LT, the Advisory Circular was around a long time a
Post# of 41413
So Baltia didn't write the AC as you're saying. It was already done back in 2003 (girt bars and all). What Baltia did do was expose the AC, saying "we did everything according to your FAA-approved plan". By taking those words out, they're basically passing the buck. The saving grace from the revision was when they reversed course on accidental deployment, saying that it can't be the SOLE reason for deeming it a failure. I just don't understand what accidental deployment really means.
The problem is really the lack of clarity in the regs and the AC as to who is ultimately responsible for a malfunction. I don't think the AC resolved anything personally. In fact, I think it makes the FAA look worse as it really just looks like a CYA for them.
BUT, and this is the most important but, what it does show is that all this time, at least we now know for certain that the FAA has been investigating the EES and its operations. So while it's pretty murky what the hell the FAA accomplished by making these slight revisions other than pass the buck, it shows that Baltia's tests got under the skin and that the FAA is not just blatantly ignoring everything, which was a concern a lot of us investors had. The FAA at least did SOMETHING, though I do think that something still didn't help anyone other than themselves. But it gives us some transparency that they're doing something at least with respect to emergency systems, so you have to think they're actively looking at this and not just letting it collect dust on their desks.