“The FAA’s proposal simply does not make the 737 MAX a safe airplane. Even if the FAA privately does have data to support each of its assertions, the 737 MAX is not proven safe to fly and clearly would not be certified if it were a new aircraft,” explained Paul Hudson, President of FlyersRights.org and longtime member of the FAA Aviation Rulemaking Advisory Committee. “The 737 MAX debacle should motivate any concerned person to want independent experts to evaluate the 737 MAX fixes and technical details and for the FAA and Boeing to implement all of the Joint Authorities Technical Review (JATR) recommendations.”
Many other stakeholders submitted comments, including:
• Families of the victims of ET 302,
• Senator Blumenthal and Senator Markey,
• Robert Bogash, former Director of Quality Assurance at Boeing,
• Chris Ewbank, Boeing engineer
• The National Air Traffic Controllers Association (NATCA),
• Association of Flight Attendants (AFA-CWA)
• the British Airline Pilots Association (BALPA), and
• Dennis Coughlin, the author of “Crashing the 737 MAX” and 30 year veteran on FAA safety regulation
Many of the listed comments included criticism of FAA’s lack of transparency and supporting data, flaws in the 737 MAX’s aerodynamics, MCAS software problems, overall criticisms of FAA and Boeing’s safety culture and delegations of safety certification to Boeing, and needed revisions to flight crew manuals and training.
The FAA will review these comments and decide whether to revise its proposed Airworthiness Directive. Meanwhile, the House Transportation and Infrastructure Committee and Senate Commerce Committee have objected to the FAA’s and Boeing’s lack of transparency and lack of cooperation in turning over certain documents and information. FlyersRights.org is involved in Freedom of Information Act (FOIA) litigation against the FAA. To date, the FAA, at Boeing’s request, has redacted the documents that the federal court has ordered turned over, removing all technical details on grounds of trade secrets and confidentiality. FlyersRights.org has argued that the FAA needs to disclose the technical details of its proposed fixes so that independent experts can evaluate the proposed changes.
FlyersRights.org also submitted its white paper, “The Boeing 737 MAX Debacle”, for the record. The white paper details the flawed certification process and the resulting flawed MAX, and it proposes 10 recommendations for Congress, the FAA, and Boeing, none of which have been adopted.