Rose Bridger’s Latest Paper Looks at Aviation Abuses in Indonesia


The imbalance of power between aviation and local residents is troubling. In the United States, we commonly see where the federal regulator, FAA, ‘collaborates’ with airport authorities, airlines, operators and other industry players to run roughshod over local communities. Aviation profits are always profusely accommodated, nearly always with substantial costs to people and the environment: natural habitat is destroyed, quality of life is diminished, and people are exposed to more air pollutants, including carcinogens.

Across the planet, some of the most egregious aviation injustices are happening where state authorities are enabling industry expansions against the will of local residents, sometimes even large population areas. When people in the U.S. rise up to fix aviation impacts, they rarely have to deal with lines of cops. They deal instead with a wall of unaccountable bureaucrats; people who make their money by supporting aviation expansion; people who routinely lie, distort, and even antagonize the much better people who are responsibly seeking to fix the aviation impacts; people who play ‘hot potato’, claiming they lack authority so “…gee, check with the other guy.”

Is it fair to say that, in either form, this amounts to state terrorism? If burdens are imposed and rights taken, be they by gun or billy club or categorical exclusion, does it really matter how graphically extortive the process is? Nobody may be killed or even injured (a good thing!), yet many bodies (and minds) incur great costs for the narrow benefits created. Farmland is taking and people are dislocated (see this example in rural Minnesota). All of this is enabled by federal agencies that pretend to enforce safety and manage aviation, but more truthfully just offers cover for industry players to abuse people. In the United States, in Indonesia, and across the planet.

How Do People Regain Power?

When dealing with unaccountable bureaucrats (especially those at FAA and various airport authorities), it’s always a good idea to learn as much as you can. Study what is happening elsewhere. See how others are making progress. Identify the framing that YOU need to impose on the issues; if we allow FAA/industry to frame the issues and implement faux-solutions like time-wasting workgroups, we only guarantee that the problems will persist, never to be resolved.

Rose Bridger, UK author of Plane Truth: Aviation’s Real Impact on People and the Environment, is one person whose works are well worth studying. Rose continues to be a prolific advocate for people and the environment. She has just published a new insightful study: Aviation expansion in Indonesia: Tourism, land struggles, economic zones and aerotropolis projects. Here is an archived copy:

Click on the image below for a scrollable view; the PDF file may be downloaded.


UPDATE, 6/14/2017: — per a GAAM email update: The report contains a map showing all the airport locations and maps of two airport sites, and accompanies GAAM’s interactive digital map: Aviation Expansion in Indonesia which features all the airports that are mentioned, integrating spatial information with text and images. For paper copies of the report, please contact: Third World Network, 131 Jalan Macalister, 10400 Penang, Malaysia, Tel: 60-4-2266728/2266159, Fax: 60-4-2264505, Email: twn@twnetwork.org.

FAA Forms Workgroups to solve their ‘People Problems’

FAA has a problem, and like any over-matured and sclerotic agency, they have their solutions. Not clean solutions that actually FIX THE PROBLEM, but dirty solutions to serve the agency/industry interests while disempowering people.

FAA’s failing NextGen implementations are destroying long-established residential communities across the nation. People are standing up, speaking louder and louder, and connecting and organizing. So, how does FAA propose to deal with this problem?

Form workgroups.

Just to be clear, the ‘problem’ FAA wants to ‘deal with’ is not the NextGen failures but the PEOPLE who are organizing. If their message gains traction, the People might actually get a few in Congress off their butts, demanding (and I mean REALLY DEMANDING!) that FAA fix this mess. The right steps are obvious:

  • demand Huerta step down (he has disserved the larger Public under two administrations, and is clearly just an industry hack);
  • revert the problematic NextGen implementations to pre-NextGen routes;
  • legislate a robust local democratic voice so that local citizens are able to decide what curfews and operational restrictions are needed to best serve their local community (i.e., the airport should be THEIR LOCAL AIRPORT, not a fortress for a major airline);
  • legislate reforms that disincentivize hubbing, so the airlines will instead offer more direct routes and a better/fairer distribution of airport impacts, equitably using hundreds and thousands of under-utilized airports instead of just a dozen evolving superHubs.

