properly trained crew are very important.

As an employee, internally speaking, ValuJet stride for quality assurance. Having read various news articles; watching television news, and listening to our President Mr. Lewis Jordan, ValuJet increased its efforts to put programs into place to address such issues.

The staff of ValuJet has personnel with many years of aviation experience. Grounding a entrepreneurial carrier the size of Valujet seems to destroy the true essence of the American Dream. That is to start a business, watch it grow, learn from your mistakes, and stratigize for success.

Please help return ValuJet to the airways and low fares to the East Coast.

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I am writing to you in regard to a matter related to the recent ValuJet crash in the Everglades. I spent 16 days at the scene of the crash as the American Red Cross Mass Care Officer, in charge of providing all the food and other similar supplies to the NTSB, police, fire, and other emergency workers at the scene.

This letter to you is instigated by the crash because it has again brought up a pattern of behavior by the (career) FAA Associate Administrator for Regulation and Certification, Anthony J. Broderick. I am aware that Mr. Broderick has agreed to an early retirement. I can only say that I am pleased. Based on personal experience in dealing with Mr. Broderick, I feel that it is not an exaggeration for me to allege that his policies and behavior, over a period of many years, have been responsible for much loss of life within the aviation community.

The primary reason for this allegation is that I had substantial dealings with him and other FAA personnel within his Office during a several month period in 1993 while I was the lead investigator of a significant aviation safety issue, as a member of the Vice President's National Performance Review.

The persons I interviewed in 1993 within the FAA Office of Regulation and Certification told me that Mr. Broderick had, and was continuing to, "stonewall" the issue of requiring improved Emergency Locator Transmitters (ELTS) on United States aircraft. Personnel at the NTSB felt the same way. I also met personally with Mr. Broderick, and came away with the same impression.

The FAA has delayed the implementation of an improved ELT on United States aircraft for 20 years, and, although I have been retired since 1994 and have been away from the issue for two years, I believe it has continued to do so to this day.

I bring all this up now, not to further attack Mr. Broderick, but in the hope that, with his departure, some real progress can now be made toward mandating the replacement of the totally inadequate Model TSO C-91 ELTs with Model TSO C-126 (or equivalent) ELTs in all U.S. aircraft.

I enclose a copy of the National Performance Review study (August 1993) for your further consideration.

Sincerely

Richard Fremont-Smith

Captain, USCGR (Retired)

Enclosure (as stated)

26-755 97-17

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