ANM7 

FACSIMILE MESSAGE 

Kyle E. Lomazow 

FED.ERAL AVIATION ADMINISTRATION 

OFFICE OF REGIONAL COUNSEL 

ANM-7 

1601 LIND AVENUE S.W. 

RENTON, WASaJNGTON 98057 

PAGE 01/12 

The infom1ation contained in this facsimile message .is legally privileged and confidential 

information and is intended only :for the use of the individual named on this cover sheet. 

If the reader o:fthis message is not the intended recipient, you are hereby notified that any 

use, dissemination, distribution, or copy of this facsimile is strictly prohibited. If yo~l 

have received this facsimile in error, please immediately notify us by telephone at 

425-227-2007. 

DATE: 

TO: 

FAX NO.: 

PHONE NO.: 

RE: 

March 14, 2013 

Federal Aviation 

Administration 

202-493-5142 

SKYWEST AIRLlNES 

DMS No. FAA-2011-0782 

FAA 2010NM060081 

Complainant's Reply Brief 

NO. 

PAGES: 

FROM: 

FAX NO.: 

PHONE 

NO.: 

EMAIL: 

12 including cover 

Kyle E. Lomazow. 

425-227-1007 

425-227-1847 

Kyle.lomazow@faa.gov 
03/14/2013 08:15 4252271007 ANM7 

1 Kyle E. Lomazow 

2 FAA Office of Regional Counsel 

3 1601 Li.nd Ave., SW 

• Renton, Washington 98057 

s Telephone: (425) 227-1847 

e Facsimile: (425) 227-1007 

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UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATlON 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

16 In the Matter of 

17 DMS NO. FAA-20ll-0782 

1s SKYWEST AIRLINES, INC. FAA Case No. 2010NM060081 

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COMPLAINANT'S REPLY BRIEF 

INTRODUCl'lON 

Sky West Airlines has attempted to mislead the court with false, mislcadi.ng and 

contradictory statements. They have also attempted to impugn the Federal .Aviation 

Administration's (FAA) reporting inspector, insinuating that he alone perceived a violation, 

and then acted unilaterally in proccssi.ng the enforcement action. 

What led to this enforcement action i.s SkyWest's attempt to find a creative way to 

clear a system/component fault indication without employing the time consuming, 

troubleshooting processes outlined by Bombardier and incorporated into the Sky West 

45 maintenance program. Each flight conducted under such practices is an experiment of sorts, 

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4 7 with unsuspecting passengers on board the subject aircraft. 

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COMPLAWlVJT' S REPLY Hl?J\.RING P..RT~l? 

fiT~Y"Wi!.ST .AIP.LINl\.0::- lff.lMS WO Fi\i\-20:i,l-075!2 

FAA CnsE No. 2010NM060081 

Page J. of ll TEL: (4~5)227-1847i FAX1 (425)227-1007 

PAGE 02/12 
03/14/2013 08:15 4252271007 AN~17 

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The facts in this case are relatively straightforward: 

6 L A fully qualified and competent pilot, trained under the Sky West Airlines pilot 

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training program aborted the takeoff because of a fault indication. Sky West has 

asserted that the pilot's action.s were the re<mlt of incompetence or bad judgment. We 

vehemently disagree. 

' 5 2. The pilot made an entry in the aircraft maintenance log describing the observed 

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mechanical irregularity, as required by 14 C.F.R., l'art I 21.563 and Sky West's flight 

oper,ations procedures. Again, Sky West insists the pilot's entry was an error, driven 

by the pilot's incompetence and lack of judgment, 

3. Given the aborted takeoff and maintenance log entry by the pilot, Sky West was 

obligated by regulation, operations specifications and their maintenance program to 

effectively isolated and cm1·ect the cause of the indicated fa11it. Sky West asserts their 

maintenance program merely represents their core maintenance procedures and that 

they arc not binding. 

4. Sky West Airlines argues that q11allfied mechanics and maintenance controllers have 

the artistic license to create new maintenance procedures on an ad hoc basis as a 

particular maintenance scenario may dictate. We disagree. 

