Comments submitted to the docket in response to the FAA’s
proposal for new icing certification regulations range from self-serving promotion of new inventions to carefully considered suggestions about how to improve icing safety after decades of study and hundreds of fatalities.
The comments submitted by former FAA engineer and icing expert John Dow are clearly focused on the safety issues raised by the FAA’s notice of proposed rulemaking (NPRM). Dow points out in his submission that even if the new rules make it through the agency’s cumbersome rulemaking process on schedule, the effects will not be realized until 25 years since the American Eagle Flight 4184 accident that precipitated the FAA’s action. The accident occurred near Roselawn, Ind., on Oct. 31, 1994, killing 68 passengers and crew in an ATR 72. “The time period for the aviation industry to propose this amendment that they must comply with and for the FAA to bring it to the NPRM stage has been 15 years, seven months, 28 days from the date of the accident,” Dow noted. “If [it is] codified and effective at the beginning of say, 2011, transport airplanes will have five years for a new design to be certified to this rule or 2016 before an airplane would enter service and several more years for a fleet to accrue significant exposure.”
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