Why does FAA like to form workgroups? Simply because they are ‘manageable’. Each workgroup first creates an illusion of citizen involvement. But, the membership consistently includes industry ‘stakeholders’, who dutifully steer the work process – and infuse delays when the work product is going in the wrong direction. Plus, even the most ardent and effective aviation impact activists are human, thus susceptible to feeling a lot more accepting of the impacts because they are now an elite citizen representative.

Here’s an example of a new workgroup related to Baltimore [KBWI]. They appear to be very well focused on fixing the problems, but are running into an intransigent FAA. The Facebook group, Save Milton Skies, shared a link to this article, which is archived below. Rebuttal comments have been added by aiREFORM. It is a good article, overall, though it again demonstrates how FAA’s salespitch elements are readily incorporated into the final news article.

Click on the image below for a scrollable view; the PDF file may be downloaded.

See also:

Queens Quiet Skies: Latest Newsletter Offers Great Insight into FAA’s NextGen Failures

Janet McEneaney is President of Queens Quiet Skies, a group advocating for relief from aviation noise impacts related to both the LaGuardia [KLGA] and Kennedy [KJFK] airports. These are two of the three major airports that serve the NYC area. FAA’s full capitulation to the airlines, to expand flight schedules beyond what these airports can accommodate, has not only created terrible impacts that are destroying communities, but is also the root cause of nearly all delays in the U.S. ATC system. In other words, if FAA simply chose to apply rational capacity discipline on the NYC airports, system delays would be massively reduced.

Janet makes some excellent points in her latest update email to QQS members. A PDF copy has been created, with active links to the referenced materials. Hopefully this will help other aviation impact activists to learn about what FAA/industry are doing, why NextGen is failing, how workgroups tend to become coopted/steered by FAA/industry, and more.

Click on the image below for a scrollable view; the PDF file may be downloaded.

BTW, Janet has been a great activist on this issue, for years. Read more here.

Also, archived copies of the documents linked within the QQS update may be accessed via these links:

Santa Monica is Failing Their Promise to Shorten the Runway

A big event happens tomorrow night (May 24th), when the Santa Monica City Council holds a Special Session with major airport-related items. Here are some key links:

It has been four full months now, since the ‘surprise’ press announcement of a Consent Decree between FAA and the City. No progress has been made. FAA had approved, and the city promised, an immediate runway shortening, but now we are seeing the City dilly dally with lots of money to consultants to create reports that defy common sense while making unsupported claims that prolong the status quo impacts.

The City hired consultants to study options for shortening the runway to 3,500-ft, as allowed now by FAA. Documents indicate the consultant delivered a report with four options, but for whatever reason, the City stripped two of those options out and is proceeding to pretend only two options are viable. These two options alone were shared with the Public a few weeks ago (the existence of the other two options were only revealed in the last few days, after City posted documents related to the 5/24 agenda; see links above).

Frankly, it looks like City is playing a drawn-out delay game. It also looks like City is ignoring the health of the citizens of Santa Monica and nearby West LA neighborhoods. Even the City of Los Angeles should be pressing hard on this matter: to protect their citizens, they should be demanding that Santa Monica quit the dilly dallying and shorten the runway … NOW!!

The City owns the airport, and the City owns the runway itself. With that ownership, the City carries risks and liabilities. At this or any airport, if a runway is dangerous – too close to homes, or even too close to hangars as at Santa Monica, where people died in the last fiery airport crash – the airport authority needs to restrict operations for safety. If only to manage their risk exposure, all airport authorities should have the right to deny access of larger aircraft to substandard runways – especially commercial operations such as charter jets.

The biggest progressive step this year, as declared by the Consent Decree, is that FAA has finally backed down just a bit, and is letting the City manage the KSMO runway. City airport officials should use this restored authority to do as they say: immediately close the northeast portion of Runway 21, making it illegal for any aircraft to touch the asphalt.

Likewise, at the southwest end of the runway, City needs to take full advantage of the existing taxiways and simply close to operational use the roughly 450-feet of runway between the existing runway end and the first set of crossing taxiways (A1 & B1).

City could have done this in late January. That they have done nothing strongly suggests that City has a different and unspoken motive. The City, managed by Rick Cole, along with the airport office and under the guidance of the City Council, is not really trying to mitigate the severe impacts on hundreds of homes within the Runway Protection Zones (RPZs). The City is not honoring the clear request of the citizens who passed Measure LC with a wide margin, back in 2014 – a measure which demanded closure as soon as possible, and which also prohibited commercial use of any land reclaimed from aviation use in the future.

