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The actual written feedback provided by Mr. Ewbank is far more useful than Bloomberg's summary: https://www.regulations.gov/document?D=FAA-2020-0686-0163 https:

The actual written feedback provided by Mr. Ewbank is far more useful than Bloomberg's summary: https://www.regulations.gov/document?D=FAA-2020-0686-0163 https://www.regulations.gov/document?D=FAA-2020-0686-0163 While I'm not a 737 expert, I have evaluated flight software (FSW) and vehicle management systems (VMS) on Gov't programs. Mr. Ewbank points out systemic deficiencies in the 737 VMS and controls. It would seem the question to be answered by the FAA is whether they intend to address these systemic deficiencies or just the proximate causes of the crashes. It would be a valid, and more rigorous view that since these aircraft are already out of service in an unprecedented way, these systemic issues should be addressed as well. To be clear, it will involve significant engineering work to do so. There will be immense pressure on the FAA, especially since the aircraft has been out of service and damaged Boeing economically so much already, to just deal with the proximate cause (i.e., stay the course they're on now). That will come from Boeing of course, but also internal management and their perceptions, as well the implicit or explicit pressure from the political class. Speaking purely for myself, I hope the FAA does force the root causes to be dealt with as Mr. Ewbank advocates (I don't know him, but have immense respect for his coming forward like this - you have to know and understand the systems to be able to provide this kind of critical review). However, I wouldn't at all be surprised if the fact they have already started down the path they're on causes them to retrench and leave these root causes unaddressed.

