[REFERENCE]: Leaded AvGas


REFERENCE Links re: Leaded AvGas

CRAAP recently shared three links to articles and other reference resources on the public health issue of lead, which FAA has failed to remove from aviation fuel (AvGas). Another group, Oregon Aviation Watch (OAW), has been actively working to end the addition of lead to AvGas. For readers wanting to learn more, here are a few links:

OAW Endorses Testimony in Support of Removing Lead from Aviation Fuel
Oregon Aviation Watch
Pediatrician Urges EPA to Lower the National Ambient Air Quality Standard for Lead
Oregon Aviation Watch
FEB 2015
Best Practices Guidebook for Preparing Lead Emission Inventories from Piston-Powered Aircraft with the Emission Inventory Analysis Tool
TRB Report 133, 47p
Oregon Public Broadcasting Report on Leaded Aviation Fuel and EPA Delay of Endangerment Finding
Oregon Aviation Watch
Three Articles on Leaded Aviation Fuel
Oregon Aviation Watch
OCT 2014
Quantifying Aircraft Lead Emissions at Airports
TRB Report ACRP-02-34, 218p
NOTE: if you are particularly concerned about the lead issue and interested in reviewing any of these documents, please consider drafting an analysis, outline or even an article to guest-post at aiREFORM.com. Technical consultation, advice, editing, and other support will gladly be provided by aiREFORM.

[IMPACT]: Loud in Laveen

Check out this short video, taken in a backyard southwest of the Phoenix Sky Harbor Airport. Watch and listen as back-to-back flights demonstrate the last six months of noise impact due to FAA’s NextGen implementation.When FAA turned on NextGen at Phoenix Sky Harbor [KPHX] last September 18th, community noise complaints went through the roof.20150323cpy.. KPHX Noise complaints AUG & OCT, 2014 vs 2013 Just two complaints in August rose to nearly 500 in October! Hardest hit was the historic residential communities along Grand Avenue, to the northwest of KPHX. But the noise increases were in all quadrants, because of three problematic elements within the design of FAA’s KPHX NextGen plan:

  1. FAA set up new departure procedures that mandate pilots turn at lower altitudes, much closer to the departure points.
  2. The very design of NextGen focuses routes sharply onto thin lines. Thus, traffic that was previously dispersed over many miles of slightly randomized routes is now focused over the same house, with repetitive noise events, minute after minute after minute.
  3. Tightening the turns (closer to the airport) creates compression. Because these departures are turned closer to the airport, flights under them (such as helicopters and small GA airplanes flying through) have less space to maneuver, thus tend to fly lower to the ground and closer to impacted residences.

So, Where is Laveen?

One of the impacted communities is Laveen, to the southwest of Sky Harbor. This is an area of farmlands transitioning to residential subdivisions. Under NextGen, when KPHX is in a west flow, departures toward Texas and Florida make a left turn at 1,640 feet altitude. Similarly, other departures generally east (most from New York to Atlanta, and even a few Chicago flights) usually make left turns. The problem  is, the KPHX airport elevation is 1,135 feet; thus, FAA is directing these departures to start their turns at just 500-feet above the surface (AGL). A 500-foot AGL turn is OK in many cases, but not when it points flights toward residential areas … as it does at Laveen.

Laveen Impact (FTHLS2, KATMN2 DEP FIXES)

VFR Sectional, with the three fixes and RNAV Departure legs added by aiReform.com. The fixes are DAVZZ, VANZZ, and BUNEE.

KATMN DEP showing first three fixes (Laveen, KPHX)Prior to September 18th, these departures would turn left to heading 240, then continue straight ahead until a 9-mile fix (aka 9-DME), THEN start another left turn. With FAA’s NextGen routes, flights are lower and further east (closer to KPHX), plus they start their second (southbound) turn earlier. The RNAV departures being touted by FAA are KATMN2 and FTHLS2, and both require pilots to remain at or below 8,000 feet MSL (mean sea level) until after BUNEE. As shown at right, both of these new departures are taking off, turning direct to DAVZZ, then direct to VANZZ, and then direct to BUNEE.

