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Thirty Eight South
23rd Jan 2007, 04:07
As seen today in Flight:

Airbus is questioning why its rival Boeing should be allowed to grandfather" the certification of the new 747-8 on the back of the original version of the aircraft, which entered service in 1970.

And European regulators want Boeing to be required to undertake a full evacuation demonstration of the new 747 variant - something it avoided doing when the -400 was introduced in 1989.

Under previous 747 stretch development studies, such as the 747X of 2001, Boeing had intended to adopt an all-new certification path, but says it will pursue certification for the 747-8I/8F under an amended 747-400 type certificate.

The 747-400 was itself approved as an amendment to the certification of the original 747-100 that was launched in 1966

Boeing claims it's an all new A/C for the twenty first century, why then do they intend to save development costs by not submitting the B747-8 to the pax evacutation certification required for 2007? It's our safety that's at stake

Volume
23rd Jan 2007, 06:39
This (http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgFinalRule.nsf/0/dffb17444a421c9a862568fd00664c02!OpenDocument) Document may be interesting to read for those, who want to understand the philosophy behind "grandfathering". (may need an hour to read, and much longer to understand...)
We know, that the 747 airframe is a non damage tolerant structural design, we know that the 747 does not comply with today´s rules for rapid decompression, sustained engine imbalance, uncontained engine failure etc.
The problem will be to prove, that all the changes that need to be introduced to make the 747-8 comply with todays rules, will "contribute materially to the level of safety of the changed product". The 747-400 fleet service experience meets the safety goal of the rule, to make a catstrophic event (which can be linked to the aircraft design, so no CFIT etc.) an extremely remote one (less than one catastrophic event per 100.000.000 service hours).
It is not fair for shure, to make the A380 heavier than it would have to be to meet the 747 type certification standard, just because it has to comply with today´s rules. But following the rules for changes to certified products, the 747-8 may come away with the old rules. The wording is not very specific, the changes are not that significant (different engines, small fuselage plugs, different wingtips) to clearly make it a new type.
Who wants to blame Boeing to rate economy higher than safety, when indeed the operators and the passengers do the same? If two versions of the 747-8 would be available, one certified per the actual rules, and one "grandfathered", and the ticket prices would be 5% higher for the newer one, which would the passenger choose? I bet for the cheaper ticket.
I personally are absolutely unsatisfied with this situation, I always want a product to be as safe as it could be, and not as safe as it must be, but many people have a different philosophy.
I read a statement in some aviation paper a few years ago, when an airline manager complained about todays safety standards, to be to expensive. He stated, that customers obviously accepted 1970s aviation safety standards, because otherwise air traffic would not have grown from there, as it did. So there is no reason to increase safety requirements, if the customers are indeed happy with the existing ones. There is some logic behind that.

Groundloop
23rd Jan 2007, 08:46
monkeybdg, but the 747-8 is bigger that the -400, ie 5.6m longer. Significantly more pax to exit it by the same number and size of doors. That's why an evacuation test should be required.

Jetstream Rider
23rd Jan 2007, 08:58
The Ford model T was very successful, so why make it any better? Operations have been done without anasthetic for hundreds of years so we obviously don't need it?

Statements like the managers words in Volumes post and those above are ridiculous. They stifle advancement and improvement. If only those managers could see how they are actually making things worse, then we might actually see real leaps and bounds in current aircraft operation. I'm not saying the 747-400 is a Ford model T, but taking these things to extremes often exposes how stupid they are. If 1970's safety standards were still in operation, we would have serious accidents every week and that wouldn't be palatable to any of us. Flap and gear controls the same size, position and shape anyone?

alexban
23rd Jan 2007, 10:06
groundloop..the difference between A318 and A321 or B737-600 and B737-800 is a lot bigger than 5.6 m .And I doubt they did a different pax evac test,or even certification.
Anyway,the A380 did a pax evac test for 800 pax,and flyies with only 550 ,maybe the 747 did the same.
How many seats are in a a jal 747,btw?

742
23rd Jan 2007, 10:47
The issue is safety, and the purpose of certification is to avoid problems in new designs. The later does not ensure the former.

The 747 has been flying for 37 years with an enviable safety record. Its problems were identified, and fixed, long ago. Given a choice of an airplane with such a service history and a new design that jumped through a bunch of hoops, be it an A380 or a 787, I think only a bureaucrat would argue that the later is “safer”.