mattlondon 6y ago
From the doc: > The FAA allowed the regulations to be modified to fit the 737’s preexisting design Terrible. I wonder, if the FAA gives the 737 MAX the all clear, but no one else does, what does that mean for the aircraft? Would a US-only certification still be an effective grounding in all but name? I guess there are a bunch of routes within the US, but there must be crap-tons elsewhere too (and presumably international from US<->* that formerly used 737 MAX)?
- salawat 6y ago
  It'd certainly be a disaster for international airlines or operators, and I'm fairly certain an extremely powerful statement in terms of catalyzing domestic pushback. To be frank, if I worked at the FAA, I'd be kicking and screaming to resolve any level of concern raised by engineers in good faith before giving the go ahead. It may not necessarily appear as such, but the FAA, while having taken a credibility hit, has not taken one severe enough to unseat it as a leading international authority. If it goes ahead and gives the green light when the rest of the world isn't sold on it, then we can unambiguously say the entire regulatory institution is irredeemably defective. At that point the only real fix is an absolutely amazing change in the Executive branch, or a Legislative solution; and I have doubts on the efficacy of the latter, since a regulator is only as good as the people staffing it at the best of times.
  - zepearl 6y ago
    > To be frank, if I worked at the FAA, I'd be kicking and screaming to resolve any level of concern raised by engineers in good faith before giving the go ahead. I agree and I'd like to add that in my opinion the airplane now needs to actually be better than its competitors. If it isn't and there is another accident (big or small, that might or might not involve deaths but which might even slightly be related to MCAS or other systems having similar design flaws) then I think that there would be again another (bigger?) round of repercussions: for the plane itself, for Boeing and for the FAA. Saying this because I imagine that a negative event might become a final public and/or political confirmation that 1) the FAA & Boing cannot be trusted and that 2) the airplane has just too many flaws that need to be addressed. Therefore, to avoid this, the plane must be absolutely rock-solid otherwise if anything happens people will immediately ask Boeing and especially FAA "why did you create/approve this thing - are you incompetent and/or stupid and/or unscrupulous?". A very interesting topic, in my opinion :)
- alexithym 6y ago
  The 737 isn't really designed to fly longer international routes - it's mostly used for domestic short haul flights. However, the international market is absolutely gigantic, especially the Asian one, and not being able to fly 737s in countries other than the US would be a godsend for Airbus and a tremendous blow for Boeing.
  - raverbashing 6y ago
    The MAX reaches all the way to Brazil (non-stop) from the US and can open more flights Europe<>US/Canada as an example. It was a big selling point.
- martin8412 6y ago
  The FAA really dropped the ball on the 737 MAX, and as a result EASA won't blanket accept FAA certification as in the past.
  - ashtonkem 6y ago
    The irony being that the FAA bent over backwards to make it easier for Boeing to certify this aircraft, and they’ve probably done more damage to Boeing than anyone could’ve ever imagined. Turns out competent safety regulation matters, who knew?
- ashtonkem 6y ago
  A big part of the Max’s sales proposition was that it shared a type certification with the old 737. This meant that pilots would need minimal retraining, and could easily swap back and forth between the two easily. This requirement is why the MCAS software wasn’t properly documented; to avoid expensive retraining requirements that would be unattractive to buyers. Ignoring the training issue (which is already long gone), the inability to take the Max abroad would be a serious hindrance for sales. It means that it would require that airlines track them separately for routes, making sure to never take the Max 8 outside of America, which is exactly what Boeing was hoping not to do with the Max 8.
pdonis 6y ago
> It would seem the question to be answered by the FAA is whether they intend to address these systemic deficiencies or just the proximate causes of the crashes. There are really two separate questions: first, should the FAA address other deficiencies particular to the 737 MAX, and second, should the FAA go beyond that to require Boeing to fix issues that are common to all 737 models? I agree with Mr. Ewbank that the answer to the first question is yes; but he also argues that the answer to the second question should be yes, since the issues he points out in the latter part of the paper are not specific to the 737 MAX, as far as I can tell, but affect all 737 models. I don't agree that Boeing should be forced to address those issues, since that would amount to decertifying all 737s, which is not justified by the safety data; no other 737 model has an accident record that justifies any such decertification.
- mjevans 6y ago
  The key difference is the 737 MAX is a new airplane intended for many more decades of service. Presumably the older 737s will age out and already have well known behaviors that are not as troublesome due to a more forgiving pairing of engine size and airframe balance.
dheera 6y ago
> damaged Boeing economically so much already It bothers me that when lives are lost, our first response as a greedy capitalistic society is to cut funding, considering there aren't really many competitors, and the switch-over costs for airlines would be prohibitive. We should be funding efforts to investigate the heck out of this and make sure it doesn't happen again. I'm not sure how one would structure such funds to make sure they aren't abused, but I certainly don't want Boeing cutting more corners and hiring less-competent lower-salary aircraft engineers because they are now low on funding and need to get the plane out before some damn quarterly earnings report.