The change is clearly viewable in the diagram below. The letters PHX represent the airport. The red box marks the Laveen area. Blue lines represent the old departure patterns; green lines represent the new departure patterns, under FAA’s NextGen. Notice how the green routes are thin and concentrated, versus the dispersed pattern for older blue routes. Also, in the area southwest of PHX, notice how the old 240-headings to 9-DME push the departure pattern further west (and higher) versus the new NextGen routes. The new NextGen lines are green; the new NextGen program is anything but green.20141216.. KPHX Departure Route changes (p.12 of 21p RNAV_PolicyPresentation to PHX City Council)

And why did FAA implement these changes?

Well, it is this simple. FAA collects billions of dollars each year, mostly from airline passenger taxes. They want (need?) to spend these billions each year on airport expansions and technological upgrades, to support the industry. But, the overall airline system has been downsizing for more than a decade, with far fewer flights today than during the peak years of the late 1990’s. Plus, the airlines are understandably averse to spending, especially since most airlines already have (and have been using!) the basic satellite-nav technologies to gain more direct routes and better efficiencies. FAA still wants the airlines to buy more of what they do not need, so they resisted. The airlines said ‘NO’ to FAA’s early NextGen proposals. FAA had to get the airline support, so they traded away environmental impact, granting the airlines minor fuel (and cost) savings via earlier and lower departure turns. They whitewash NextGen with a flood of distorted propaganda, suggesting the technologies are new and efficient and safer. In reality, it is all just a bad and fraudulent sales job.

In the Phoenix area and in other impacted cities (Boston, Minneapolis, Seattle…), hundreds of thousands of airport neighbors will testify to the fact:

“Hey, FAA, these NextGen departures are failing!”


ANALYSIS: The ‘Mogas’ Study at KHIO, by KB Environmental Sciences

This Post offers an analysis of a 59-page study funded by the Port of Portland, to investigate the potential and feasibility to sell unleaded aviation fuel at the Hillsboro Airport [KHIO]. It includes some background on the leaded fuel issue, followed by a look at (and critique of) the KB ‘Mogas’ Study.


The Clean Air Act was passed in 1970, and included guidance for the removal of toxic lead from transportation fuels. It took more than two decades for EPA to completely phase out lead in automotive fuel, as was accomplished in 1996. But, although there are far fewer aircraft and fueling locations (and thus the change for aviation should have been faster and easier to accomplish), it has now been 45-years, yet lead remains in the most commonly used General Aviation (GA) fuel: 100LL, commonly called Avgas.

Many aircraft have been modified to safely use unleaded fuel, commonly called Mogas. The problem, though, is that while mogas is widely available from wholesalers, very few airports have invested in the above-ground storage tanks and/or fuel trucks needed to offer this less hazardous fuel choice. Thus, even busy GA airports do not offer mogas. Such is the case today at the Hillsboro Airport [KHIO], west of Portland, OR.

20150204scp.. PoP Aternatives to Lead in Aviation Fuel [KHIO]For the past few years, lead has been a focused issue at the Hillsboro Airport. The airport is owned/operated by the Port of Portland (PoP). It is common throughout the U.S. for airport authorities to appoint citizen groups, which ostensibly assures the community is involved in airport impact decisions. In reality, though, PoP and other airport authorities tend to stack the membership of these groups so as to assure they vote favorably for the airport uses (and against the airport neighbors). At Hillsboro, PoP created the Hillsboro Airport Roundtable Exchange (HARE). Many airport neighbors feel that HARE is strongly aligned with the aviation interests at KHIO, particularly Hillsboro Aviation.

The KB ‘Mogas’ Study’s Summary:

At some point in the recent past, the Port of Portland hired a consultant to prepare a study related to the KHIO avgas/mogas issue. They hired KB Environmental Sciences, based in Tampa Bay, FL (and with offices in Washington, DC and Seattle) to do a study. KB is one of a handful of companies who make lots of money doing studies that are use by the aviation status quo to sustain practices and delay change. KB’s 59-page report was completed last December, and just recently made public. Here is the bullet list from the Executive Summary page:

…to read the study summary and the aiREFORM analysis,
please see page two of this Post…

Lies, Damned Lies, & FAA Overselling of NextGen: Houston Metroplex

It’s not a secret among pilots, mechanics and most FAA employees: when an FAA official says ‘A’, you will do well to think ‘B’. Not just when FAA dodges revealing details of the latest birdstrike or controller error, or when they deny trashing a safety Whistleblower, but also when FAA is in their frequent PR/spin mode. Like when they are trying to sell the Public and Congress to (PickOne: waste/spend/invest) billions on programs like NextGen and Metroplexes.

