Repost: Mini Evac Tests / Certification Analysis
Posted On: 02/12/2016 3:39:43 PM
Posted By: The Lieutenant
From a fellow BLTA investor:
Hi,
I suppose you've already been in contact with Congressman Lee Zeldin (assuming you live in his district) to push the FAA. Attached is an info sheet I wrote about the mini-evac problem that you can use for reference.
An ex-FAA exec I know says that the best way to stimulate a quick
decision from the FAA is not to get a congressman to send a letter, but instead for the congressman to request a meeting with the head of the FAA, Michael Huerta. Lee Zelden of Long Island, as vice-chair of the Aviation Subcommittee has a lot of clout. And right now the FAA is under a lot of pressure because its reauthorization bill and another bill to privatize air traffic control (which the FAA is against) are being considered right now. This tension can be used to Baltia's advantage to get a favorable decision quickly, if stockholders play the right cards.
Lee Zeldin's phone numbers:
DC: (202) 225-3826
Patchogue: (631) 289-1097
Riverhead: (631) 209-4235
Regarding the Baltia situation, and the one-year hold-up in getting a passing grade on a "mini-evac" test ("mini" because it's done without "passengers," done with crew only), this has been due to mechanical problems, mostly with slides inflation. The slides inflation problem is completely beyond Baltia's control because Baltia doesn't pack the slides. The slides are packed by FAA certified slide packing companies. It should be noted that industry-wide, according to the NTSB the slide failure rate in airline accidents and incidents has been 37%, which has been of great concern to both the NTSB and FAA.
The way the mini-evac test works is this. The 747 has 10 doors on the main deck. For the test, only 5 doors are used, but the airline is not told by the FAA inspectors which 5 to use until the moment of the test. Then the crew has to get the doors opened and the slides deployed quickly enough to be able to get all passengers off in less than 90 seconds. In all of the attempted tests, the crew performed as required. The problem was only with doors or slides.
In the first test, Baltia used the evac checklist that came with the plane from Northwest Airlines. Unfortunately, that checklist had an error in the cabin depressurization procedure that interfered with the opening of some of the doors. Getting a corrected checklist solved that problem.
During test #2, at least one evac slide failed to inflate.
In another test (#3), an FAA inspector miscued one of the lights indicating which doors were to be used in the test, so that Baltia used 6 doors instead of 5. Of the 6, 5 doors correctly opened and had correctly inflated slides, but 1 had a slide failure. Baltia believes that because they met the test requirement of 5 sets of doors and slides operating, that they should be given a "pass" for this test. But it was judged a “fail” and so Baltia proceded to test #4.
During test #4, at least one evac slide failed to inflate.
In April, 2015, Igor Dmitrowsky (an engineer by training) analyzed the slides non-inflation problem, which has plagued other airlines too, and he discovered it was caused by the packing companies providing a Mooring Line (strap) of the wrong length. The correct length, noted in the manufacturer's manual, is 24 inches. But repacked slides were being sent to Baltia with Mooring Lines of much lesser length, which interfered with the slide launching mechanism. Once Baltia found this problem, and got the slide re-packers to put the 24" length on their checklists, that problem was solved -- not only for Baltia, but for all airlines. But rather than giving credit to Baltia for solving a problem that had caused a 37% failure rate of slides industry wide, the FAA has penalized Baltia for not solving the problem sooner -- a problem that the FAA as certify-er of the slide packers should have analyzed and solved itself years ago.
Two more mini-evac tests were performed after Baltia's April discovery and the correction of packer checklists. One in late May, 2015, which failed due to a girt bar problem (this bar anchors the slide to the plane's doorway). Unfortunately, after a girt bar is installed,there is no way to determine if it will work properly. But Baltia has taken responsibility for that failure. Then at the end of July, the last test was done in which all of the slides opened, but one of them got tangled up during inflation due to another type of packing error -- a misthreaded cable inside the sealed slide-pack which Baltia had no way of checking. At that test there were about 30 FAA inspectors on site. All but one of them voted to give Baltia a "pass" on this test. Without a unanimous decision, the decision was pushed upstairs to FAA management in Washington, where it sat for months. Some in FAA management -- who apparently had not been given all of the facts -- believed that Baltia's certification process should be terminated because there had been so many evac test failures.