Volume
23rd Jan 2007, 10:54
The 747-400D (Domestic) is a high density seating model developed for short-haul domestic Japanese flights. Capable of seating 568 passengers, the aircraft is the highest-capacity passenger aircraft in the world, even when the Airbus A380 officially enters service.
I don´t think the evacuation test will cause any problems, even if stretched by 5.6m, only a part of it will be in the "economy section" aft of the wing, and for the front end with the seats typical today, there will be no problem. The change for the rear end will mean a maximum of 3 additional rows, so we are talking about 15 persons per door more, most probably this can be done by extrapolation from existing numbers. The rules have not changed since these days, and some details of the test have been even relaxed. No total darkness is required anymore.
As stated above, damage tolerance, rapid decompression, uncontained engine failure, emergency landing will require a complete redesign of the fuselage structure, if it should meet todays requirements. But most probably it will not meet performance requirements of the operators with the additional weight... So either the 747-8 will be "grandfathered" or cancelled.

411A
23rd Jan 2007, 11:36
It makes no difference how much longer the airplane is (withing reason, IE: max 60 feet between exits, for example) but all has to do with the max capacity under original certification, with an equal number of exits.

Example.
Lockheed L1011, standard body aeroplane.
Max, 362, with six standard doors, and two smaller doors OR maximum 400 with eight standard doors.

B747 has 10 doors, except some with BA (as they apparently know better:ugh: )
Stretch the aeroplane.
Check the TCDS for the maximum capacity.
Add pax up to that maximum, with no additional evac demonstration required.
Done.

The Europeans?
They are just miffed because the white elephant (aka, A380) is overweight, overcost...and waaaay behind.

Ah, poor babies.:{ :{ :{

Groundloop
23rd Jan 2007, 11:46
groundloop..the difference between A318 and A321 or B737-600 and B737-800 is a lot bigger than 5.6 m .And I doubt they did a different pax evac test,or even certification.

But the A321 has a completely different exit layout than the A318/19/20. Something Boeing managed to get away with it when they produced the 737-800 and -900. They could continue with 4 small overwing emergency exits because the 737 had "grandfather rights". Airbus, on the other hand, because the A320 came under newer rules required the different exit layout when certifying the 321.

SADDLER
23rd Jan 2007, 12:21
I think 411A has hit the nail on the head.It all sounds like sour grapes.

Whitehatter
23rd Jan 2007, 13:24
Usual kneejerk replies from the usual suspects.

If you actually bother reading the articles instead of trying to mudsling at the A380, it makes sense. There is much more than just evacuation numbers being discussed.

Items such as structures and doors come into it, which were certified in the 1960s and could do with revisiting. John Leahy made an important point as well concerning the forward maindeck cabin of the 747, which might not be acceptable using today's design criteria for emergency exits.

The 747-400 already benefitted from one compromise with the old CAA/British Airways dispute. That was one example of stretching the 1960s design approvals to cover a new variant. The 747-800 is even more distant from the original aircraft and only those with a vested interest can seriously argue against the policy of safety first.

Or are Boeing profits more important than people?

Captain Airclues
23rd Jan 2007, 13:41
B747 has 10 doors, except some with BA (as they apparently know better:ugh: )

411A

All of BA's 747-400s have 12 doors. Several years ago BA removed the overwing doors (with Boeing approval) on the 747-200s (no longer in service) when they reduced the passenger capacity, leaving 10 doors (8 main deck and 2 smaller upper deck doors).

Airclues

ARINC
23rd Jan 2007, 15:21
Emotion doesn't enter into it.....It's Business

AB are in competition with Boeing, they are doing what any aggressive business does. They will take every opportunity to make life as difficult as possible for Boeing and naturally Boeing will reciprocate.

Heilhaavir
23rd Jan 2007, 17:10
groundloop..the difference between A318 and A321 or B737-600 and B737-800 is a lot bigger than 5.6 m .And I doubt they did a different pax evac test,or even certification.
Anyway,the A380 did a pax evac test for 800 pax,and flyies with only 550 ,maybe the 747 did the same.
How many seats are in a a jal 747,btw?
Don't know about JAL, but ANA's 744 carries 569...