NextGen is the collection of ‘new’ satellite-based technologies (though ‘new’ is inaccurate, because most of these technologies have been in use for decades). Metroplexes are the application of these technologies to alter flight paths and airspace design near the nation’s busiest commercial airports. In the big picture, FAA is seeking to award $Billions$ in contracts to firms and contractors within the aviation-industrial complex, which also happens to employ many retired FAA officials. And, as has almost always happened in FAA’s 55-year existence, the agency is over budget and behind deadlines in their latest ‘upgrade’ scheme. So, they bring in the spin squad.

20140618.. KIAH NextGen MetroPlex celebration speech pic, Huerta (Foxx, Rinaldi, et al)

June 18, 2014

A June article at Wired.com helped push along FAA’s spin. The article happened because, on June 18, 2014, a PR event was staged, ‘celebrating’ the Houston Metroplex. FAA Adminstrator Huerta, DoT Secretary Foxx, and NATCA President Rinaldi all flew down to Houston, to join airline and airport officials for a staged presentation with set speeches. This was all tightly managed and coordinated, too; for this PR event, there was an FAA Press Release and a DoT Press Release, plus a set of videos uploaded to YouTube (here is one: a 2-minute explanation of airspace design changes, with an upbeat musical jingle):

What was FAA Selling?

The two key improvements proposed for the Houston Metroplex had to do with arriving aircraft. The sales pitch claimed that arriving flights would fly shorter routes; in fact, the diagram below (from a 7/22/2013 article) shows a proposed NextGen arrival (green arrow) angling in over Interstate-69 to a short final approach. This was shown to improve upon a conventional long downwind to a 35-mile final (red box pattern).20130722.. screencap from GCN article on NextGen, KIAH graphic by FAA (pic only, no text)Here is a closer look. Conventional downwinds have typically been turned onto a base leg as far east as Dayton (around 30-miles out). A more efficient base turn over Lake Houston (around 13-miles out) can happen, if traffic allows. But, the problem is that United-Continental, the major airline at KIAH, schedules their flights (and small feeders) in surges. This forces ATC to use the long downwind legs as a tool for spacing and sequencing. No NextGen technology can fix this traffic saturation problem. Nonetheless, that does not stop FAA from promoting NextGen spending.

20141003.. KIAH west flow satellite view (east to Dayton)

A longer view: From Dayton to the Airport.

20141003.. KIAH west flow satellite view (east to Lake Houston)

A closer view: From Lake Houston to the airport.

The sales pitch also claimed the descents would reduce fuel burns by using steeper approaches, without ‘level-offs’. The ‘before’ (in orange) shows many level sections, while the ‘after’ (in green) shows steady and steeper descents from 100 miles out.20130619.. KIAH before-after descent profiles, from DoT-news release

FAA produced sharp graphics (and even videos), and they claimed that we will see some significant changes, which would substantially reduce overall fuel burn. Both changes were fine goals, but a goal is not worth much if little progress is made toward achieving it. And, so far, at Houston, there have been no substantial changes in the arrival patterns for the biggest airport, KIAH.

In Reality, the ‘Improvements’ Did Not Happen

FAA spearheaded the celebration and many attended. Were they celebrating a change and delivering improvements, or were they just cheerleading and deceiving the Public with yet one more fabricated sales pitch?

The proof is available online. All you have to do is use the available websites like Flightaware.com or FlightRadar24.com and look at real arrivals (and arrival descent profiles) for real flights, even those landing right now. Just go to either site and select any flight, randomly. Chances are, when you open the views showing the flight route and descent profile, you will see conventional long finals with on average two- or three- level-offs. No changes.

Here is example one, from June 28th, an American Airlines MD82 inbound from KDFW. The base turn is near Dayton, and the final leg is more than 25-miles long. As a matter of practice, the controller normally directs a downwind flight to maintain a set altitude, typically 3,000- or 4,000-feet; in the screen-cap below, this MD82 is at 2,900-feet. Months later, on October 2nd, this same flight was turned to a final at more than twenty miles out, after two level-offs, at 7,000′ and 5,000′ altitude.20140628.. AAL2435 KDFW to KIAH, map showing long base turn
And here is another example, the October 2nd arrival of United Flight #1555, a Boeing 737 from Phoenix [KPHX]. In this case, a long downwind leg is flown, and the turn to final is east of Lake Houston, at nearly 20-miles out. Note the two level-offs, at 6,000′ and 4,000′ altitudes.20141003.. KIAH map view for UAL1555, B738 from KPHX20141003.. KIAH descent profile for UAL1555, B738 from KPHX

