Paul Cline

I believe the proposed rule will enhance the safety of the flying public and therefore should be adopted. That said, I would caution that the over-reliance on technology to solve what is essentially a training and decision making problem, may fail to obtain the stated goals of the new regulation. In the background section of the Notice of Proposed Rulemaking (NPRM), the authors describe a 2005 accident involving a commercial flight in known icing conditions. Following an extensive investigation, it was determined that the “flightcrew had not activated the airframe ice protection system during approach, as was required for those operating conditions by the Airplane Flight Manual (AFM).” As a result, the National Transportation Safety Board (NTSB) issued safety recommendation A-07-14, which suggested that “manufacturers and operators of pneumatic-deicing-boot-equipped airplanes be required to revise their AFM, operating manuals, and training programs [emphasis mine] to emphasize that leading-edge deicing boots should be activated as soon as the airplane enters icing conditions.” While there is little doubt that relevant technology has a place in reducing aircraft accidents, technology in and of itself is not a replacement for sound aeronautical decision making practices. With this in mind, I would encourage the FAA to follow the NTSB’s lead in combining additional and/or remedial training with the proposed technological changes to address this pressing problem.