Grunf
23rd Jan 2007, 17:40
Hello all.

This will be more a political issue and a marketing stunt then anything else.

747's structure, especially -400 on which -8 is based is an overkill, for most of it. For modifications (i.e all the ADs and consequent SBs) DTA was performed, as required by regulatory documentation. So the complaints about fail-safe vs.. DT does not stand, or at least it is hard to support it.

EASA and FAA will come to the same ground because there are many other bigger and more important project looming on the certification horizon like 777F, A330-200F, A330 conversions (passenger to freighter), 787, A350.

For each and every of them a tit-for-tat game can be played and this helps nobody. For those of you who need explanation on the term overkill: loads used for initial (conceptual) design were far higher then the real loads coming from the fleet usage. Overall the issues mentioned related to structure (alleged lack of DT analysis) are not correct.

Cheers

Thirty Eight South
23rd Jan 2007, 20:06
[/quote]"The Europeans? They are just miffed because the white elephant (aka, A380) is overweight, overcost...and waaaay behind.

Ah, poor babies.:{ :{ :{[/quote]

-Maybe, but the point is that the B747-8 is an ICAO code F A/C for Airfield Rescue and Fire Fighting-a classification it uniquely has in common with the Airbus A380. Both of these A/C have to comply with this ICAO classification; it's not negotiable.

If I was an airport safety operator or authority I would be very interested to know that the passenger evacuation certification criteria are for any new large aircraft that is to begin operating into my airport, particaulary the certification issue; Airbus have a point, why does the rule apply to one airframer and suppossedly not the other?

And as for politics getting invovled - who started the WTO A350 v 787 wrangling?

CargoOne
24th Jan 2007, 11:48
Is it true that evacuation from 747 upper deck using the slides was never demonstrated by Boeing? I read somewhere they only evacuated passengers from upper deck using the stair to main deck and slides from there?

Taildragger67
24th Jan 2007, 12:28
We know, that the 747 airframe is a non damage tolerant structural design, we know that the 747 does not comply with today´s rules for rapid decompression, sustained engine imbalance, uncontained engine failure etc.

OK, it's only one instance so a very small survey sample, but didn't the incident with a UA Classic out of Honolulu go some way to indicating that a 747 could cope with a pretty big bit of damage (loss of a cargo door and surrounding skin), rapid decompression (which followed the loss of the cargo door) and sustained engine imbalance (3 & 4 out all the way back to HNL)?

As long as the cargo door lock design fault was rectified, that incident actually reassurred me with respect to the 747's hull strength and survivability.

Taildragger67
24th Jan 2007, 12:31
We know, that the 747 airframe is a non damage tolerant structural design, we know that the 747 does not comply with today´s rules for rapid decompression, sustained engine imbalance, uncontained engine failure etc.

OK, it's only one instance so a very small survey sample, but didn't the incident with a UA Classic out of Honolulu go some way to indicating that a 747 could cope with a pretty big bit of damage (loss of a cargo door and surrounding skin), rapid decompression (which followed the loss of the cargo door) and sustained engine imbalance (3 & 4 out all the way back to HNL)?

As long as the cargo door lock design fault was rectified, that incident actually reassurred me with respect to the 747's hull strength and survivability.

Further, can anyone advise on what extra hoops had to be jumped through for the A340-500 and -600 as opposed to the -200 and -300? Without checking the numbers, I'd think that a -600 is at least as much longer than a -200, than the 748 will be over a 744.

Porrohman
24th Jan 2007, 16:18
If the 737-400 had been required to undergo a more comprehensive set of certification trials before carrying fare-paying passengers could the Kegworth accident, and several other 737-400 incidents around that time, have been avoided?

I know there were other contributory factors to the Kegworth accident, but the chain of events began with an issue that, it could be argued, should have been detected during the certification process had "grandfather" rights not been applied.