5. Sky West Airlines argues that excerpts from the ai'1Jlane flight manual (QRH) are 

perfectly suited to the performance ofmain.ten.anoe because they were produced by 

Bombardier. It is the FAA's position that the QRH was not developed or intended to 

COM?L~lNhNt'S REPL~ HEAR~NG D~T~F 

S!<YWSST ATRT..!N"R.~- FDMS No F'AA~2011 .. 0782 

'S-AP. D\SE No, 2010NM06003], 

P.a.ge 2 ot 1, ~-

/{)'f.,P. F:. LDlM.ZCW 1 FF/>.A ATTORNEY 

TEJ..<: (112!;;)227-11::41; ~AX: (425)2?.7-JOO? 

PAGE 03/12 
03/14/2013 08:15 4252271007 ANH7 

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be used "in lieu" of maintenance or for the expeditious elimination of fault 

indications. 

6. Sky West Airlines insists the subject aircraft was not unairworthy. It is the FAA's 

position that the aircraft was indeed operated in an unairworthy condition boca11se it 

did not conform to its type design with inoperative systems/components, even if the 

failures were, initially, intermittent The FAA also cites US Air vs. FAA in which the 

ALJ found that an aircraft subject to a legally required inspection (fault isolation 

procedures) is "unairworthy" when operated without the benefit of the inspection. 

~o 7, SkyWe$t Airline~ suggests the fact that the subject aircraft required extensive 

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maintenance to finally return tho aircraft to service was merely a coi.ucidence.lt is the 

FAA's position that the failures were the cause of the original aborted takeoff and 

aircraft maintenance record eotry by the pilot 

8. Sky West claims the FAA failed to prove noncompliance with 14 C,F.R., Part 

43.l3(a), We note the FAA's case docs not allege noncompliance with .1 4 C.F.R., Part 

43, 13(a). To Sky West's "point" about failing to show their actions "in lieu" of 

maintenance were not "unacceptable"; we find their assertion moot. The primary 

violation is Sky West's failu'e to perform maintenance in accordance with their 

maintenance progr~m and associated operations specifications. By their own 

admission, they did not perform maintenance, whi.ch lead to the violations of their 

operations specifications and operation of an 1mairworthy aircraft. 

9, Pinally, unable to challenge the FAA's case on the facts, Sky West Airlines' 

erroneously stated this enforcement action is the result of the actions of a lone and 

COMI?Lli.INANT 1 s REPLY .tlflARING B:<IE:.f' 

Sr<YWF;51' 1\rR'LINES - FDt1S NO FAA-20J.l-07f.l).: 

FAA CMt:; No. 2010NM060081 

Page J of 11 '1'E:J,.~ (1'125)227-1947; ?P.X: (42.5)?,?,7-1007 

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uninformed FAA safety inspector (Gerhing). For the record, the FAA notes this 

enforcement action was subject to same due process and scrutiny as any other, That 

being the case, no fewer than 1 0 managers, supervisors, technical experts and 

attorneys concurs with the reporting inspector's allegations in this case. 

ARGUM.ENT 

17 DISCREPANCY vs. MALFUNCTION 

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The catalyst for maintenance action by Sky West should have been the aborted takeoff, the mechani.cal inegularity entered in the aircraft maintcnanc~ log by the flight crew, the 

fundamental requirements of the Sky West maintenance program (their CAMP) and federal 

regulations. The semantics of"discrepancy" vs. "malfunction" serve no purpose in this 

discussion. However, if Sky West had taken the aircraft out of service in response to the 

31 aborted take-off and maintenance log cntly by the Sk-y West flight crew, they would have 

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discovered and corrected the system/component failures as they eventually did when tl1ey 

realized the QRH "reset" was ineffective. 