- scoopdewoop 6y ago
  If Boeing was socialized, that'd be one thing. Boeing paid $11.7 Billion dollars in stock buybacks in the two years preceding this fiasco. All the money they ever needed was already there. Instead, they spent the money inflating executives portfolios. And now you want more money going to them? If they want to privatize the gains, they can privatize the losses. Your sympathy is very misplaced, IMHO.
  - dheera 6y ago
    > And now you want more money going to them? No, I clearly said "I'm not sure how one would structure such funds to make sure they aren't abused". I want more money going to engineers, not the executives. But I do like to think with a forward-thinking mindset about how to make that possible instead of dismissing the problem and saying cutting funds in the right answer, because that definitely doesn't get more money in the hands of engineers to debug problems. Perhaps more money to engineers + a third party audit company appointed by the court + fire the executives that did wrong, I don't know, but I'd like to be optimistic about it. Taking away funds is only going to strip engineers even further of funds for fixes, make unsafer planes, that's for sure. The executives that inflated their portfolios while knowing there was going to be safety issues -- I support punishing those individuals. Not Boeing as a company though, since we pretty much depend on them.
  - rkagerer 6y ago
    Boeing paid $11.7 Billion dollars in stock buybacks in the two years preceding this fiasco I didn't know that. What kind of development budget did the Max have? If they'd taken 10% of that to do $1B more safety related engineering during the project, might that have helped?
linuxftw 6y ago
I read a good portion of the FAA's preliminary report that came out a couple months ago. They are completely incompetent. The report didn't include ANY data about rate of failure of AoA sensors, number of engagements of MCAS in the field, or number of flights where the plane was landed without MCAS enabled. It contained vague statements like 'rare set of circumstances' with ZERO data on the expected probability. As we know in the software world, a 1 in a billion chance could happen many times per interval given the scale of any particular problem. I'm never stepping foot on a MAX.
- bgorman 6y ago
  Yeah it is really sad, but Alaska Airlines and Southwest airlines may become untouchable for me in the future if they proceed to integrate the MAX back into their fleet. I will never fly on that plane
  - blackflame7000 6y ago
    The 737NG had 3 verified crashes and 4 additional suspected crashes due to a rudder issue before it was solved and you flew on that plane. https://en.wikipedia.org/wiki/Boeing_737_rudder_issues https://en.wikipedia.org/wiki/Boeing_737_rudder_issues
    - cs278 6y ago
      Per the article two crashes which were of 737-200/300 (i.e first and second gen) not 737NG.
      - blackflame7000 6y ago
        Does it matter? The 737 wasn't cancelled back then after 2 crashes. Point is that they solved the problem and the plane went on to fly successfully and the public forgot about it. They didn't second question the entire aircraft design over one fault like we are doing today.
        6y ago
blackflame7000 6y ago
The thing is, you are really punishing the airlines by doing this instead of Boeing. Boeing also produced the 787 and 777 and the same time they were working on the 737 MAX and those aircraft have superlative safety records. I think you leave the decision up to Boeing with the caveat being that if the plane crashes again due to a design flaw, it will never fly again which would be devastating to Boeing. If they are confident in moving forward with those stakes, then I would fly on it.
- shock 6y ago
  > I think you leave the decision up to Boeing with the caveat being that if the plane crashes again due to a design flaw, it will never fly again which would be devastating to Boeing. What is the downside for Boeing to just say "let's put the plane back in the sky"?
  - blackflame7000 6y ago
    The economic loss of losing by far their biggest money maker which most likely means bankruptcy.
    - Klinky 6y ago
      They already took that gamble and lost, twice. Would not be surprised to see them gamble with human lives again. Got to hit those quarterly sales figures. I think you scrap the plane, then start over with a wholly compliant design. This whole ordeal is a great example of regulatory capture. You have a plane with a ton of new flaws, and all the flaws of the old design, and business decided it was cheaper to pressure the regulator to be okay with these flaws and to kill a few hundred people than to build a proper plane, but let's give them one more chance to kill a few hundred more people, so they're not financially inconvenienced over a problem of their own making.
      - blackflame7000 6y ago
        There have been thousands of passenger jet crashes and on the broad scheme of things this plane is still extremely safe. The fact that it wasn't a redesign means it builds off all the lessons learned over the 30+ years the 737 has been in service. "Got to hit those quarterly sales figures." An aircraft that crashes is pretty detrimental to achieving this goal. Achieving sales figures doesn't preclude safety
VBprogrammer 6y ago
Some of these points seem really sensible and well thought out. For example being able to silence the stick shaker and overspeed warnings. However, some of them seem completely over the top. A complete review of the 737 control system for example, given its operating record across the fleet, would as likely result in introducing new failures as eliminate some as yet unknown failure mode.