Baltia made two presentations to FAA officials in Washington in September and December to try to get an evac "pass" decision based on two tests where slide failures from 3rd party packing errors were beyond Baltia's control, or a "pass" for the one test where 6 doors were opened and 5 performed flawlessly with their slides. Granting a “pass” in one of these cases will not compromise passenger safety, because Baltia has identified the causes of the slide packing errors (incomplete slide-packing checklists used by 3rd party slide packers) and has gotten appropriate corrections made. Baltia should be commended for finding solutions to slide inflation problems that had vexed the FAA for over 10 years—solutions that will now benefit all other air carriers and the traveling public. Instead, the FAA has stopped Baltia’s certification process.
After the December presentation to John Duncan, the FAA director of safety, he apparently led Mr. Dmitrowsky to believe that he was favorably inclined toward a "pass," but that it would have to be a team decision that Baltia could expect to receive between January 4th to the Jan 15th of 2016. Such decision has not yet been forthcoming, and so congressional help is needed to unstick the logjam.
A few years ago, the FAA Administrator, Michael Huerta, said in a speech or article that, looking ahead, airline traffic is expected to grow dramatically during the next ten years – perhaps to even double the current volume. His main point was that FAA resources had to be increased to be capable to meet the needs of this volume growth.
If Mr. Huerta’s prediction is correct, then the future would seem to hold great opportunities for growth for existing airlines and for the creation of new airlines. However, regarding new airlines, the last scheduled part 121 airline (airlines flying full-size and jumbo airliners) to be certified by the FAA was Virgin America in 2007. At that time, the certification of a new airline typically took 6-9 months. Then an entirely new system of certification was instituted by the FAA, under which several new airline applicants would have to proceed. Some of them were Baltia Air Lines, California Pacific Airlines, and People Express (new version). Both California Pacific and People Express eventually failed to make it through the new process and had to withdraw. But Baltia persevered through what has now been 5 years in certification.
In this new FAA certification process, it is now obvious that going through the airline certification rocess must be measured in years, not months. A large part of the predicted traffic growth is in international travel. But, the way the rules are set up, any new airline certified overseas, by much less stringent certification processes, can fly into the U.S. within the scope of “open skies” or “bilateral route assignments.” Thus new foreign carriers are likely to reap far more gain from the traffic growth that is provided largely by American travelers, while new American airlines languish in the overly bureaucratic FAA certification process. Is this good for competition? Is this good for the American traveler? Is this good for American business?
A specific example of this problem is in Baltia’s certification process. Baltia’s current holdup is due largely to a gray area in the decision authority given to the FAA’s certification managers by the certification regulations. The problem is that the situation Baltia has encountered in trying to pass the “mini-evac” test was not anticipated when the regulations were written. That situation is where a test failure – the failure of evacuation slides to inflate -- is consistently due to errors made by 3rd party FAA certified vendors – in Baltia’s case, the slide repackers. Though FAA officials seem to have been sympathetic to Baltia’s mishaps caused by 3rd parties, and though the regulations do give the on-site certification manager some leeway in authorizing an additional attempt to pass the test, there doesn’t seem to be clear authorization in the regs. to allow classifying an error caused by an FAA certified 3rd party as a “pass” isnstead of a “fail.” Yet Baltia was able to find the cause of the 3rd party errors and rectify them so they will not be repeated. So, not only would passenger safety not be compromised by giving Baltia a “pass,” it will actually be greatly improved for all airlines due to Baltia’s discovery of the root causes of slide failures.
It should be noted that prior to Baltia’s first mini-evac test in November of 2014, the FAA already had a big concern about evacuation slides that for unknown reasons weren’t inflating in airliner emergencies. An NTSB study found that 37% of slides in these instances weren’t opening. This FAA concern was heightened in the spring of 2015 when a Delta Airlines plane ran off the runway at LaGuardia and most of the slides did not inflate. Well, Igor Dmitrowski’s discovery in April, 2015, that most slide failures were due to an incorrect length for the Mooring Line in the repacked slides solves the problem. This line must be at least 24 inches long, or else it will interfere with slide activation by the Trigger Strap. Igor (a trained engineer) found that on many of the repacked slides, the Mooring Line was much less than 24 inches long, preventing the Trigger Straps from working so that the slides did not inflate.
Upon investigating the source of this defect with the slide repacker, Baltia found that the repacker’s checklist had no mention of the 24 inch requirement for Mooring Lines, even though this requirement is stated in the manufacturer’s manual. Subsequently, the repacker inserted that requirement onto their repacking checklist. This finding by Baltia will greatly benefit slide reliability and safety for all airlines and their passengers as slides are repacked. (Perhaps all repacked slides of all airlines should be recalled and then repacked according to the Baltia fix., for the safety of the traveling public.)
