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UNITED STATES DEPARTMENT OF TRANSPORTATION . ' " ^' ^^ , -^^ ^ 

I'KDERAL AVIATION ADMINISTRATION - - ' . ' _?. ; . / --..{ ) 

* FAA Docket No.CPl OSW0006 

-" 'izotO:/ 

In ihc Matter of: * •' ''^ C ""^fj ^ 

* 

* DMS No-FAA-2010-0532 S^ ^ 

AMERICAN AIRLINES, INC. * V >- § 

* ro OP ^ 

* Hon. Richard C. Goodwin (ALT) -cr to 

COMPLAINANT'S SKCONP AMENDED RESPONSE TO RESPONDENT'S FIRST SET OF 

INTERROGATORIES TO COMPLAINANT 

Tnicrrogatory 3. 

3. Please identify all FAA rules, regulations, orders, policies and/or other reference documents, 

whether Formal or informal, that evidence, refer or relate to a Flight Fault Review ("FFR"), as 

alleged in Paragraphs II (7)-(8) in the FAA's Complaint. 

RESPONSE: 

Objection is made lo this response as it is overly broad and burdensome. All documents in 

Complainant's EIR or which are intended TO be used ai trial have been provided to Respondent or 

arc incjtided herewith. Further, Flight Fault Review (FFR) is not related to the FAA, but rather is 

a function of equipment installed on aircrali operated by American Airlines. American Airlines 

has custody and control of any such documents which may exist. 

4. Plea,se identify all FAA rules, regulations, orders, policies and/or other reference documents, 

whether formal or informal, that evidence, refer or relate to the interpretation of Respondent's DC9 MEL Item 22-2(b). 

RESPONSE: 

Objection is made to this response as it is overly broad and burdensome. All documents in 

Complainant's EIR and expected to be used at the time of trial have been provided to Respondent 

or are included herewith. 

5. Please identify each and every fact thai supports your contention in Paragraph IT (17) of the 

Complaint thai "the proper deferral option would have been to placard the duplex rudder servo in 

accordance with MEL 22-16." 
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RESPONSE: 

The Flight Fault Review revealed the autopilot duplex rudder servo had failed. There is only one 

autopilot duplex rudder servo on the aircraft, fhat servo was bad. A ftilly functioning autopilot 

duplex rudder servo is required for die autopilot coupled (ILS) operations, category 2 operations 

and automatic go around. The proper deferral option would have been to comply with MEL item 

22-16. 

7. Please identify each and every document that refers or relates to your contention in Paragraph 

11 (17) of the Complaint that "the proper deferral option would have been to placard the duplex 

rudder servo in accordance with MEL 22-16." 

RESPONSE; 

Op Specs , page D-085-10 (lOP 3) is a function of equipment installed 

Log pages form E-6 logboolc for aircraft 454 (TOP 4) 

Computers print out from American Airlines computer (lOP 5) 

Copy of American Airlines MD-80 maintenance manual (lOP 6) 

Copy of Page 22-2 of American Airlines MD-80 MEL (lOP 7) 

Copy of page 22-12 of American Airlines MD-80 MEL (lOP 8) 

Copy of page 22-12 of American Airline MD-80 MEL (lOP 9) 

Copy of repair report from Honeywell Inc (lOP 15) 

Copy of Page 22-11 of American Airlines MD-80 MEL previously provided. 

REQUESTS FOR PRODUCXrON 

3. All Documents related to any side or personal fiJe(s) kept or maintained by FAA personnel 

regarding FAA Case No. 2008SW210058, specifically including FAA Inspectors Andrew Blosser, 

C.J. Di Ccsarc and William 1", Sallerlield. 

RESPONSE: 

Any documents responsive to this request are enclosed. 

10. All Documents related to a Flight Fault Review, specifically including its intended use and/or 

limitations. 

RESPONSE: 

Flight Fault Review is not an related to FAA but rather is a function of equipment installed on 

aircraft operated by American Airlines. /Vmerican Airlines has custody and control of any such 

documents which may exist. All documents in Complainant's EIR and expected to be used at time 

of trial have been provided to Respondent or arc enclosed herewith. 

11. All Documents related to other FAA enforcement proceedings in which FAA has alleged that a 

Pan 121 air carrier improperly relied on DC-9 MEL System 22 (Autoflight) to defer maintenance. 
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RESPONSE: 

Objection is made to this Request for Production in that the information sought is not relevant to 

the facts of this case nor calculated to lead to any relevant information. Objection is made to this 

Request for Production in that it is overly broad and burdensome. All documents in 

Complainant's EIR and expected lo be used at time of trial have been provided to Respondent or 

are enclosed herewith. 

15. All Communications between I'"AA Inspector Andrew Blosser and anyone else regarding 

American's compliance with Federal Aviation Regulations. 

RESPONSE; 

Complainant objects to this Request for Production as it is that it is overly broad and burdensome. 

Objection is made to Request for Production No. 15 as it is vague and ambiguous. 

18. All Documents related to Your contention that "[a] fully functioning autopilot duplex rudder 

servo is required for the autopilot to function properly," as alleged in Paragraph II (11) of the 

Complaint. 

RESPONSE: 

Objection is made lo Request for Production No. 18 as it is vague and ambiguous. All documents 

in Complainant's EIR have been provided to Respondent. All documents in Complainant's EIR 

and expected to be used at time of trial have been provided to Respondent or are enclosed 

herewith. 

19. All Documents related to Your contention that "[d]eferral using MEL, Item 22-2b was 

improper," as alleged in Paragraph II (14) of the Complaint. 

RESPONSE: 

Objection is made to Request for Production No. 19 as it is vague and ambiguous. All documents 

in Complainant's EIR and expected to be used at time of trial have been provided to Respondent 

or are enclosed herewith, 

20. All Documents related to Your contention that "jtjhc proper deferral option would have been 

(0 placard the duplex rudder servo in accordance with MEL 22-16," as alleged in Paragraph II (17) 

of the Complaint. 

RESPONSE; 

Objection is made lo Request for Production No. 20 as it is vague and ambiguous. All documents 

in Complainant's EIR and expected to be used at time of trial have been provided to Respondent 

or are enclosed herewith. 
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Re.spectfully submitted, 

LYNETTE WORD 

Regional Counsel 

Southwest Region 

/ 

By: 

Yolanda Ayala B^rnal 

Attorney / 

Safety Enforcement Branch 

Phone: (817)222-5070 

FAX; (817) 222-5945 or 5092 
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CERTIFICATE OF SERVICE 

I hereby certify that on September 13, 2010, an original and one copy of 

COMPLAINANT'S SECOND AMENDED RESPONSE TO RESPONDENT'S 

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS was sent by 

Federal Express Mail to: 

I-ederal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building Room2W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

I hereby certify that on September 13. 2010, a copy of COMPLAINANT'S SECOND 

AMENDED RESPONSE TO RESPONDENT'S INTERROGATORIES AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS was sent by Federal Express Mail to; 

The Honorable Richitrd C. Goodwin 

US Department of Transportation, Office of 1-Iearings, M-20 

1200 New Jersey Avenue, S.E. 

Cast Building Ground Floor, Room El2-320 

Wa.shington, DC 20590 

Evan P. Singer, 

Jones Day 

2727 North Harwood St. 

DaWas.iX 75201-1515 

Sylvia C. Twa, Paralegal 

Office of Regional Counsel 

Federal Aviation Administration 

Fort Worth, TX 76137 

Date; September 13, 2010