mattlondon 6y ago

From the doc: > The FAA allowed the regulations to be modified to fit the 737’s preexisting design Terrible. I wonder, if the FAA gives the 737 MAX the all clear, but no one else does, what does that mean for the aircraft? Would a US-only certification still be an effective grounding in all but name? I guess there are a bunch of routes within the US, but there must be crap-tons elsewhere too (and presumably international from US<->* that formerly used 737 MAX)?

salawat 6y ago
It'd certainly be a disaster for international airlines or operators, and I'm fairly certain an extremely powerful statement in terms of catalyzing domestic pushback. To be frank, if I worked at the FAA, I'd be kicking and screaming to resolve any level of concern raised by engineers in good faith before giving the go ahead. It may not necessarily appear as such, but the FAA, while having taken a credibility hit, has not taken one severe enough to unseat it as a leading international authority. If it goes ahead and gives the green light when the rest of the world isn't sold on it, then we can unambiguously say the entire regulatory institution is irredeemably defective. At that point the only real fix is an absolutely amazing change in the Executive branch, or a Legislative solution; and I have doubts on the efficacy of the latter, since a regulator is only as good as the people staffing it at the best of times.
- zepearl 6y ago
  > To be frank, if I worked at the FAA, I'd be kicking and screaming to resolve any level of concern raised by engineers in good faith before giving the go ahead. I agree and I'd like to add that in my opinion the airplane now needs to actually be better than its competitors. If it isn't and there is another accident (big or small, that might or might not involve deaths but which might even slightly be related to MCAS or other systems having similar design flaws) then I think that there would be again another (bigger?) round of repercussions: for the plane itself, for Boeing and for the FAA. Saying this because I imagine that a negative event might become a final public and/or political confirmation that 1) the FAA & Boing cannot be trusted and that 2) the airplane has just too many flaws that need to be addressed. Therefore, to avoid this, the plane must be absolutely rock-solid otherwise if anything happens people will immediately ask Boeing and especially FAA "why did you create/approve this thing - are you incompetent and/or stupid and/or unscrupulous?". A very interesting topic, in my opinion :)
alexithym 6y ago
The 737 isn't really designed to fly longer international routes - it's mostly used for domestic short haul flights. However, the international market is absolutely gigantic, especially the Asian one, and not being able to fly 737s in countries other than the US would be a godsend for Airbus and a tremendous blow for Boeing.
- raverbashing 6y ago
  The MAX reaches all the way to Brazil (non-stop) from the US and can open more flights Europe<>US/Canada as an example. It was a big selling point.
martin8412 6y ago
The FAA really dropped the ball on the 737 MAX, and as a result EASA won't blanket accept FAA certification as in the past.
- ashtonkem 6y ago
  The irony being that the FAA bent over backwards to make it easier for Boeing to certify this aircraft, and they’ve probably done more damage to Boeing than anyone could’ve ever imagined. Turns out competent safety regulation matters, who knew?
ashtonkem 6y ago
A big part of the Max’s sales proposition was that it shared a type certification with the old 737. This meant that pilots would need minimal retraining, and could easily swap back and forth between the two easily. This requirement is why the MCAS software wasn’t properly documented; to avoid expensive retraining requirements that would be unattractive to buyers. Ignoring the training issue (which is already long gone), the inability to take the Max abroad would be a serious hindrance for sales. It means that it would require that airlines track them separately for routes, making sure to never take the Max 8 outside of America, which is exactly what Boeing was hoping not to do with the Max 8.

pdonis 6y ago

> It would seem the question to be answered by the FAA is whether they intend to address these systemic deficiencies or just the proximate causes of the crashes. There are really two separate questions: first, should the FAA address other deficiencies particular to the 737 MAX, and second, should the FAA go beyond that to require Boeing to fix issues that are common to all 737 models? I agree with Mr. Ewbank that the answer to the first question is yes; but he also argues that the answer to the second question should be yes, since the issues he points out in the latter part of the paper are not specific to the 737 MAX, as far as I can tell, but affect all 737 models. I don't agree that Boeing should be forced to address those issues, since that would amount to decertifying all 737s, which is not justified by the safety data; no other 737 model has an accident record that justifies any such decertification.

mjevans 6y ago
The key difference is the 737 MAX is a new airplane intended for many more decades of service. Presumably the older 737s will age out and already have well known behaviors that are not as troublesome due to a more forgiving pairing of engine size and airframe balance.

dheera 6y ago

> damaged Boeing economically so much already It bothers me that when lives are lost, our first response as a greedy capitalistic society is to cut funding, considering there aren't really many competitors, and the switch-over costs for airlines would be prohibitive. We should be funding efforts to investigate the heck out of this and make sure it doesn't happen again. I'm not sure how one would structure such funds to make sure they aren't abused, but I certainly don't want Boeing cutting more corners and hiring less-competent lower-salary aircraft engineers because they are now low on funding and need to get the plane out before some damn quarterly earnings report.