The system/component failures and associated corrective actions that occurred the 

following day are indisputable evidence that the subject aircraft was experienci.ng problems 

(mechanical irregularities) as observed, and reported by the flight crew previously. The flight 

45 crew was properly certificated, rated, trained and qualified to fly this aircraft, and they did 

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exactly what they were supposed to do, given their training. Pilots are required to report what 

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COMPLAINANT'S R~PL¥ H~A~INQ B~~F.F 

SKYWRS:r' 7\J:RT.:!I:'l!i!.S:- PTJMS NO F'A'A-201l-0'791 

PAA Cl>.!flil No. 2010NM060081 

!?age 4 of 11 

KYL-E El. t..Oli'I.!\ZOW 1 FAA ATTORNEY 

TBL~ (<;i-25)227-~.947; FAX: (<\?.5)2/,7-1007 
03/14/2013 08:15 4252271007 ANH7 

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required to diagnose the problem (once on the ground) or to sort various mechanical 

irregularities into categories (some requiring action ... somc not). They simply observe (lnd 

6 report. On the other hand, maintenance personnel have the responsibility not to train pilots 

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over the telephone, but to follow prescribed (operations specifications) maintenance and 

inspection processes to determine the cause of the reported mechanical irregularity. Once the 

nature of a reported failure or malfunction is verified, maintenance personnel must either 

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return to service or issuing a dispatch release. 

n OPERATIONAL MANUALS ARE NOT MEANT FOR MAINTENANCE 

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Sky West is authorized to conduct operations under 14 C.F.R, Part 121 if they 

maintain their aircraft is accordance with their CAMP. There is no provision for avoiding 

maintenance by using flight operation manuals. Complainant has no objection to use of the 

QRH in the appropriate context. However, Complainru1t does not condone the use of the 

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is not about what WAS done, but what was NOT done. Maintenance was required and it was 

not performed. The aircraft was flown 8 times with passengers on board while the QRH 

41 experiment was in process. This experiment failed the following day lca.ving Sky West no 

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option, but to invoke the maintenance program, and replace the defective components. 

Sky West further argues that a manufacturer's maintenance manual cannot envision 

every malfunction or scenario that will occur to the aircraft during operation. The problem 

with that line ofthinldng is that Bombardier did in tact envision the mechanical problem 

CQMPLAINANT 1 S ReFLY HEARING BRISt 

S!C(WEST' AJ;Rt.;m;:s - F'DM$ No F.A!-\.~2011·"0782 

FA.Il,. C11.St: No. 2010NM060081 

Page 5 of 11 TEL: (425)227·1847; P.~: (425)227-1007 

PAGE 05/12 
03/14/2013 08:15 425227W07 ANH7 

1 reported by Sky West's flight crew and Bombardier did provide maintenance instructions 

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necessary to detect and correct the system/component failures.' 

Sky West also makes the extremely false argument that the QRH is in fact part of their 

a CAMP by referencing Standard l'ractice l'orrn 8600. 2 However, as Sky West is fully aware, 

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Standard Practice 8600 allows for the use of the QRH in flight as indicated by the language, 

''Once the QRH procedure, if applicable, is accomplished, the PIC (Pilot in Command) refers 

15 to the MELICDL/NEF to make the following decision:" One of those options is "retur!l for 

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maintcnan.cc," which is exactly what the Captain of this :Bight did. In other words, Standard 

Practi.ce 8600 allows a pilot to reference the QRH for in,flight issues, which is exactly what 

Complainant has argued aU along, To argue that Standard Practice 8600 authorizes the QRH 

for maintenance as well reads into the document what is absolutely not there. 

USE OF THE ORH TO PERFORM MAINTENANCE 

The methods, techniques and practices set forth in Sky West's CAMP are indeed those 

tbe FAA deems "acceptable." Sky West is required to adhere to their maintenan.ce program in 

accordance with 14 C.F.R., Part l19.5(g). The notion that line mechanics, maintenance 

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maintenance scenario is not only incorrect, but dangerous. Sky West, as it knows, may at their 

discreti.on, specify alternative procedures, however, those procedures must be included in 

,. maintenance program documents and incorporated into operations specifications, paragraph 

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5:2 ::~ R@.apondent.'s Brief, pa~e G. 

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COM'PT.,Jl.!N]l.liT' S RZPL.Y HRARIN13 B~tlElF 

SKYWRST AIRLINE~ - E'LiMS No FAA .. 2011~ 0782 

P.M C.!J.,SE No. 20l0N!'-10(.'IQ09;L 

P~ge (I of 11 TEL: (425)227-1847; FAX: (425)227-10{)7 

PAGE 07/12 
03/14/2013 08:15 4252271007 ANM7 

1 D072. In other words, Sky West maintenance workers cannot simply make it up as they go 

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6 THE AIRCRAFT WAS NOT AIRWORTHY BETWEEN MAY 30 AND JUNE 1, 2010. 