The last Baltia test attempt on July 28, 2015, saw a different type of repacking error cause a slide failure. In this case, a slide began to inflate properly, but then a cable that was misrouted in the repacking process (and being inside the sealed pack, could not be checked by Baltia) caused the slide to get tangled like a pretzel. Again, due to a 3rd party FAA certified vendor’s fault. Another repacking checklist correction was made to prevent this in the future, to the benefit of all airlines, the traveling public, and the FAA.
And so, Baltia’s certification is at a standstill, even though they have solved significant safety problems affecting all airlines and the traveling public. A solution to the FAA’s procedural problem in allowing Baltia to now proceed to the next step in certification, would be to navigate the decision-making gray area of the certification regs by applying the over-arching interests of public safety that the regulations are supposed to protect to enable a correct decision. Has Baltia’s identification of solutions to slide inflation problems sufficently decreased the likelihood of these 3rd party errors happening again, so that Baltia should be given a “pass” for test #7 and perhaps two prior tests that failed due to systemic 3rd party problems that Baltia later solved for all airlines?
Thanks to Baltia’s solutions, the next airline going through this certification step will likely sail through the mini-evac test. So, hasn’t Baltia earned the right to a “pass” also?
Obviously, the new certification regulations are a problem, because no new part 121 scheduled American airline has successfully gone through certification in the last nine years. This creates a so-far insurmountable challenge for new American airlines that may seek to serve the growing need for more available seats on international routes. Thus, these service opportunities will most likely go to foreign carriers instead. It would seem that this would not be in the USA’s best interests.
Imagine the outcry in the business community if the process for incorporating a new business had been made so excessively rigorous that no new incorporations had been made in the last 9 years?
This certification problem extends way beyond Baltia, and with unnecessary bad implications for the future of new airlines in the US, and with results that do not really enhance airline safety.
Why has the new airline certification process not produced new certified airlines, and what impact may that have on meeting the challenges of growing air travel demand that Mr. Huerta has predicted?
http://investorshangout.com/post/view?id=3548997
BLTA
Posted On: 02/12/2016 3:39:43 PM
Posted By: The Lieutenant
From a fellow BLTA investor:
Hi,
I suppose you've already been in contact with Congressman Lee Zeldin (assuming you live in his district) to push the FAA. Attached is an info sheet I wrote about the mini-evac problem that you can use for reference.
An ex-FAA exec I know says that the best way to stimulate a quick
decision from the FAA is not to get a congressman to send a letter, but instead for the congressman to request a meeting with the head of the FAA, Michael Huerta. Lee Zelden of Long Island, as vice-chair of the Aviation Subcommittee has a lot of clout. And right now the FAA is under a lot of pressure because its reauthorization bill and another bill to privatize air traffic control (which the FAA is against) are being considered right now. This tension can be used to Baltia's advantage to get a favorable decision quickly, if stockholders play the right cards.
Lee Zeldin's phone numbers:
DC: (202) 225-3826
Patchogue: (631) 289-1097
Riverhead: (631) 209-4235
Regarding the Baltia situation, and the one-year hold-up in getting a passing grade on a "mini-evac" test ("mini" because it's done without "passengers," done with crew only), this has been due to mechanical problems, mostly with slides inflation. The slides inflation problem is completely beyond Baltia's control because Baltia doesn't pack the slides. The slides are packed by FAA certified slide packing companies. It should be noted that industry-wide, according to the NTSB the slide failure rate in airline accidents and incidents has been 37%, which has been of great concern to both the NTSB and FAA.
The way the mini-evac test works is this. The 747 has 10 doors on the main deck. For the test, only 5 doors are used, but the airline is not told by the FAA inspectors which 5 to use until the moment of the test. Then the crew has to get the doors opened and the slides deployed quickly enough to be able to get all passengers off in less than 90 seconds. In all of the attempted tests, the crew performed as required. The problem was only with doors or slides.
In the first test, Baltia used the evac checklist that came with the plane from Northwest Airlines. Unfortunately, that checklist had an error in the cabin depressurization procedure that interfered with the opening of some of the doors. Getting a corrected checklist solved that problem.
During test #2, at least one evac slide failed to inflate.