How to Study the KIAH Arrivals

Air traffic controllers are averse to work; they are normal people that way. So, they will set up direct routes and minimize the number of level-offs as much as they can. At a large airport like KIAH, if the majority of arrivals are inbound from the east, ATC will tend to bring the arrivals straight-in, landing to the west. So, if there is steady arrival traffic from the east, arrivals from the west will have to be sequenced into the downwind. However, during slow periods, such as in the early morning hours, ATC may use timing to bring in arrivals from both directions (east and west) and land them at opposite ends of the same runway. Always, the objective for ATC is to minimize time spent working each flight, while applying set rules to ensure the flights remain properly separated. This strategy for working air traffic pre-dates the sales pitch by FAA last June; there was no significant change after FAA officials gave that sales pitch.

You can study these arrivals yourself. Here’s how:

  1. select KIAH as your airport at Flightaware.com (here is a link).
  2. Study the list of arrivals by selecting the ‘More’ link. Look for arrivals that are against the flow; for example, from the west when most arrivals are from the east.
  3. Select one of those flights and a list appears for the same flight number, with links to weeks worth of previous flights. Click on any of these links and look for downwind arrivals.
  4. Click on link in the data box, under ‘Status’, where it says ‘Track Info & Graph'; this produces the vertical profile, as well as flight parameters, from which you can quickly identify level-off altitudes.

FAA’s Culture of Unaccountability: The PIX11 Investigative Series, by Mario Diaz

20140730.. Still No Answers, Whitaker (PIX11 Investigates, by Mario Diaz)One of the few journalists today pressing FAA with hard questions is Mario Diaz, at Pix11 TV in the New York market. Mr. Diaz has been investigating a pattern within FAA where air traffic controllers found partially responsible for fatal accidents are put right back to work and are not held accountable.

The fifth in a series of investigative reports aired in the New York market on July 30th. It includes an interview of FAA’s Deputy Administrator, Michael Whitaker, after he had spoken at a U.S. Senate Subcommittee on Aviation hearing.

Click here for links to the other investigative reports in this series.

[ARCHIVE] 2014-07-27: Buffalo News Op/Ed About FAA’s Regulatory Capture

And, again, the Federal Aviation Administration looks to be trying to weaken the new flight safety rules enacted by Congress in the aftermath of the deadly 2009 crash in Clarence Center. It’s becoming routine, and the FAA is beginning to show what appear to be its true colors – more concerned with satisfying the airline industry than it is in ensuring air safety.

Let’s be clear: Fifty people died here because of poor pilot training. Flight Capt. Marvin D. Renslow took the exact opposite action the situation required when Continental Connection Flight 3407 stalled due to dangerously slow air speed. That’s why the Families of Flight 3407 campaigned and, with the muscular help of Sen. Charles E. Schumer, D-N.Y., fought for legislation increasing training requirements for new pilots.

The law was passed and virtually since that day, the airlines, the FAA and even some in Congress have sought to subvert it. Schumer has helped to fight back against those efforts and we presume he will monitor this latest maneuver to ensure that the law is fully implemented.

Industry leaders are shedding crocodile tears about a lack of pilots because of the new training requirements. Basically, they want to continue, as much as possible, operating in the same way: underpaying and overworking pilots whose training doesn’t cost too much. It’s a cynical game whose consequence played out in Clarence Center five years ago.

This issue cries out not just for our congressional delegation and the Families of Flight 3407 to stand firm on this issue, but for Congress to evaluate the function and performance of the FAA. If it has been so badly infiltrated by the airline industry that it cannot reliably implement safety laws passed by Congress and supported by Americans, then perhaps its mission and organizational structure – including its lines of accountability – need to be re-evaluated.

The crash of Flight 3407 was a watershed moment. Too many Americans are being flown on regional carriers, profiting the large airlines at the expense of passengers whose safety has been placed in the hands of inadequately trained, poorly compensated cockpit crews.

That changed with the ensuing legislation. It needs to stay changed.