I know they changed the rules about engine certification, but have the other rules regarding "grandfather" rights altered since the Kegworth accident? If not, certain issues with the 747-8 might not be discovered until airline pilots and fare-paying passengers are on board, and one of the important lessons from the Kegworth accident will have been lost.

b.t.w. I've seen at first hand (fortunately in an environmental test facility) the effects that modifying a large structural component of an aircraft had on its resonant frequency and integrity. Our Client wanted us to significantly reduce the weight of the component, and this appeared to be feasible, however the weight reduction significantly altered the resonant frequency of the component. This resulted in all of the aircraft standard fasteners rapidly unwinding when the component was subjected to the expected vibration conditions. The fasteners unwound and the maintenance access panels fell open within seconds of the vibration test commencing. We tried beefier and beefier fasteners, but to no avail. It was amazing to see and surprised everyone except our chief mechanical engineer who was very experienced and had seen this sort of thing before. The solution to the problem was to offer less of a weight reduction, which resulted in a component that had a resonant frequency that was compatible with the rest of the airframe.

Porrohman.

Grunf
24th Jan 2007, 16:40
If the 737-400 had been required to undergo a more comprehensive set of certification trials before carrying fare-paying passengers could the Kegworth accident, and several other 737-400 incidents around that time, have been avoided?

I know there were other contributory factors to the Kegworth accident, but the chain of events began with an issue that, it could be argued, should have been detected during the certification process had "grandfather" rights not been applied.

Have the rules regarding "grandfather" rights altered since the Kegworth accident? If not, certain issues with the 747-8 might not be discovered until airline pilots and fare-paying passengers are on board, and one of the important lessons from the Kegworth accident will have been lost.

b.t.w. I've seen at first hand (fortunately in an environmental test facility) the effects that modifying a large structural component of an aircraft had on its resonant frequency and integrity. Our Client wanted us to significantly reduce the weight of the component, and this appeared to be feasible, however the weight reduction significantly altered the resonant frequency of the component. This resulted in all of the aircraft standard fasteners rapidly unwinding when the component was subjected to the expected vibration conditions. The fasteners unwound and the maintenance access panels fell open within seconds of the vibration test commencing. We tried beefier and beefier fasteners, but to no avail. It was amazing to see and surprised everyone except our chief mechanical engineer who was very experienced and had seen this sort of thing before. The solution to the problem was to offer less of a weight reduction, which resulted in a component that had a resonant frequency that was compatible with the rest of the airframe.

Porrohman.

Porroohman,

One of the certification issues mentioned above is the structure (which I have commented). Since Kegworth, as bad as it was, was an issue primarily with engines and systems design (fuel system to be more specific) it could be a completely separate topic.

As for the structure 'grandfathering" is not a big problem (see what flies above our heads, for that matter!). In case of new systems I think Boeing has learned its lesson with Kegworth, at least (as well as the rudder issues etc).
In case of vibrations, however, it depends if the piece you were working with was part of primary or secondary structure, if it was an SSI/PSE etc. In general and from what I've seen none of the OEMs (commercial) are having much concern over vibration issues. Sadly, but this is truth.:E

Of course they do verify maybe for the first 2 modes for the overall aircraft model (a very lumpy one, mind you) but I've never seen detailed work as it is necessary for military projects.

So, certification issues with "grandfathered" structures are usually with systems, not structure.

One gets to mind Bombardier's series of RJs (CRJ 200, 700, 900 and future "extended" 900) which are all DERIVATIVES of the original CL600 Challenger?! Talk about grandfathering, huh?:ugh:

Cheers

Tallbloke
24th Jan 2007, 20:03
Is the 747 unique in having no forward exit for the front cabin?

barit1
25th Jan 2007, 00:30
The Ford model T was very successful, so why make it any better? Operations have been done without anasthetic for hundreds of years so we obviously don't need it?...

The reason the Model T was finally discontinued is that the market discovered newer cars to be more efficient, safer, more reliable --- and they quit buying the "T".

When the A380 demonstrates superior statistics in service, the falling 747 sales will tell Boeing it's time to start a fresh design. Until then, 1966 vs 2007 original cert standards will have little influence on the marketplace.

Volume
25th Jan 2007, 13:00
OK, it's only one instance so a very small survey sample, but didn't the incident with a UA Classic out of Honolulu go some way to indicating that a 747 could cope with a pretty big bit of damage (loss of a cargo door and surrounding skin), rapid decompression (which followed the loss of the cargo door) and sustained engine imbalance (3 & 4 out all the way back to HNL)?