Also, notably, the most severe impacts at this airport are by small- to medium-sized charter jet and bizjet operations, often carrying just one wealthy person. These elites are inflicting an extraordinary negative impact on Santa Monica residents’ quality of life, simply because they will not be inconvenienced. They could instead fly out of much safer and less impactful airports such as LAX, Burbank, or Van Nuys, which like most U.S. airports, have no homes within their runway RPZs. They could do this, but they choose not to … and FAA and the City allow this injustice to continue.

Many have picked up on this story. No Jets Santa Monica Airport posted this great analysis on FaceBook:

Click on the image below for a scrollable view; the PDF file may be downloaded.

Similar concerns have been posted by Ben Wang, at SMO Future. There are a lot of good people around Santa Monica, like Martin Rubin, who have devoted multiple decades to restore local quality of life and protect health. These are good people, who have fought for a just resolution of the noise and air pollutant impacts. It looks as though FAA and a few of the current City leaders are just trying to wear them out. FAA’s intransigence, and the corruptibility of selected Santa Monica officials, has ensured no meaningful progress in all these decades.

These are but a few of the people at the forefront of the movement by the majority of Santa Monica residents, who simply want to control and close the airport .. and they need to control it for their health. They are vocal activists, but they are not the only residents who find this is a major issue. These vocal activists represents the opinions – and the votes – of probably 5,000 Santa Monicans each. This is why there have been surprisingly long public comment sessions at City Council meetings when an airport issue has come up. The citizens have a network that lets them know when to come out in force to voice their opinions. Every day, more and more citizens are learning exactly which City Council members are secretly pro-airport. A clear story has emerged. The people will vote-out the now exposed pro-airport insiders.

This all has to change. If this does not change, we really do not have any functioning Democracy.


UPDATE, 6/1/2017:Written Public Comments, submitted to the City (copy posted by CRAAP, 89p)

What Is FAA Hiding from the Public? And Why??

FAA, like many federal agencies, has a nasty habit of expending lots of time and money working to keep the people in the dark. They are supposed to comply with FOIA laws, but instead they redact the hell out of what should be disclosed. Making matters worse, in recent decades it seems as though most in Congress are ‘too busy’ and/or ‘too inert’ to force FAA to follow the FOIA laws.

Every once in a while, we get a great chance to look past these barriers. Sometimes, FAA’s redactions become unmasked. When that happens, it is like sitting down with the devil, and sharing tea and a candid conversation. So much can be learned….

In this Post, a 27-page FAA memo is offered in two forms, redacted and unredacted. This memo documents how a safety investigation produced copious details and a strong recommendation for corrective action … which was then nixed by a higher FAA official. The heavily redacted copy was provided to an investigative report team. Seeing that so much data was hidden, they filed an appeal. An appeal response letter was eventually sent, rejecting the appeal, but somehow a copy of the unredacted 27-page was included in the appeal response letter.

Here are the two versions, presented as scrollable/downloadable/searchable PDFs. View them side-by-side. See for yourself what FAA chose to redact, when a reporter team tried to help the public understand how FAA was handling a dangerous safety failure involving commercial aircraft maintenance.

Click on the image below for a scrollable view. This is the heavily unredacted version, as initially sent by FAA (and after extensive review by numerous FAA managers). Click here to download the PDF file.

Click on the image below for a scrollable view. This is the full, unredacted version. Click here to download the PDF file.

The Background:

A few days ago, an aiREFORM Post encouraged readers to read the excellent investigative series done by the Tampa Bay Times. In the third article of the series, Nathaniel Lash showed how higher level FAA managers were over-riding the conclusions and recommendations of their field inspectors. The inspectors were investigating how a nut had detached causing an elevator jam, forcing an Allegiant MD80 to do a high-speed aborted takeoff at Las Vegas. This was an extremely serious situation that would have assuredly killed everyone on board, if the nut had failed while actually airborne. A similar failure caused the 1/31/2000 crash of Alaska 261, an MD83 that lost flight control near Santa Barbara and plunged into the Pacific, killing all 88 on board.

The similarities are in two troubling areas:

  1. the casual failure by maintenance crews to properly execute their tasks and to follow needed steps that would identify and fix failures (so as to ensure nuts do not fall off leading to catastrophic crashes); and,
  2. FAA’s gross failure at safety oversight, where key FAA officials knowingly allow maintenance crews to sidestep required procedures.

