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similar to that developed by American for its A300-600 pilots. This
airplane -specific training should go beyond NTSB Safety
Recommendation A-02-01 and focus on: (1) the unusually sensitive
rudder; (2) the yaw damper design; (3) the limited capability of the
RTLU to compensate for acceleration; and (4) the unique APC
susceptibility of the A300-600 and the A310. Training should
recognize that the piloting techniques used when flying other
transport category airplanes may not safely transfer when
transitioning from those airplane s to the A310/A300-600.
The NTSB should recommend that the FAA require manufacturers of
transport category airplanes either manufactured in or imported into
the United States to develop FAA-approved advanced maneuver
training programs, including specific documentation and guidance for
classroom and simulator training specific to each airplane.
21
D. OVERSIGHT
1. Bilateral Agreement
Bilateral Aviation Safety Agreements (BASAs) with Implementation Procedures for
Airworthiness (IPA) provide for airworthiness technical cooperation between the FAA
and partner international civil aviation authorities. France and the United States have
agreed to certification and acceptance of aircraft manufactured in either country under the
terms of BASA. The first such agreement, a Bilateral Aviation Agreement (BAA), was
reached in 1973 and was renewed as a BASA in May 1996. BASAs were initiated in part
to enhance cooperation and increase efficiency in matters relating to civil aviation safety.
One other advantage was to reduce the economic burden imposed on the aviation
industry and operators by redundant technical inspections, evaluations, and testing. These
agreements were not intended to diminish the level of safety for the industry. By
requiring equivalent safety measures, the BASA envisioned that aviation products
manufactured in either country would meet the standards of both countries.
Airplanes certificated by the FAA under BASA are required to meet U.S. airworthiness
standards. For transportation category aircraft, the specific standards are defined in 14
Code of Federal Regulations (CFR) Part 25. The BASA process cites several CFR parts
and ACs which define the equivalent requirements for both France’s Direction Générale
de Aviation Civile (DGAC) and the U.S.’s FAA. These CFRs and ACs are the guidance
that a non-U.S. manufacturer must comply with in order to receive a U.S. Type
Certificate for a specific airplane model. The data required by these CFRs and ACs
should be maintained for examination during the lifecycle of a specific airplane. To date,
following numerous requests, neither Airbus nor the DGAC have provided data relevant
to the type certification required for the major component change from the A300B2 to the
A300B4-605R. Specifically, that major component change was the shift from the VLA to
the VSA in the rudder control system.
FAA-AC 21-23A states:
“a. Following the type certification of an aircraft, it frequently becomes necessary to
revise data on the aircraft type design. Major changes to a type design not great enough
to require an application for a new TC, sought by the TC holder, may be issued as
amendments to the type certificate issued under 14 CFR 21.29, or otherwise approved by
the FAA. A certification procedure similar to that described in Chapter 2 is conducted
and adjusted for the magnitude and complexity of the design change. The FAA retains the
right to determine whether the proposed change is substantial enough to require a new
type certificate for the changed design.”
It is unknown whether Airbus did not identify the major change in the rudder system or if
the FAA determined that “one rudder control unit is like another.”
22
Airbus verbally stated the change from VLA to VSA was for weight, reliability, and
simplicity. This design is on all subsequent Airbus designs with one major difference:
limiting systems as a result of Fly-by-Wire (FBW) technology. Airbus also admitted that
their company does not use industry-recognized flight characteristics and handling
quality tests such as the Cooper-Harper Method or the FAA HQRM used in U.S.
certification. 4 Airbus has not produced any other test program data to justify their
selection of overly-sensitive control forces other than what their test pilots thought
appropriate.
Airplane manufacturers hold the proprietary engineering data that allows them to
determine the aerodynamic loads on aircraft experiences based on DFDR data. American
Airlines does not have access to this proprietary data. As such, Airbus had a moral
responsibility to inform the DGAC and the FAA that one of their aircraft experienced a
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