The Aircraft in question was a 747-100, which means a lower load level anyway (lower MTOW) and much smaller engines than the -400 or -8, thus smaller loads due to sustained engine imbalance for a shorter time period (lower range).
The door took away a big part of the main deck sidewall, which was a good thing, as the main cabin decompression was through that hole, and not through the cargo door opening. otherwise the main deck floor would have most probably collapsed. (Not THAT bad for a 747, as the flight controls do not run in the main deck floor, but in the main cabin crown area, so not that fatal as for the THY DC-10 in Paris, the accident which forced the rules to be changed wrt. rapid decompression). Rapid decompression is most critical for the smallest volume (in that case for the cockpit), as the small air volume escapes quite fast for a given hole size, imposing a greater pressure difference end hence pressure load on the structure separating that area from the main cabin. A big hole in the cockpit roof may make the cockpit floor collapse into the cockpit, killing the crew and severing the flight controls running there. The 747-400 with the old european "4-country-certification" (it was pre JAA certification times...) has a reinforced upper deck floor to cope with the JAR decompression rule, which required a bigger hole to be taken into account compared to the FAR requirements those days.
For the damage tolerant structure, the China Airlines crash clearly demonstrated, that the rear fuselage is not able to cope with a certain crack size, the frames are not able to stop or bridge a crack growing over a certain length in the longitudinal direction. With respect to the widespred fatigue damage criteria taken into account today, the 747 will also have some problems demonstrating compliance.
To be fair, the 747 is not "1960´s safety standards" today, as some measures have been taken retroactively to all aircraft, for example the fatigue and damage tolerance issues past the aloha-accident. So Boeing demonstrated, that the 747 can take a little more, than demonstrated according to the initial rules. But demonstrating that it is 2006 safety standard, looks impossible to me.

Taildragger67
25th Jan 2007, 13:24
Volume,

Thanks. Full & complete, QED!

Cheers
TD67

Tallbloke,
Yes AFAIK amongst current civils.

Grunf
25th Jan 2007, 16:04
Volume,

I quite agree with your statements, especially the China Airlines stuff. Again, this was covered with several SBs and consequently appropriate analysis (DTA including) was completed with new inspection intervals.

As for meeting the 2006 safety standards if we go back I would be ready curious to see how is Airbus going to certify the A330-200F as a derivative since it will be non-compliant to the new requirements, as well. Not on the level of 747 of course but still not meeting all the requirements (come to think the new EASA requirement of 2G Up for the cargo floors etc).

Also, a good example would be the pain Lockheed is seeing when trying to sell more Hercules' as they were never certified by FAA (nor designed per FARs). Someone these days requires that for the new sales and bang, a big problem is generated.

Grandfathering is a slippery road but there is always a way to go through, at the end. We can like it or not but IMO one needs to know the relations between Boeing and FAA and Airbus and vice versa EASA/JAA.

One would assume the impartiality in both cases but then if you work for some other OEM (Bombardier, Embraer) then you find out how these relations work:{ . I had a painful experience with both JAA and FAA related to that and nowadays I can again see how it looks when you're on the "right side".:cool:

Cheers

alexban
27th Jan 2007, 09:15
As far as I remember Kegworth is a case of mistakenly identifying the faulty engine,so what has to do with 'grandfathering' ?
Are you talking about the fact that a blade ruptured in one engine? So..?
As I remember,they incorrectly checked the vibration indicators (low is good as opposite to all other instruments ) ,and also helped by the fact that the vibrations reduced with reduced thrust,as they level off and desended, they decided to shut-down the good engine. After resuming thrust ,the bad engine failed,so they remained without engines,and landed short.
So ,again,what's with the 'grandfathering'..?

Porrohman
27th Jan 2007, 10:54
Alexban;

Due to "grandfathering", Boeing did not fully test the new engine / airframe combination. Here's an extract from Wikipedia;

"Analysis of the engine from the crash determined that the fan blades (LP Stage 1 compressor) of the uprated CFM56 (http://en.wikipedia.org/wiki/CFM56) engine used on the 737-400 were subject to abnormal amounts of vibration when operating at high power settings above 25,000 ft. As it was an upgrade to an existing engine, in-flight testing was not mandatory, and the engine had only ever been tested in the laboratory. Upon this discovery all 737-400s (around 100 at the time) were grounded and the engines modified. Following the crash, it is now mandatory to test all newly designed and signficiantly redesigned turbofan engines (http://en.wikipedia.org/wiki/Turbofan_engine) under representative flight conditions."