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Sky West would have followed the requirements of their CAMP when the mechanical 

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test flights. To suggest the preceding failures and aborted take-off were coincidental in the 

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In support of this argument in their hearing briet~ Sky West included part of the 

transcript on Page 82-83, but ended with Inspecto; Gehring answering "No," on page 83. 

However, what Sky West failed to include is the .rest of Inspector Gehrings testimony, which 

follows: 

Q: Exactly. Because it's a known condition of the aircraft that will happen if 

you. advance the throttle too quickly. Isn't that true? 

A: No. You advance tbe throttle slowly. You don't spike the system. Tbe 

system is still supposed to operate. Now the flight crew did a- - they told 

everybody, according to the interviews, that they did a normal open bleed 

takeoff, so it should work. And it gives them a message, it tells them what to 

do if they do that But this pilot had one pack iu op and the other pack shut 

down on him. And the flight crew made the command decision that the 

airplane was needed to stop so they aborted that takeoff. 3 

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S'- 3 Tr at 82-84, l.;l.ne:s 12 - 6. 

,, COM~LAINANT'S REPLY HEAR!NG BRIEF 

$l{VWR!=:T AIRLIN<:S - FDMS NO "f,?,AA-/,Oll-Cl'?8:2 

FAA CADE No. 2010NM060081 

P.8ge 7 of 11 TEJ.,~ {425)'2.~7-1347; FAX: (4/,l:i) 22.7-lOC? 

PAGE 08/12 
03/14/2013 08:15 4252271007 ANM7 

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Q: But it's your testimony that not in the MEL or GMM or any other awroved or 

accepted document is it a kDow:n condition of this aircraft that if you accelerated too 

qui~kly with one air conditioning pack deferred it will spike the pressure, latch a fault, 

That's not a known condition? 

A: It's not a known condition, Nowhere in the manuals does it say that this is a 

known condition, 

Sky West offered no evidence in the form of manuals indicating this is a knovm 

condition or any testimony from their mechanics to support this belief. In essence, Sky West's 

argument is that this is a known condition because Sky West says it is. 

1 SKYWEST'S CAMP ADDRESSES THE DISCREPANCY JN DETAlL 

The Fault Isolation Manual (FIM) is part ofSkyWest's camp and they are arguing in 

essence that they shouldn't have to follow their CAMP under the vague assertion that it is not 

detailed enough, Sky West cannot allow their maintenance workers to conclude on their own 

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allowed such leeway then there would be no use for a CAMP at all, 

lN THE l'r.lA TTER OF USAIR IS APPLICABLE 

Comrary to what Sky West would like to believe, In the Matter of USAJR, INC., J 996 

I. 

WL 509037, Docket No, CP94EA0045 is applicable for the reasons stated in Complaimmt's 

initial Brief and the reasons stated below, The USAir case is not only applicable, but very 

similar to the fact pattern here. Just as Sky West argues that they did not need to follow the 

Fault ]solation Manual because it was not detailed enough, the Respondent in US Air made a 

similar argument in. order to justifY not Llsing the maintenance manual in that case, However, 

the Administrator disagreed, stating that: 

"Although USAir may disagree with Boeing, the alrplanc manufacturer, 

about whether the melting of a wheel fuse plug is a good indicator of whether 

COMPL.r'\IN,\Nf'-S REPLY Hl?.~~I~O fiiRIEF 

SKYWEST :?\l;IH.TN"I?.."J - FDMS No FAA-2011-07!32 

FAA CASE: hlo. 2010N1-l06008l. 

!?age 9 of 11 

KYL..E E, LOI•lJi.ZOt.<, fi'{l\}:j. .i\TTOI'.NEY 

TEL: (1125)227~1847; FAX: (tJ?,5)2:a7-1007 
03/14/2013 08:15 4252271007 ANH7 

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a high energy condition has occurred; US Air is bound to follow che manufacturer's 

manuaL ...... US Air's brief suggests that the manual needs to provide certainty 

as to whether heat damage has occurred, but the argument makes no sense. 

