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echristley(at)nc.rr.com
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 Posted: Tue Jan 09, 2007 10:25 pm Post subject: ABEA and TSO's...and fuel level sensors |
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Chuck Jensen wrote:
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Ernst,
The AIM is like the Work Rules that Railroad Companies provide to their
employees. One important rule is when dismounting a moving train, the
employee musto ensure that he selects a safe, sound landing spot. Of
course, with rocks, weeds, ditches, ties and general debris, a safe,
sound landing spot is neigh impossible to find. Nonetheless, when
ankles are twisted or bones broken in this somewhat high risk but
necessary activity, the RR has the perfect proof that you broke the Work
Rule, because obviously, the landing spot you selected was not safe and
sound.
So it is with the AIM--a catch 22, gourdian knot, gotcha and the rest.
How can you possible be operating a plane in a safe prudent manner if
you are violating AIMs?
Chuck Jensen
Do Not Archive
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8*) There's the explanation that makes it all clear. The AIM is
informational, not regulatory. It just happens that the information it
provides is the definitions of what they meant in the regulation. When
OC spoke of "violat[ing] a provision of the AIM" , it really isn't the
AIM that's violated. It's the FAR, viewed in the light of the AIM, that
is violated.
I think an interesting corollary is provided by this document:
http://isddc.dot.gov/OLPFiles/FAA/008464.pdf It's a note to field
personnel on how to deal with making mechanics comply with
manufacturer's manual. My unlawyerly summation is that the maintenance
manual doesn't mean squat, unless there is a specific AD or FAR that
says it means something. Even then, the FAA has the burden of proof
that an equivalent repair/procedure was not sufficient. "The FAA case
should show that an equivalent level of safety was not attained."
I think these situations are related in that in both cases we have
regulations that have been instituted through due process (the FARs and
ADs), being assisted by documents that have no public review process
(AIMs and manufacturer manuals). Bureaucrats will try to brandish the
lesser documents as much as possible, but at an enforcement hearing only
the ones having passed through due process carry enforcement powers. My
faith in the American way is restored.
BTW, there's interesting reading at
http://www.ntsb.gov/alj/O_n_O/Query.ASP?WCI=Answer&WCU=
NTSB Orders are written in plain English. Read them for yourself to see
how the system really works. For instance, there is an explanation of
the Lindstam Doctrine in Order #3588. If you have an accident in an
airplane, the accident itself is proof enough that you were careless and
reckless.
Now back to what this list is about. I've modified Jim Weir's
capacitive fuel tank sensor so that a plate along the bottom can act as
the active element in the reference oscillator. This should make it
resistance to any alcohol laden gas I might pick up. It's not TSOed,
but the schematic is at
http://ernest.isa-geek.org/Delta/Library/FuelLevelSensor.pdf
[quote]
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tompkinsl(at)integra.net
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| Posted: Wed Jan 10, 2007 11:50 am Post subject: ABEA and TSO's...and fuel level sensors |
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The following is a portion of the historical basis for the term "or equivalent."
This response is also a suggestion that we each continue to do the "best we know how," as Bob N. advocates when it comes to equipment.
Unfortunately, a bureaucrat is someone who truly believes in his "heart of hearts" that it is regulations written by non-pilot lawyers rather than LIFT that keeps planes flying. Therefore, if you have a mishap in an aircraft, said bureaucraft merely needs to determine which regulation you broke and, by his own definition/philosophy, he has the explanation for your crash. So your determination to use experimental category avionics ought to be determined by your own diligent research that the product design and manufacture is reliable and durable. IMHO, you will be in the position of defending yourself after any accident you survive.
RANT:
Speaking from 35+ years auto/transportation engineering experience, some of the worst efforts by bureaucrats are when they jump on the UNDERdeveloped technology band wagon and legislate that technology into production. Some examples are the original truck ABS systems and 1st generations air bags. The original truck ABS law basically stated that semi-trucks had to have ABS brakes. Because of susceptability to RFI/EMI these early ABS trucks had NO brakes when the driver keyed the mike on his CB radio, especially if equipped witha linear amplifier. The Feds were sued by PACCAR and they learned their lesson. The Feds have learned to drive technology with "patent law" type descriptions so they can't be held liable for legally requiring technology that doesn't work. Here is one example: NHTSA wanted to standardize car bumper heights at 16 - 20" above ground, but the CFRs don't say build your car with a bumper face that is 16 - 20" above ground. The CFRs say that the bumper system is required to pass a pendulum test and the face of the pendulum that strikes the bumper will be from 16 - 20" above ground.
Back to Aviation:
Rotax was at one time going to give customers the choice of purchasing a certificated or non-certificated engine. By their own acknowledgment all the engines were built in the same facility, on the same production line and from the same parts. My recollection is that the cost of the paperwork trail added 2 - 3 thousand dollars to the price of the certificated engine. I would argue that the certification added no value.
Non-certificated avionics is not quite the same apple, because the OBAM avionics manufacturers are not building any certificated units. This is a "caveat emptor" situation. There is a lot of attraction for a GRT or AFS EFIS for 25% of the cost of a certificated Chelton System. The determination each of us potentially bets our lives and the lives of our families on is that these manufacturers have done all the work that adds value, reliability and durability without the accompanying NO value paperwork. I am contemplating one of these two systems for my own plane, but my decision will be deliberate and I will be test flying whatever system I choose for quite a while before I depend on it in the clouds.
One area where I have a great deal of concern is the experience level of the engineers at these companies. If a person is ignorant of items that have already been discovered and addressed by TSO type testing, then that person can actually believe that he is doing a terrific job, when he is truly not doing "the best we know how." TSOs offer some protection that known issues have been addressed. Without a TSO it then becomes our OWN responsibility to determine that the purveyor of the avionics is not ignorant of issues and has addressed them in his product design.
A second concern I have is that new marketing features seem to be frequently released. I don't know how well thought out and proven some of these features are. My own preference is NOT to be a Beta site for the avionics manufacturer. I am a forensic engineer and use an accident reconstruction software that has had 14 new releases since December 2005! I would argue that every user of this software (Windows XP based) is a beta site. The software is fabulously useful, but when it glitches I am still sitting in my chair firmly supported by the floor. I would not want to be using software like this at 5000' AGL in the soup!
Larry
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