The latest Times article showed that FAA was found to be covering up dangerous maintenance failures performed by AAR on the Allegiant passenger jet. Note that AAR is a Maintenance, Repair and Overhaul (MRO) operation; over the past decade, airlines have been reducing labor costs related to employing their own mechanics by increasingly outsourcing aircraft maintenance to MRO contractors. Costs may go down, but so do safety margins.

Scary on So Many Levels

(click on image to view USAToday article about the magazine cover)

New Yorker magazine is famous for its cover images, such as this one: Trump watching, in full-pout mode, while Sessions drags Comey off the plane. And, the citizens sit, obediently quiet, in their plastic seats, distracted by their devices and programmed toward suppressing and internally denying their outrage.

The same dynamics are at play in communities impacted by FAA’s fraudulent NextGen program, and by FAA’s enabling of impactful activities at places like Santa Monica and Longmont. More and more local residents are speaking up and organizing to protect their families, homes and neighborhoods. Yet, similarly, they run into so many neighbors who are afraid to share the outrage, who instead incline toward silence and distraction.

The architecture of our aviation system and our airplanes – the very geometry that defines how we sit on a commercial passenger flight – hints at how deeply corrupted our political system has become. A nation that for centuries has proudly pointed toward individual liberties and responsibilities, now sits mostly silent while money sets the houses on fire. We sit. Silently obedient, pretending a respect for authority that disrespects humanity.

Oh, and Happy Mothers’ Day to everyone! Let’s make our Moms proud and clean up this mess!!

An Outstanding Investigative Series on Allegiant Failures and FAA Hiding Those Safety Issues From the Public

If you are increasingly concerned that FAA appears to be just a hack, a faux-regulator that does not really serve the people but instead enables the industry … you need to read these articles.

If you have felt yourself doubting the veracity of an FAA high official, as they spew glowing pro-NextGen claims while dodging the enormous failures and impacts (like David Suomi, at the Port of Seattle on 4/25/2016; to see the video, click here, then select the April ‘video’ tab, and ‘Item 3c – Briefing’ under the 4/25 meeting) … well, you need to take a look at these articles.

This is where agency corruption goes beyond being an annoyance, to become downright dangerous.

When the Nut is Not Secured…

This photo was shot during an investigation after an Allegiant MD80 was forced to do a high speed aborted takeoff. The castellated nut at the center of the photo has a twisted safety wire, to prevent the nut from detaching. The near-accident was caused by failure to secure the nut, creating a jammed elevator.

Despite FAA and industry efforts to confuse us all, this is not rocket science.

Given the speed and power in aviation, it is absolutely critical that parts not ‘come apart’ while operating.

So, what happens when aircraft mechanics fail to include a cotter pin or safety wire, as in the photo at right? Well, in this example, a hundred or so aircraft occupants are damned lucky they did not end up dead in a post-impact fire in Las Vegas. What exactly happened? While accelerating for takeoff, the nose lifted up on its own and the crew suddenly discovered they had zero elevator control. They cut the power to bring the nose back down and, luckily, had enough runway remaining to come to a safe stop and taxi back to the gate.

…Safety Eventually Breaks Down

This particular incident has far bigger repercussions. It was one of many incidents that caught the attention of Nathaniel Lash and other reporters, who did an outstanding investigative series, published by the Tampa Bay Times. Here are links to archived PDF copies of the three articles:

The third piece just came out, and it includes an interesting twist. It appears that FOIA was used, and that FAA heavily redacted their response documents. A formal appeal was filed and, eventually, an appeal response letter was sent back by FAA, denying the request to reveal the redactions. BUT… a fully unredacted copy was enclosed with the appeal response! So, now we can see what FAA chose to initially redact (which itself can be extremely revealing).

Was the fully unredacted report enclosed by accident? Maybe, maybe not. Perhaps it was enclosed by someone who had seen too much. FAA employees are real people, often feeling trapped in a corrupt and soulless bureaucracy, and silenced by the fear of losing their paycheck. Sometimes real people become sick and tired of all the lying and propaganda, and feel it is their duty to bypass the corrupt intentions of higher FAA officials; sometimes they make little ‘mistakes’ with big consequences. Lucky for all of us, not all FAA employees are afraid of the agency’s ‘culture of fear’. Some really do blow the whistle, and sometimes they do this in very subtle ways.