The full article is here; http://en.wikipedia.org/wiki/Kegworth_air_disaster

In the Kegworth example, the application of "grandfathering" resulted in the engine problem that started the chain of events that led to the accident. The rules regarding engine certification were changed following Kegworth. What I'm not sure of is whether rules concerning other aspects of "grandfathering" have also been changed. If not, there is potential for "granfathering" to result in future problems.

Porrohman.

lomapaseo
27th Jan 2007, 12:32
Alexban;
Due to "grandfathering", Boeing did not fully test the new engine / airframe combination. Here's an extract from Wikipedia;
"Analysis of the engine from the crash determined that the fan blades (LP Stage 1 compressor) of the uprated CFM56 (http://en.wikipedia.org/wiki/CFM56) engine used on the 737-400 were subject to abnormal amounts of vibration when operating at high power settings above 25,000 ft. As it was an upgrade to an existing engine, in-flight testing was not mandatory, and the engine had only ever been tested in the laboratory. Upon this discovery all 737-400s (around 100 at the time) were grounded and the engines modified. Following the crash, it is now mandatory to test all newly designed and signficiantly redesigned turbofan engines (http://en.wikipedia.org/wiki/Turbofan_engine) under representative flight conditions."
The full article is here; http://en.wikipedia.org/wiki/Kegworth_air_disaster
In the Kegworth example, the application of "grandfathering" resulted in the engine problem that started the chain of events that led to the accident. The rules regarding engine certification were changed following Kegworth. What I'm not sure of is whether rules concerning other aspects of "grandfathering" have also been changed. If not, there is potential for "granfathering" to result in future problems.
Porrohman.
The discussion is OK but the inference varies greatly with the subjectivity and the relavance to the thread title.
The words 'fully test" have a very broad meaning among certification engineers. Thus the word "garndfathering" has an equally broad and subjective meaning. The objective is to define the product in engineering terms such as vibratory stress and frequency over the complete expected operating environment. Then to provide for variations in tolerance (both mechanical and operational) to ensure that it is unlikely that the product will fail in this environment.
The certification standards provide boundries to the level of mechanical tolerance within defined levels of environment. The certification testing provides data for analysis to show that the expected variations in mechanical conditions in context with the expected environmental conditions will not result in a failure condition.
We have long since progressed way beyond the build-m and bust-m stage and that includes such margin tests as the blade-off and ingestion tests. Instead, all test data is considered as sucessful and applied to analysis. This is then taken together with past experience or history and can be interpolated in a far broader range than any affordable testing of the one product/environment example at hand could demonstrate.
So, in the lessons learned sense, the only useful tweaking of the meaning of "mandantory" is that all parts of the certification process need be examined when there is a shortfall and not necesarily just a simple test requirement.
OK, now to get back to the thread subject at hand.
Is there a shortfall? (if it ain't broke, don't mess with it)
Has the total industry wide experience indicated a change in the environment?
Is the previous test data and analysis still credible? or has the environment substantially changed?
For the questions above, what level of new data and analysis are necessary for validation?
Notice that I always use the term data and analysis together if one is to make any worthwhile subjective opinion.

Porrohman
27th Jan 2007, 17:20
lomapaseo,

I agree with your comments. I see merits in "grandfathering" where it's appropriate and I see merits in "fully test" where the data from previous tests might not be relevant to the modified aircraft.

The manufacturer and the certification authority need to apply very careful judgement in relation to where they apply "grandfathering" and where they decide to "fully test" to obtain new data for analysis. I expect that this will involve educated, well intentioned but subjective judgements in relation to certain issues. In the case of Kegworth, these educated, well intentioned but subjective judgements were, with hindsight, flawed. Some might argue that the different vibration characteristics of the new airframe / engine combination should have been foreseen and that new data for analysis should have been obtained before releasing the 737-400 to airline pilots and the travelling public.

We rely upon the certification authorities and the manufacturer to make the correct decisions in relation to this matter and we trust they will have learned from the Kegworth accident.

Porrohman.

alexban
27th Jan 2007, 21:23
If you have some time it may prove a very interesting reading of the kegworth accident report (he 638 kb pdf file ) ,found here ..http://www.aaib.gov.uk/sites/aaib/publications/formal_reports/no_4_90_502831.cfm
121 very interesting pages