In another test (#3), an FAA inspector miscued one of the lights indicating which doors were to be used in the test, so that Baltia used 6 doors instead of 5. Of the 6, 5 doors correctly opened and had correctly inflated slides, but 1 had a slide failure. Baltia believes that because they met the test requirement of 5 sets of doors and slides operating, that they should be given a "pass" for this test. But it was judged a “fail” and so Baltia proceded to test #4.
During test #4, at least one evac slide failed to inflate.
In April, 2015, Igor Dmitrowsky (an engineer by training) analyzed the slides non-inflation problem, which has plagued other airlines too, and he discovered it was caused by the packing companies providing a Mooring Line (strap) of the wrong length. The correct length, noted in the manufacturer's manual, is 24 inches. But repacked slides were being sent to Baltia with Mooring Lines of much lesser length, which interfered with the slide launching mechanism. Once Baltia found this problem, and got the slide re-packers to put the 24" length on their checklists, that problem was solved -- not only for Baltia, but for all airlines. But rather than giving credit to Baltia for solving a problem that had caused a 37% failure rate of slides industry wide, the FAA has penalized Baltia for not solving the problem sooner -- a problem that the FAA as certify-er of the slide packers should have analyzed and solved itself years ago.
Two more mini-evac tests were performed after Baltia's April discovery and the correction of packer checklists. One in late May, 2015, which failed due to a girt bar problem (this bar anchors the slide to the plane's doorway). Unfortunately, after a girt bar is installed,there is no way to determine if it will work properly. But Baltia has taken responsibility for that failure. Then at the end of July, the last test was done in which all of the slides opened, but one of them got tangled up during inflation due to another type of packing error -- a misthreaded cable inside the sealed slide-pack which Baltia had no way of checking. At that test there were about 30 FAA inspectors on site. All but one of them voted to give Baltia a "pass" on this test. Without a unanimous decision, the decision was pushed upstairs to FAA management in Washington, where it sat for months. Some in FAA management -- who apparently had not been given all of the facts -- believed that Baltia's certification process should be terminated because there had been so many evac test failures.
Baltia made two presentations to FAA officials in Washington in September and December to try to get an evac "pass" decision based on two tests where slide failures from 3rd party packing errors were beyond Baltia's control, or a "pass" for the one test where 6 doors were opened and 5 performed flawlessly with their slides. Granting a “pass” in one of these cases will not compromise passenger safety, because Baltia has identified the causes of the slide packing errors (incomplete slide-packing checklists used by 3rd party slide packers) and has gotten appropriate corrections made. Baltia should be commended for finding solutions to slide inflation problems that had vexed the FAA for over 10 years—solutions that will now benefit all other air carriers and the traveling public. Instead, the FAA has stopped Baltia’s certification process.
After the December presentation to John Duncan, the FAA director of safety, he apparently led Mr. Dmitrowsky to believe that he was favorably inclined toward a "pass," but that it would have to be a team decision that Baltia could expect to receive between January 4th to the Jan 15th of 2016. Such decision has not yet been forthcoming, and so congressional help is needed to unstick the logjam.
A few years ago, the FAA Administrator, Michael Huerta, said in a speech or article that, looking ahead, airline traffic is expected to grow dramatically during the next ten years – perhaps to even double the current volume. His main point was that FAA resources had to be increased to be capable to meet the needs of this volume growth.
If Mr. Huerta’s prediction is correct, then the future would seem to hold great opportunities for growth for existing airlines and for the creation of new airlines. However, regarding new airlines, the last scheduled part 121 airline (airlines flying full-size and jumbo airliners) to be certified by the FAA was Virgin America in 2007. At that time, the certification of a new airline typically took 6-9 months. Then an entirely new system of certification was instituted by the FAA, under which several new airline applicants would have to proceed. Some of them were Baltia Air Lines, California Pacific Airlines, and People Express (new version). Both California Pacific and People Express eventually failed to make it through the new process and had to withdraw. But Baltia persevered through what has now been 5 years in certification.
In this new FAA certification process, it is now obvious that going through the airline certification rocess must be measured in years, not months. A large part of the predicted traffic growth is in international travel. But, the way the rules are set up, any new airline certified overseas, by much less stringent certification processes, can fly into the U.S. within the scope of “open skies” or “bilateral route assignments.” Thus new foreign carriers are likely to reap far more gain from the traffic growth that is provided largely by American travelers, while new American airlines languish in the overly bureaucratic FAA certification process. Is this good for competition? Is this good for the American traveler? Is this good for American business?