Also, for those who really want to dive deep, check out the 27-page unredacted report.

Maryland Governor’s Great Letter Demands FAA Revert to Ease NextGen Impacts

This is a great letter. It precisely defines the NextGen problems, points out FAA’s casual indifference that only delays while sustaining these impacts, and all but demands that FAA revert to pre-NextGen procedures until the problems are corrected. The Governor and his Chief of Staff should be proud to post this, as it shows a proper focus, serving real people ahead of corporations.

(click on image to view source and video at Baltimore Sun)

The only thing that will improve this letter is the follow through. I.e., at some point, when FAA continues to fail, requests must become demands. Concern must morph into outrage. Not just in Maryland, but everywhere, and for every instance of FAA impacts upon local communities: from Boston to San Diego, and at places like Santa Monica and Longmont, too.

If our leaders continue their general aversion to showing outrage and demanding reform, we will only continue to slide deeper into the new realm: a corporatocracy that produces profits, narrowly enjoyed by an elite few, while growing negative impacts – the diminishment of health and loss of quality of life – are born by a wide swath of citizens.

Thank you, Governor Hogan, for recognizing this is unacceptable, and demanding FAA reform NextGen.

Earthen EMAS: How to Make the Most of the KSMO Consent Decree

What is going on in Santa Monica? Is the City honoring the will of the people who rejected massive campaigning by aviation lobbyists, and resoundingly approved Measure LC back in 2014? Or, is the City pulling a fast one on its people?

(click on image to view an aiREFORM Post about the accident and the lack of runway safety areas at KSMO)

Increasingly, it looks like the City is pretending to care about the lead, the particulates, the noise, and the obvious health impacts, yet is doing nothing to correct these problems.

Then, too, there is the problem of airport proximity to dense residential properties; airport neighbors have actually had lawn furniture blown over by the blast behind jets taking the runway; the smell of jet exhaust is a regular occurrence in backyards, where children play.

The fiery crash of an arriving bizjet back in 2013 killed four, but would have been far worse if that volume of jet fuel had ignited while crashing through the houses within the designated Runway Protection Zones (RPZs). Yep, although RPZs are supposed to be vacant land, hundreds of houses exist in the trapezoidal spaces at the ends of the Santa Monica runway; both FAA and the airport authority – the City – are going to be held accountable and found totally liable, if and when a crash happens in the RPZs.

The Consent Decree itself is suspect … no, doubly suspect. The City had a solid legal case, Nelson Hernandez had been insisting to noise activists that there were no discussions toward settlement, and yet City suddenly gave away all their advantage and caved to FAA pressures … AND Chamber of Commerce pressures, … and wealthy jet owner and wealthy airport users’ pressures. Twelve more years were added, with no guarantee of eventual airport closure. The only ‘gains’ received by the City were the right to shorten the runway, from 5,000-ft to 3,500-ft. The shortening was supposed to be immediate; rational people assumed it would take at least a few weeks or months to formally shorten the runway on paper, and add some surface markings. Instead, this process is being badly bungled, and is really calling to question, the integrity and intent of City Manager Rick Cole and key personnel such as Mr. Hernandez. Here are some examples of their bungling:

  • on 4/25, a meeting was held to share options for how to shorten the runway. The only options offered were to shorten it by clipping 750-ft off each end, or to shorten it by removing the bulk of the 1,500-ft from the west end. There was no option offered to remove 1,500-ft from the east end, which would best serve the most impacted airport neighbors (because the airport is nearly always in a west flow, the engine runups and idling by bizjets and charter jets nearly always happen on the east end; the jets often fly out IFR, thus have to wait until ATC can alter the LAX flow, to safely allow the SMO departures … so the jet idling can go on for a long time; also, the predominant winds push the concentrated pollutants to West LA, just east of the airport).
  • the meeting invitations went out only to the so-called ‘stakeholders’: pilots, airport operators & tenants, and other aviation folk. The local non-aviation community was not invited.
  • eventually, the local non-aviation community found out. Understandably, they felt slighted. Trust in Rick Cole and Nelson Hernandez has plummeted.
  • now, tonight, the Airport Commission meets, to consider the limited options, which reportedly carry an extraordinary $6 Million price tag, mostly just for adding paint to pavement!
  • It’s as if the goal is to so frustrate activists that they just give up (but they can’t: the stakes are too high, when you are fighting for health!).

