The Importance of Questions
Sometimes, the question may be as important as the answer, particularly when people in a position to answer decline to do so in a straightforward, honest manner.
Sometimes, the question may be as important as the answer, particularly when people in a position to answer decline to do so in a straightforward, honest manner. Some questions below fall into that category.
Several years ago the FAA proposed an airworthiness directive on Bell Helicopter 205, 212 and 412 tail booms. It indicated that tail booms equipped with aftermarket strakes were suffering from an increased incidence of cracks.
The A.D. included a course of remediation to this supposed problem. (Its details are not here.) Once the proposal hit the operator community, the reaction was loud and immediate.
The medium Bell community told the FAA that tail boom cracks had been a recurring problem long before anyone knew what a strake was and that blaming strakes was not a well-conceived thought. The proposed A.D. was rescinded.
Who raised this issue? What agenda drove it? And why did the FAA allow itself to be sucked into what was an obvious commercial ploy to eliminate a competitor? Today BLR Aerospace strakes are on every 412 Bell produces.
Why has the FAA decided that now is the time to investigate inlet barrier filters (IBFs)? What incident, accident or sleight of hand caused this issue to be elevated to the FAA’s critical-issues list?
In the FAA town hall meeting at Heli-Expo last March, FAA Rotorcraft Directorate Manager Lance Gant said, “There’s not an unsafe condition identified regarding IBFs.”
Furthermore, the manufacturers of these systems have shown statistics that indicate aircraft with IBFs installed have accumulated around 20 million hr of engine flight time without a single issue. Again I ask, what caused this issue to become a critical one for the FAA?
At a meeting held by the General Aviation Manufactures Assn. in June, all but one of the large helicopter OEMs indicated that the installation of aftermarket IBFs is a non-issue for them. What is the concern of that last OEM? Does it have a legitimate safety concern? If so, let’s hear it.
Does the fact that this particular manufacturer has shown an interest in producing its own IBFs cause me to think that trying to eliminate competition in the marketplace is the real issue? You could think that.
The additional data point in this mess is that knowledgeable folks in the helicopter industry are convinced that the FAA has a separate, symbiotic issue in addition to the commercial aspects. The course of action taken here would allow the FAA to set a precedent of changing set rules or policy on how supplemental type certificates (STCs) are accomplished without the burden of a formal rulemaking process (which includes a financial impact study).
This could forever change the way STCs are attained, requiring potential applicants to obtain detailed data from OEMs. In fact, the FAA indicated that the IBF manufacturers should obtain additional data from the OEMs to meet the new criteria it is proposing. The chances of the OEMs releasing this data is nonexistent, in my experience. The FAA’s suggestion about the data is either naive to a fault or arrogant beyond the pale.
Why should all of this concern you? The pilot, mechanic and operator, after all, are not involved with attaining STCs. They don’t manufacture parts that require STCs. All they want to do is enjoy their passion and get the mission done.
When I was blissfully flying for a living, all I cared about was doing the best job I could and earning the respect of my customers and fellow pilots. Then I got involved with program management and eventually consulting. It took me a few years to see what was going on, but eventually I came to realize that the OEMs have a cost structure generated by a plethora of factors that does not allow them to compete with smaller, focused companies with specialties in single areas.
You should be concerned about the issues above because, taken to their final conclusion, only OEMs will be able to provide things like IBFs. When that day arrives, count on paying at least 100% more than what you pay today. I am convinced that the small support companies in the helicopter industry are the most important segment for innovation and cost control and the actions outlined above are a direct threat to their viability. R&WI