A specific example of this problem is in Baltia’s certification process. Baltia’s current holdup is due largely to a gray area in the decision authority given to the FAA’s certification managers by the certification regulations. The problem is that the situation Baltia has encountered in trying to pass the “mini-evac” test was not anticipated when the regulations were written. That situation is where a test failure – the failure of evacuation slides to inflate -- is consistently due to errors made by 3rd party FAA certified vendors – in Baltia’s case, the slide repackers. Though FAA officials seem to have been sympathetic to Baltia’s mishaps caused by 3rd parties, and though the regulations do give the on-site certification manager some leeway in authorizing an additional attempt to pass the test, there doesn’t seem to be clear authorization in the regs. to allow classifying an error caused by an FAA certified 3rd party as a “pass” isnstead of a “fail.” Yet Baltia was able to find the cause of the 3rd party errors and rectify them so they will not be repeated. So, not only would passenger safety not be compromised by giving Baltia a “pass,” it will actually be greatly improved for all airlines due to Baltia’s discovery of the root causes of slide failures.
It should be noted that prior to Baltia’s first mini-evac test in November of 2014, the FAA already had a big concern about evacuation slides that for unknown reasons weren’t inflating in airliner emergencies. An NTSB study found that 37% of slides in these instances weren’t opening. This FAA concern was heightened in the spring of 2015 when a Delta Airlines plane ran off the runway at LaGuardia and most of the slides did not inflate. Well, Igor Dmitrowski’s discovery in April, 2015, that most slide failures were due to an incorrect length for the Mooring Line in the repacked slides solves the problem. This line must be at least 24 inches long, or else it will interfere with slide activation by the Trigger Strap. Igor (a trained engineer) found that on many of the repacked slides, the Mooring Line was much less than 24 inches long, preventing the Trigger Straps from working so that the slides did not inflate.
Upon investigating the source of this defect with the slide repacker, Baltia found that the repacker’s checklist had no mention of the 24 inch requirement for Mooring Lines, even though this requirement is stated in the manufacturer’s manual. Subsequently, the repacker inserted that requirement onto their repacking checklist. This finding by Baltia will greatly benefit slide reliability and safety for all airlines and their passengers as slides are repacked. (Perhaps all repacked slides of all airlines should be recalled and then repacked according to the Baltia fix., for the safety of the traveling public.)
The last Baltia test attempt on July 28, 2015, saw a different type of repacking error cause a slide failure. In this case, a slide began to inflate properly, but then a cable that was misrouted in the repacking process (and being inside the sealed pack, could not be checked by Baltia) caused the slide to get tangled like a pretzel. Again, due to a 3rd party FAA certified vendor’s fault. Another repacking checklist correction was made to prevent this in the future, to the benefit of all airlines, the traveling public, and the FAA.
And so, Baltia’s certification is at a standstill, even though they have solved significant safety problems affecting all airlines and the traveling public. A solution to the FAA’s procedural problem in allowing Baltia to now proceed to the next step in certification, would be to navigate the decision-making gray area of the certification regs by applying the over-arching interests of public safety that the regulations are supposed to protect to enable a correct decision. Has Baltia’s identification of solutions to slide inflation problems sufficently decreased the likelihood of these 3rd party errors happening again, so that Baltia should be given a “pass” for test #7 and perhaps two prior tests that failed due to systemic 3rd party problems that Baltia later solved for all airlines?
Thanks to Baltia’s solutions, the next airline going through this certification step will likely sail through the mini-evac test. So, hasn’t Baltia earned the right to a “pass” also?
Obviously, the new certification regulations are a problem, because no new part 121 scheduled American airline has successfully gone through certification in the last nine years. This creates a so-far insurmountable challenge for new American airlines that may seek to serve the growing need for more available seats on international routes. Thus, these service opportunities will most likely go to foreign carriers instead. It would seem that this would not be in the USA’s best interests.
Imagine the outcry in the business community if the process for incorporating a new business had been made so excessively rigorous that no new incorporations had been made in the last 9 years?
This certification problem extends way beyond Baltia, and with unnecessary bad implications for the future of new airlines in the US, and with results that do not really enhance airline safety.
Why has the new airline certification process not produced new certified airlines, and what impact may that have on meeting the challenges of growing air travel demand that Mr. Huerta has predicted?
http://investorshangout.com/post/view?id=3548997
BLTA
5