So, that’s how bad it is. Now, if the City really cared to resolve decades-old airport problems, what would they have immediately embarked on after finalizing this Consent Decree?

  1. as a first step, declare the closure to become effective at the earliest allowable date. If any operators of the airport need more than 3,500-ft of runway, they would have a reasonable time window to depart, but after the closure date, that option would no longer exist.
  2. designate a runway portion for the initial closure. This does not have to be the final closure portion, but it does have to be designated. The surface markings have to be added, and the ATC procedures modified, to make it illegal for any flight to use this runway portion except in an emergency. Thankfully, the surface markings and modified ATC procedures are not a large or expensive task, and are easily completed.
  3. simultaneous with the above, define a full set of runway shortening options. The present set is woefully deficient. A full set would include at least three final runway positions, where the final runway portions to be closed would be all at the east end, all at the west end, or equally on both ends of the runway.
  4. a second set of ‘options’ – and equally important for addressing airport impacts – is what to do with the closed runway portions. Are they to be maintained, to enable longer takeoff or landing distances for larger bizjets, or are they to be declared unusable? So, this second set of options should consider removal of the asphalt versus painting the asphalt, and should also consider how the surface of the former runway sections are to be finished and maintained (grass, sand, or ??).
  5. if the goal is to maximize safety and minimize environmental impacts by bizjets and charter jets, the solution should be to discourage use of the airport by jets. Therefore, it would be a no-brainer to tear out the asphalt and create an earthen EMAS – perhaps sand, or perhaps just compacted soil seeded to grass, as is found at most airports. A small jet, aborting a takeoff or with a brake failure on arrival, would have its speed safely arrested in the overrun area; larger charter jets would simply avoid SMO, using longer runways in less impacted communities instead. LAX, for example, which has a brand new VIP terminal aimed at serving elite charter clients.
  6. for the record, FAA’s version of EMAS is very expensive. A specially formulated ‘crushable concrete’ is poured, and the cost to repair is also very high. Not just for actual accidents, but also when a pilot blunders and accidentally taxis onto it, as happened at Burbank with a private jet carrying baseball player Alex Rodriguez, in October 2006.

The Santa Monica Airport should have been closed decades ago; that it has not yet closed testifies not only to the power of the aviation lobby and the depth of FAA’s corruption in serving that lobby, but also to the lack of will (and intentional deception?) by City officials. From a distance, it is hard to watch this play out and not wonder, who’s getting paid off with what? Is Santa Monica just a wealthier version of the Bell, CA scandal?


UPDATE, 5/3/2017: — a petition for writ of mandate was filed by two citizens, seeking to have the Consent Decree declared null and void, on grounds that it was negotiated in violation of open records laws; see 98-page PDF copy here.

An Example of FAA’s Illegible Orders … Is There a Reason they are Mostly Incomprehensible Garbage?

The day after the Fight the Flight forum, one of the local impacted citizens shared her concerns about research she was doing, to learn about the problems. She provided a link to FAA’s 19-page Desk Reference for Noise and Noise-Compatible Land Use. Here is her comment:

People all across the nation run into this problem when trying to take care of their family and community. FAA creates a problem by enabling excessive airport expansion, and by forcing the abandonment of noise abatement procedures. When our best citizens then take their valuable time to learn and be heard, to fix the new problem,  they run into FAA’s next wall: the concealment of valuable information. Sometimes the concealment is simply by refusing to talk, as happened when David Suomi and Steve Karnes left ‘early’ after their 4/25/2017 NextGen presentation to the Port of Seattle Commissioners; other times it is by FAA’s wasting taxpayer money, creating voluminous and byzantine standards and illegible procedural documentation.

One of the roles aiREFORM tries to serve is to archive the documents that are relevant to aviation impacts. A new Reference webpage has been created, with archived copies of the Desk Reference as well as the full Current Order and full Previous Order. Click here to view it, and download any copies that may be helpful in your local fight for quality of life.

Also, a request: if anyone finds they are doing some deeper analysis of these documents, creating a thorough outline or notes just to REALLY know this material (or to precisely define FAA’s failures), please consider sharing your work back; we can make a PDF of that and share it online, too, to help others.