I had a really good discussion with MikeSLTJ23 about the Advisory Circular that was shared by Baltia Airlines on Facebook. It was actually released by the FAA on their website sometimes after October 8th, 2015. He shared with me on the differences between the one that is released in 2003 and this year.
Per MikeSTLJ23’s statement:
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.
The FAA is nothing more than a policy maker and enforcer. They review all designs provided by the Airport authority for new constructions. They review all designs provided by the companies that develops an aircraft…they do all this in the name of the public safety. Any policy they make are compiled of studies in the aviation history to eliminate risk while flying in United States airspace.
I want to make it clear that Baltia never wrote the AC. They didn't even write the new one. But during the mini-evacuation demonstration, Balita did unravel a problem that plague the entire aviation industry on the emergency slides. On the 7th mini, they had all the paperwork in place, confirmation from supplier saying that it was inspected and certified by the supplier. Baltia PROTECTED themselves at the time of the test.
When FAA saw what was going on...they realize they shot themselves in the foot. It is because of the wording in the old AC. I'll explain the history behind this.
In 2000, NTSB did a comprehensive study on the emergency slides for Part 121 carriers. The study covered all make of the aircraft which that from the bottom of the doorway to the ground is greater than 48" requires an emergency slide. Anything below that does not require an emergency slide. So they looked at 2,750 incident that used the emergency slide in such event. Most of the events were engine fire. The purpose of that study was to make recommendations to FAA on improving evacuation from the aircraft using emergency slides in a safe manner. It was found that about 35 recommendations were made and 3 were to be eliminated the existing rules.
Then the FAA reviewed the recommendations, and in 2003, they created the advisory circular.
From 2003 to now, there has been some start-ups airliners that had to go through the new certification. The majority of them bought new planes, and once they come right off the assembly line, they are issued an airworthiness certification. So nobody really did the mini-evacuation except on an demo station that was designed for training.
But Baltia is unique because the 747 they bought used, had to go through a major overhaul to get up to today’s standards. Having that said, what was found was the workmanship of the slides came from the supplier, who the FAA approved. UTC Aerospace is a huge company. They are #3 in the aerospace industry. I used to work for #2...Spirit Aerosystems. The majority of airliners go to UTC Aerospace for replacement parts such as the slide.
What had happen was that when the AC was written in 2003, they were over confidence in the supplier they approved, and the products they used are on thousands of aircrafts. With this revelation that Baltia discovered, this means that all airliners are in violation of the AC. That is a huge embarrassment to FAA.
When the FAA took the recommendations from NTSB in 2000, and wrote that AC in 2003, they didn't really think this through.
So you asked what is my take? FAA is backing off the responsibility, and is telling the airliners..."We umm, can't quite regulate this yet, but as of now...you are responsible until we get our sh*t together and have a new AC out in the future."
SO what does this mean for Baltia? The fails that Baltia had in the previous mini are being reviewed again with the new revised AC in place, so that they can overlook some of the boo-boos, and get Baltia to move forward.
It is concerning, but I don't think FAA wants to make themselves look very badly by shutting down the entire airspace on this issue. So they realize they need to review the slides more carefully, and as for the time being, let the airliners keep flying....and they cannot hold Balta back. IT would be unfair for failing Balita when the other airliners are flying with questionable sildes.
It really looks good for Baltia now. It really does.
Per MikeSTLJ23’s statement:
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.
The FAA is nothing more than a policy maker and enforcer. They review all designs provided by the Airport authority for new constructions. They review all designs provided by the companies that develops an aircraft…they do all this in the name of the public safety. Any policy they make are compiled of studies in the aviation history to eliminate risk while flying in United States airspace.
I want to make it clear that Baltia never wrote the AC. They didn't even write the new one. But during the mini-evacuation demonstration, Balita did unravel a problem that plague the entire aviation industry on the emergency slides. On the 7th mini, they had all the paperwork in place, confirmation from supplier saying that it was inspected and certified by the supplier. Baltia PROTECTED themselves at the time of the test.
When FAA saw what was going on...they realize they shot themselves in the foot. It is because of the wording in the old AC. I'll explain the history behind this.
In 2000, NTSB did a comprehensive study on the emergency slides for Part 121 carriers. The study covered all make of the aircraft which that from the bottom of the doorway to the ground is greater than 48" requires an emergency slide. Anything below that does not require an emergency slide. So they looked at 2,750 incident that used the emergency slide in such event. Most of the events were engine fire. The purpose of that study was to make recommendations to FAA on improving evacuation from the aircraft using emergency slides in a safe manner. It was found that about 35 recommendations were made and 3 were to be eliminated the existing rules.
Then the FAA reviewed the recommendations, and in 2003, they created the advisory circular.
From 2003 to now, there has been some start-ups airliners that had to go through the new certification. The majority of them bought new planes, and once they come right off the assembly line, they are issued an airworthiness certification. So nobody really did the mini-evacuation except on an demo station that was designed for training.
But Baltia is unique because the 747 they bought used, had to go through a major overhaul to get up to today’s standards. Having that said, what was found was the workmanship of the slides came from the supplier, who the FAA approved. UTC Aerospace is a huge company. They are #3 in the aerospace industry. I used to work for #2...Spirit Aerosystems. The majority of airliners go to UTC Aerospace for replacement parts such as the slide.
What had happen was that when the AC was written in 2003, they were over confidence in the supplier they approved, and the products they used are on thousands of aircrafts. With this revelation that Baltia discovered, this means that all airliners are in violation of the AC. That is a huge embarrassment to FAA.
When the FAA took the recommendations from NTSB in 2000, and wrote that AC in 2003, they didn't really think this through.
So you asked what is my take? FAA is backing off the responsibility, and is telling the airliners..."We umm, can't quite regulate this yet, but as of now...you are responsible until we get our sh*t together and have a new AC out in the future."
SO what does this mean for Baltia? The fails that Baltia had in the previous mini are being reviewed again with the new revised AC in place, so that they can overlook some of the boo-boos, and get Baltia to move forward.
It is concerning, but I don't think FAA wants to make themselves look very badly by shutting down the entire airspace on this issue. So they realize they need to review the slides more carefully, and as for the time being, let the airliners keep flying....and they cannot hold Balta back. IT would be unfair for failing Balita when the other airliners are flying with questionable sildes.
It really looks good for Baltia now. It really does.
Baltia Air Lines Inc (BLTA) Stock Research Links
Let's make BLTA great again!!!