This content is a copy of a BuffaloNews.com Op/Ed, copied from: http://www.buffalonews.com/opinion/buffalo-news-editorials/stand-firm-on-air-safety-foolhardy-faa-again-seems-willing-to-weaken-vital-pilot-training-rules-20140727.
Minor text modifications (and annotations) may have been made by aiREFORM.com.


Oregon Aviation Watch discusses Hillsboro Airport Lead Impact

On Friday June 6, 2014, a workshop was held at PCC, on the link between air quality and risks to public health. The forum was sponsored by two Oregon legislators: Rep. Mitch Greenlick (Chair of the House Health Care Committee), and Senator Mike Dembrow (Chair of the Senate Environment and Natural Resources Committee).

The forum focused on two air quality problems:

  1. Aviation lead emissions at Hillsboro Airport, and
  2. Industrial emissions of hydrogen fluoride and other hazardous gasses.

Hillsboro Aviation has been recruiting student pilots from China and elsewhere; they then provide flight training (mostly helicopters) and burn leaded aviation fuel while intensively flying around airport practice areas. Miki Barnes and Dr. Jim Lubischer of Oregon Aviation Watch (OAW) offered a presentation about the lead impact at Hillsboro Airport. The Port of Portland is currently working to start construction of a new parallel runway at Hillsboro, using FAA funds. Hillsboro is an unusual airport, in that the majority of its traffic is for the flight training of imported students. OAW’s position is that the Port and FAA are effectively subsidizing this flight training at the expense of local community health. And, the principle beneficiary is the one business with the large fleet of training helicopters: Hillsboro Aviation.

Intel and other semiconductor manufacturers use a variety of gasses in their industrial processes. Some of these are released into the atmosphere in a controlled process, and occasionally they escape uncontrolled. There has been a long history of failures to disclose details of hazardous gas emissions.

For both air quality issues, the emissions problem is greatly magnified by the attitudes of the key parties (the sources, as well the regulators). Intel, FAA, the Port, and others continue to fail to ensure full transparency to the Public.

Luke Hammill covered the event with a news-blog at OregonLive.com, which generated the usual polarized comments.
20140606.. OAW forum presentation, PB, KHIO, OregonLive

FAA’s Priorities: Are Drones More Important than People?

Easter Sunday this year produced two aviation news stories in the Rocky Mountains: one was the use of a tiny drone-camera, the other was a paraglider fatality.

In Denver, two young men were flying a drone over the pro-cannabis 420 Rally, where a crowd of 80,000 people (and a cloud of smoke) was expected. The drone pilots set up atop the Civic Center roof, to remotely control their low-altitude flight. Per FAA’s regulations, the nearest real aircraft would be far higher than the nearby skyscrapers, much more than a thousand feet above the tiny drone. Nobody was hurt, but news photos show at least seven police arrived and stood around on the Civic Center roof. No tickets were issued, and the two men complied with a request to shut down and leave. The police also filed no incident report.

Meanwhile, at essentially the same time, a 31-yr-old male (who was a contestant on the TV show ‘Bachelorette’) launched his paraglider in the hills south of Salt Lake City. Witnesses saw the chute collapse while he was 10-15 feet above the ground. He was then slammed into the ground, rendered unconscious, and hospitalized. He died three days later. [article]

Which one did FAA get excited about?

The drone, of course.

Two days after the rally, FAA announced they were investigating the drone incident. FAA spokesperson Allen Kenitzer had this to say about the Denver drone story: “Anyone who wants to fly an aircraft — manned or unmanned — in U.S. airspace needs some level of authorization from the FAA.”

FAA ignored the paragliding accident, despite the fact that it was manned and produced a fatality. Contrary to Mr. Kenitzer’s statement, after decades of similar accidents, FAA still does not require any ‘level of authorization’ for a person to be killed in a paragliding accident.

We Need more ‘Accountability Journalism’ …

…and less of the prevailing ‘Access Journalism’.

An article by Robert Jensen analyzes a book written about how our journalists failed to cover the financial crisis. Mr. Jensen is a professor at the School of Journalism, University of Texas at Austin. He covered the book The Watchdog That Didn’t Bark, as written by Dean Starkman, a former Wall Street Journal reporter and current editor at the Columbia Journalism Review.