scoopdewoop 6y ago
If Boeing was socialized, that'd be one thing. Boeing paid $11.7 Billion dollars in stock buybacks in the two years preceding this fiasco. All the money they ever needed was already there. Instead, they spent the money inflating executives portfolios. And now you want more money going to them? If they want to privatize the gains, they can privatize the losses. Your sympathy is very misplaced, IMHO.
- dheera 6y ago
  > And now you want more money going to them? No, I clearly said "I'm not sure how one would structure such funds to make sure they aren't abused". I want more money going to engineers, not the executives. But I do like to think with a forward-thinking mindset about how to make that possible instead of dismissing the problem and saying cutting funds in the right answer, because that definitely doesn't get more money in the hands of engineers to debug problems. Perhaps more money to engineers + a third party audit company appointed by the court + fire the executives that did wrong, I don't know, but I'd like to be optimistic about it. Taking away funds is only going to strip engineers even further of funds for fixes, make unsafer planes, that's for sure. The executives that inflated their portfolios while knowing there was going to be safety issues -- I support punishing those individuals. Not Boeing as a company though, since we pretty much depend on them.
- rkagerer 6y ago
  Boeing paid $11.7 Billion dollars in stock buybacks in the two years preceding this fiasco I didn't know that. What kind of development budget did the Max have? If they'd taken 10% of that to do $1B more safety related engineering during the project, might that have helped?

linuxftw 6y ago

I read a good portion of the FAA's preliminary report that came out a couple months ago. They are completely incompetent. The report didn't include ANY data about rate of failure of AoA sensors, number of engagements of MCAS in the field, or number of flights where the plane was landed without MCAS enabled. It contained vague statements like 'rare set of circumstances' with ZERO data on the expected probability. As we know in the software world, a 1 in a billion chance could happen many times per interval given the scale of any particular problem. I'm never stepping foot on a MAX.

bgorman 6y ago
Yeah it is really sad, but Alaska Airlines and Southwest airlines may become untouchable for me in the future if they proceed to integrate the MAX back into their fleet. I will never fly on that plane
- blackflame7000 6y ago
  The 737NG had 3 verified crashes and 4 additional suspected crashes due to a rudder issue before it was solved and you flew on that plane. https://en.wikipedia.org/wiki/Boeing_737_rudder_issues https://en.wikipedia.org/wiki/Boeing_737_rudder_issues
  - cs278 6y ago
    Per the article two crashes which were of 737-200/300 (i.e first and second gen) not 737NG.
    - blackflame7000 6y ago
      Does it matter? The 737 wasn't cancelled back then after 2 crashes. Point is that they solved the problem and the plane went on to fly successfully and the public forgot about it. They didn't second question the entire aircraft design over one fault like we are doing today.
      - 6y ago

blackflame7000 6y ago

The thing is, you are really punishing the airlines by doing this instead of Boeing. Boeing also produced the 787 and 777 and the same time they were working on the 737 MAX and those aircraft have superlative safety records. I think you leave the decision up to Boeing with the caveat being that if the plane crashes again due to a design flaw, it will never fly again which would be devastating to Boeing. If they are confident in moving forward with those stakes, then I would fly on it.

shock 6y ago
> I think you leave the decision up to Boeing with the caveat being that if the plane crashes again due to a design flaw, it will never fly again which would be devastating to Boeing. What is the downside for Boeing to just say "let's put the plane back in the sky"?
- blackflame7000 6y ago
  The economic loss of losing by far their biggest money maker which most likely means bankruptcy.
  - Klinky 6y ago
    They already took that gamble and lost, twice. Would not be surprised to see them gamble with human lives again. Got to hit those quarterly sales figures. I think you scrap the plane, then start over with a wholly compliant design. This whole ordeal is a great example of regulatory capture. You have a plane with a ton of new flaws, and all the flaws of the old design, and business decided it was cheaper to pressure the regulator to be okay with these flaws and to kill a few hundred people than to build a proper plane, but let's give them one more chance to kill a few hundred more people, so they're not financially inconvenienced over a problem of their own making.
    - blackflame7000 6y ago
      There have been thousands of passenger jet crashes and on the broad scheme of things this plane is still extremely safe. The fact that it wasn't a redesign means it builds off all the lessons learned over the 30+ years the 737 has been in service. "Got to hit those quarterly sales figures." An aircraft that crashes is pretty detrimental to achieving this goal. Achieving sales figures doesn't preclude safety

VBprogrammer 6y ago

Some of these points seem really sensible and well thought out. For example being able to silence the stick shaker and overspeed warnings. However, some of them seem completely over the top. A complete review of the 737 control system for example, given its operating record across the fleet, would as likely result in introducing new failures as eliminate some as yet unknown failure mode.