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Thomas J. Connolly________________________________________________________
600 S. Clyde Morris Blvd.
Daytona Beach, Florida 32114-3900


Mr. Robert Lee Cunningham
Principal Maintenance Inspector
Federal Aviation Administration
Orlando Flight Standards District Office, ASO-15
5950 Hazeltine National Drive Suite 500
Orlando FL 32822-5023

February 23, 2000

Dear Mr. Cunningham:

Your January 18, 1999, letter addresses several issues pertaining to Embry-Riddle's fleet of Cessna 172R aircraft. It is accurate regarding the types of problems we have been experiencing since the aircraft began arriving at the University in 1998. We agree with your statement that the problems have not gone unnoticed here and that we have worked relentlessly to develop a comprehensive program to achieve conclusive results. We are concerned with your implication that Embry-Riddle alone is responsible for taking conclusive action to solve this problem.

Cessna, Textron-Lycoming, Precision, Dakes and others contributed to the design and manufacture of the aircraft. Embry-Riddle is one of many users. We are required to maintain these aircraft and engines using only that information and data "acceptable to the Administrator."

We have been using and will continue to use the appropriate factory-approved Maintenance Manuals, Service Bulletins, Airworthiness Directives, Type Certificates, Supplemental Type Certificates, field approvals and DER Approved documents when repairing or altering these aircraft.

We do not have any authority to engage in research and development, engineering, trial and error or any other maintenance practices that are contrary to those documents. To do so would be a serious violation of the Federal Aviation Regulations and expose our students and instructors to absolutely unacceptable risks.

What this means is this: we do not have, unilaterally, the authority or the resources to provide for or implement a solution to take "conclusive action to eliminate this problem." That responsibility belongs where, in all likelihood, the problem originated, with the designers and manufacturers, not the University. That direction must come from the manufacturer and the contractors that helped produce the aircraft.

In the near future we will meet with senior members of Cessna's organization here at the University to discuss the very issues you identify in your letter. In late March key members of the University staff will attend the Cessna User's Conference in Independence Missouri. We will all continue to work together to find a solution. The University is eager to see the problem eliminated and continues to seek specific guidance from the FAA and the manufacturers.



Thomas J. Connolly, Ed.D


Leading The World In Aviation and Aerospace Education


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