Robodog, please correct me if I'm wrong. I work with the NJ Uniform Construction Code and other publications where we get these inserts and deletions regularly, similar to the AC's of the FAA. I did some digging on this, and I don't really know what to think yet. I'm glad they've acted, but I feel like the FAA didn't do a whole lot and almost just used this to deflect their role onto the air carriers.
As I'm sure you're aware, usually they put a bold line or something along the edge of the page to indicate where exactly the changes were made. They show absolutely no changes on page 2 (and don't include page 2 in the subset that needs to be replaced), but unless I'm drunk, page 2 looks totally different between the original and Change 1. The whole thing seems to be reworded and reorganized in some way, so I feel like they might have screwed up this AC and should have replaced everything and put a line next to every change, which it doesn't appear that they did. I guess what I'm saying is the way they did it, replacing the pages they suggest to replace doesn't create a cohesive document (which you would think with all this time they would have gotten right!)
But let's take a look at the items that they did put a line next to, so we can highlight what exactly changed and how it suits Baltia (for better or worse). I'll use the Change 1 article for reference:
1st change: Looks like they removed the term "FAA-approved" from both "FAA-approved inspection program" and "FAA-approved continuous airworthiness maintenance program (CAMP)".
2nd change: "All functional testing of the EES should be performed in accordance with the manufacturer's instructions and as approved in the air carrier's manual." has been changed from "as approved" to "in accordance with".
3rd change: Again, they basically removed the words "FAA-approved" and "approved".
4th change: "Accidental deployment data may be used to support revised inspection or overhaul times." This has been modified to read, "Accidental deployment data may not be used as the sole source to support revised inspection or overhaul times."
5th change: I don't see a change. It talks about in increase of failures during deployments or functional testing will initiate a corresponding increase in the sampling rate on both of them. Not sure where the change is.
6th change: Removed the word "approved" again.
After that, they added a couple reference documents that I didn't bother to check into, including another AC, but that AC was completed back in 2011.
So while I'm glad they reissued something, I'm confused as to what they really reissued. What do we think they accomplished by eliminating "approved" everywhere? Also, what is the true meaning of the 4th change about accidental deployment, because that was clearly something that looks like it might help us?
I just feel like this AC doesn't produce a coherent document if you were to take out the sheets they said and replace them. Things are on different pages now, number bullets have become letter bullets, etc. It's a totally differently formatted document, and the changes aren't as earth shattering as I was hoping for.
Robodog, can you shed some light on this if you get a chance? I just figured I'd look into it with my limited knowledge and get my two cents, but I'm wondering if this AC was really anything special that we had been hoping for. At the very least, it means they're at least doing something to act on the emergency equipment stuff, but it almost seems like they're just covering themselves and saying it's on the air carrier and we approve nothing.
As I'm sure you're aware, usually they put a bold line or something along the edge of the page to indicate where exactly the changes were made. They show absolutely no changes on page 2 (and don't include page 2 in the subset that needs to be replaced), but unless I'm drunk, page 2 looks totally different between the original and Change 1. The whole thing seems to be reworded and reorganized in some way, so I feel like they might have screwed up this AC and should have replaced everything and put a line next to every change, which it doesn't appear that they did. I guess what I'm saying is the way they did it, replacing the pages they suggest to replace doesn't create a cohesive document (which you would think with all this time they would have gotten right!)
But let's take a look at the items that they did put a line next to, so we can highlight what exactly changed and how it suits Baltia (for better or worse). I'll use the Change 1 article for reference:
1st change: Looks like they removed the term "FAA-approved" from both "FAA-approved inspection program" and "FAA-approved continuous airworthiness maintenance program (CAMP)".
2nd change: "All functional testing of the EES should be performed in accordance with the manufacturer's instructions and as approved in the air carrier's manual." has been changed from "as approved" to "in accordance with".
3rd change: Again, they basically removed the words "FAA-approved" and "approved".
4th change: "Accidental deployment data may be used to support revised inspection or overhaul times." This has been modified to read, "Accidental deployment data may not be used as the sole source to support revised inspection or overhaul times."
5th change: I don't see a change. It talks about in increase of failures during deployments or functional testing will initiate a corresponding increase in the sampling rate on both of them. Not sure where the change is.
6th change: Removed the word "approved" again.
After that, they added a couple reference documents that I didn't bother to check into, including another AC, but that AC was completed back in 2011.
So while I'm glad they reissued something, I'm confused as to what they really reissued. What do we think they accomplished by eliminating "approved" everywhere? Also, what is the true meaning of the 4th change about accidental deployment, because that was clearly something that looks like it might help us?
I just feel like this AC doesn't produce a coherent document if you were to take out the sheets they said and replace them. Things are on different pages now, number bullets have become letter bullets, etc. It's a totally differently formatted document, and the changes aren't as earth shattering as I was hoping for.
Robodog, can you shed some light on this if you get a chance? I just figured I'd look into it with my limited knowledge and get my two cents, but I'm wondering if this AC was really anything special that we had been hoping for. At the very least, it means they're at least doing something to act on the emergency equipment stuff, but it almost seems like they're just covering themselves and saying it's on the air carrier and we approve nothing.