The purpose of the inspection is to determine whether heat dan:tage has 

occurred." l,f.~ir at 4. 

s Similar to our case here, the purpose ofthe Fault Isolation Manual and the Aircraft 

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Maintenance Manual is to isolate the component that is failing and provide a remedy. 

USAir held that "an aircraft that has flown without required inspections is not 

'airworthy' within the meaning of the Federal Aviation Act, as amended, simply because it is 

later found to he undamaged." That rationale applies here as well. Considering the problems 

with the aircraft that resulted afterwards and the major maintenance that wa.s 'equired to 

repair the aircraft, the difference between the present case and the US Air case is that 

SkyWest's aircraft was in fact arguably damaged as a result o.ffailing to perform maintenance 

as per their CAMP. 

CONCLUSION 

Sky West used a flight operations manual in lieu of following their CAMP and as a 

result they operated an aircraft 8 times in an unairworthy condition. That is what this case is 

about and that is what Complainant has proven. Air carders have a GMM for a reason and 

they cannot be allowed to come with excuses for not following their maintenance program 

whenever it suits them. That is what Sky West did here and that is why they must be held 

COMPT,,AINAN'T 1 $ Rr:.?r .. Y H::MING BIUCTI" 

SK'!WEsT A.rRLrN:::s- FDNS No FAA ·2011-0782 

!fAA Cl\St No. :2010NM060081. 

P.age '.1 of 11 

!<HE r::. LOM.'\ZOW I fAA A'l''l'OR~18Y 

TeL, (425)227-1847; FAX' (425)227-1007 

PAGE 10/12 
03/14/2013 08:15 4252271007 ANM7 

,, 

2 responsible fo1· violations of 14 C.FK, Parts 119.5(g), 119.5(1), 12l.l53(a)(2), 

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121.709(b)(2)(i), and 121.605. As Sky West htis not conl:qted the sanction Complainant's request 

for the imposition of $68,500 should be afllrmed. 

'·" RESPECTFULLY SUBMITTED this 14'h day of March 2013. 

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' Kyle E. Lomazow 

FAA A ttorncy 

""'''"'"-.·~ '• 

COMPLJ:dNI\N't"' S R.EI:l,\'.,)1 HI~A.RING BRIBF 

Sr<.Y[1Fll~·:· .Anu,w~.S- J;DMS N(\ FAJ"\-20ll-DI82 

F;>.A C'h.<;r.: N(). 2010NM0~0081. 

Page 10 of 11 'T'E.L: (425}227-1847: FAX: (47.5):{.:;!7-1007 

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CEETIJTICATE OF SERVICE 

, I hereby certify that the foregoing Complainant's Brief, has been served via Facsimile and 

s Certified Mall this date, to the following: 

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The Honomble Richard C. Goodwin 

Office of hearings, M,20 

1200 New Jersey Avenue, S.E. 

East Bu.ilding Ground Floor, Rm E12-320 

Washington, D.C. 20590 

FAX: (202) 366-7536 

Fedeml Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

800 Independence AveS W 

Wllbu•· Wright Bldg.~ Suite 2\V!OOO 

Washington, D.C. 20591 

FAX: (202) 493·51.42 

Todd C. Emerson 

Sky West Airlines 

444 S. River Road 

St George, Utah 84790 

FAX: (435) 634·3505 

Dated this 14111 day ofMarch, 2013. 

COMF'LlltNJ\N1'' 8 RI\PT,Y HJ::?-i<ma f:'lln'S!' 

-1n 

Mary A Smith 

Office o ·Regional Counsel (ANM· 7) 

federal Aviation Administration 

1601 Lind Ave. SW 

Renton, W A 98057 

TEL: (425) 227-2925 

fA.,'{: (425) 227-1007 

SKY'I'IES"!' AI:l.LINL'i$ - FDMS No FAA-20U.~078?. 

PAA CJ\S£ NO, ?.OJ.QNMl.l60081 

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