There is a lot to think about in this piece, and much of it overlaps with how (and why) FAA continues to fail. Here’s an excerpt, with a few minor changes (highlights, color) by aiREFORM…

…the core mission of journalism is built around the Great Story “that holds power to account and explains complex problems to a mass audience, connects one segment of society to another.” This kind of journalism, he (Starkman) writes, “is also the one reliable, indispensable barometer for the health of the news, the great bullshit detector.”

Holding power to account and detecting bullshit are certainly admirable goals, and Starkman correctly points out that journalists who practice what he calls “access journalism” are unlikely to achieve them. Access journalists, as the label suggests, play the insider game and cultivate access to powerful sources. At best, access journalism can give ordinary people a glimpse of what happens behind closed doors, but on terms set by those who close the doors.

Starkman makes the case for the necessity of “accountability journalism” in the muckraking mode that is confrontational and accusatory, and that “provokes the enmity of the rich and powerful as a matter of course.” The access and accountability schools, he writes, “represent radically [emphasis added] different understandings of what journalism is [emphasis in the text] and whom it should serve.”

The book’s thesis, simply put, is that the news media’s poor performance during the financial crisis can be explained by the prominence of Access Journalism and the lack of hard-hitting Accountability Journalism. Here’s Starkman’s summary of these two styles:

Access Reporting tends to talk to elites. Accountability Reporting tends to talk to dissidents.
Access writes about specialized topics for a niche audience. Accountability writes about general topics for a mass audience.
Access tends to transmit
orthodox views.
Accountability tends to transmit heterodox views.
Access reporting is functional. Accountability Reporting is moralistic.
In business news, Access Reporting focuses on investor interests. In business news, Accountability Reporting focuses on the public interest.

Aviation vs. Railroads: Why is FAA so much slower than FRA to address personal electronics distractions?

Last week, FAA posted in the Federal Register their Final Rule, Prohibition on Personal Use of Electronic Devices on the Flight Deck. Essentially, the new rule declares the obvious … that texting (or computer games or sharing pictures of your cute kids or porn files or whatever) is dangerous, distracting, and must cease immediately …or at least once the rule goes into effect on 4/14/14.

A discussion then developed at FlightAware.com. While most of the discussion participants were pilots and all had a keen interest in aviation, some of the participants were U.S. railroad professionals. They made a very interesting point: specifically, that very similar accident histories have produced very different outcomes by the Federal Railroad Administration (FRA) vs. the Federal Aviation Administration (FAA).

In short, here is the comparison:

Rescue workers in front of the Metrolink locomotive lying on its side after penetrating the lead passenger car (left). (photo from Wiki)

FRA: On 9/12/08, a head-on collision at Chatsworth, CA killed 25, injured 135, and caused $7.1 Million in damages. The NTSB investigation revealed the locomotive engineer was texting and missed a safety signal. Twenty months later, on 5/18/10, FRA issued an NPRM rule proposal via the Federal Register. Fifteen comments were received. The Final Rule was posted to the Federal Register on 9/27/10, and went into effect on 3/27/11.

Thus, for an FRA rail safety failure related to a major accident, it took thirty months from accident to effective rule change.

FAA: On 8/27/06, Comair Flight 5191 took off from the wrong runway at Lexington, KY, then crashed, killing 49. The tower controller had failed to specify the runway and the pilots, evidently fatigued from a short night’s sleep, failed to notice they were on the wrong runway. The controller had nearly a full minute to look out the window and see the problem and ‘save’ the situation with a timely radio transmission. The tower controller failed and the accident happened. Seventy-seven months later (!!), on 1/15/13, FAA issued an NPRM rule proposal via the Federal Register. Sixty-three comments were received. The Final Rule was posted to the Federal Register on 2/12/14, and will go into effect on 4/14/14.

Thus, for an FAA aviation safety failure related to a major accident, it took ninety-two months from accident to effective rule change. Ninety-two months; yes, nearly eight years!

So, in summary, a railroad safety rule by FRA takes 30-months, while an essentially identical aviation safety rule by FAA takes 92-months.

Why does it take FAA so much longer to pass the new safety rules? Most likely, the delay is directly related to FAA (and industry) efforts to protect their financial bottom line: mistakes happen, people die, and those who might have saved the tragedy feel compelled to obscure their culpability, to protect their own interests. So, they maneuver to maximize distance from any risk/liability exposure. In other words, a conscious effort is made by aviation professionals — including some very highly paid FAA officials — to guarantee no accountability for system failures.