Dave,
“… it's fun to ridicule government employees, isn't it?” yes, but … “It would be a mistake to assume the FAA engineering staff is incompetent …”. I totally agree, but there are occasions where mild ridicule which refocuses attention might improve the objectives of a safety message.
Undoubtedly this issue is being considered by many parties with great expertise and who have access to more information than is made public, but the quality of these activities is often judged by what is said / published.
DOT/FAA are the custodians of safety and publications – even though the text may be drafted elsewhere; they, at the end of the process, should be expected to ask if what is being conveyed makes sense and will it achieve the objective. Are the explanations and procedures written from their point of view, with their responsibilities for safety in mind, or from the views of operators and the pilots who have to judge and manage the risks in potentially hazardous situations.
Regulatory authorities provide guidance on risks - as to what might be acceptable or not; in simple terms they ‘take a risk’, based on well-judged and proportioned reasoning to maintain the required safety level. However, it is the pilots who ‘run the risks’; theirs’ is the final safety call which often depends on situation assessment, which in this instance requires clear and concise depiction of the conditions and how they can be identified.
This is an onerous task for everyone in the process and warrants careful thought, which from the current public view might have been better considered.
Yes the above is posted with hindsight, but better to consider this hindsight as foresight now, rather than start again after an incident; then the judgement of economic aspects, etc (a fine balance with safety) will be wrong, whereas today, ‘it is right’.